Introduction

Your privacy and maintaining the confidentiality of your personal information is important to Indi. This document describes how we handle your personal information in our dealings with build to rent assets, including how we collect, store, use and disclose your personal information, how you can access and change your information, provide us with feedback, or make a complaint.

In this Document ‘Indi’, ‘we’, ‘us’ and ‘our’ refer to Investa Management Holdings Pty Ltd (ACN 126 219 903), Indi Management Services Pty Ltd (ACN 650 857 266) and their related and associated entities, in their dealings with build to rent assets.

This Policy sets out how we collect, store, use and disclose your personal information in accordance with the Australian Privacy Principles contained in the Privacy Act 1988 (Cth) (“Privacy Act”).

This Policy covers the ways an individual’s personal information is treated. This includes through physical communications, email and when you access and interact with the Indi website at www.Indi.com.au, and/or any other websites operated by Indi from time to time that reference or links to this Policy.

The purpose of this Privacy Policy is to generally inform people of:

• how and when we collect personal information and personal data;
• how we use and disclose personal information and personal data;
• how we keep personal information and personal data secure, accurate and up-to-date;
• how you (as an individual) can access and correct your personal information and personal data; and
• how we will facilitate or resolve a privacy complaint.

If you have any concerns or complaints about the manner in which your personal information and personal data has been collected, used or disclosed by us, we have put in place an effective mechanism and procedure for you to contact us so that we can attempt to resolve the issue or complaint. Please see section 10 Resolving Privacy Complaints for further details.

We recommend that you keep this information for future reference. 

What is personal information?

“Personal information” means any information or an opinion about an identified individual, or an individual who is reasonably identifiable:

• whether the information or opinion is true or not; and
• whether the information or opinion is recorded in a material form or not.

The kinds of personal information or personal data collected, used and disclosed by Indi.

While Indi has arrangements in place for third parties to manage the operations at its Sites, those unrelated third parties may provide personal information to Indi.

We will only use or disclose your personal information or personal data for the primary purposes for which it was collected, as consented to by you or otherwise in compliance with the Privacy Act.

At or around the time we collect personal information or personal data from you, we will aim to provide you with a notice which details how we will use and disclose that specific information.

We set out some common collection, use and disclosure instances below.

Common collection, use and disclosure instances

Residents

Type of information

• Contact and identifying information:
  • Your name, date of birth, address, billing address, email address, phone and fax numbers, nationality, residency or visa information and, gender.
  • Alternative Contact names, address and phone number, emergency contact details).
  • Bank account, online payments system, credit or debit card details.
  • Details of required primary identification information (such as a current driver’s licence, passport, etc).
• Medical conditions
• Background check: information obtained from you or third parties to perform background checks.
• Previous tenancies: If you are an applicant, details of your previous residential tenancy arrangements including the landlord/letting agent’s contact information, your tenancy period, and whether your security deposit/ bond was refunded in full (including reasons, if any).

Uses

• Identity verification: if required, the verification of your identity and proof of residency status in Australia.
• Resident Application: the consideration and processing of your accommodation application and associated lease and bond documentation.
• Term of residency: to conduct premises inspections and collect personal belongings from the premises at the end of your residency, and to ensure the safety of all residents at any given time.
• Resident activities and events: collection of your personal information or personal data to facilitate your participation in activities and events, where applicable.
• Payments and purchases: The processing of any payments and refunds, credit card authorisations, verifications and debt collection, if applicable.
• General administrative and security use:
  • The use for security and safety purposes, including the use of your details in a medical emergency or as lawfully directed or required by a government body.
  • The use for the administration and management of Indi.
  • The maintenance and development of our products and services, business systems and infrastructure.
• To provide customer services to clients and for quality assurance purposes.

Disclosures

We may disclose this type of personal information or personal data to: 

• Our contractors, agents and third party providers who manage the build to rent operations, and undertake billing, credit, caretaker, security, maintenance and utilities services on our behalf.
• Investors in the property that you are leasing from us.
• Third party providers who assist us in providing our products and services to you, or provide us with advice or other related services.
• Your previous landlord/letting agent, for the purposes of conducting a reference check and verifying your residential letting history.
• Third parties, such as external debt recovery agents, court or other entities to which we are required by law to disclose personal information or personal data.
• Government and regulatory authorities such as health authorities or agencies, the applicable residential tenancies tribunal (such as the NSW Civil and Administrative Tribunal) or the relevant police authority to conduct criminal checks.

Marketing, testimonials, surveys and competitions

Type of information

• Contact information: Such as your name, email address, current postal and residential addresses, phone numbers, country of residence (and, if applicable, age).
• Website enquiries: Such as your name, email address, phone number and any information you provide to us as part of your message.
• Social media activity: Including “likes”, comments posted, any of your oppositions or feedback, photos posted or uploaded and other information pertaining to your social media activities which concern, or relate, to Indi.
• Competitions and surveys: Any personal information or personal data you include in any survey answers or competition entries you send to us.
• Contact details and testimonials: If you agree to be engaged for testimonial purposes for inclusion in our promotional material, your photograph, name, testimonial and any other personal information or personal data you disclose on our Consent to Release Image or Recording Form and in any recordings themselves.

Uses

• General marketing, surveys and consumer analytics:
  Using your personal information or personal data:
  • To aggregate with other information and to then use it for marketing and consumer analytics.
  • To offer you updates on products, events or information that may be of interest to you.
  • For Marketing and promotional activities by us (including by direct mail, SMS and email) such as our email alerts, product awareness information and

• Competitions
  • To facilitate your participation in our
  • To offer you updates on products, events or information that may be of interest to you.
• Online accounts or social media: If you participate in our social media platforms (such as Facebook) and you provide us with your personal information or personal data, we will use it for:
  • Adding account holders to the marketing
  • Customer service related
  • Responding to social media
  • Fulfilling social media platform rules.

Disclosures

• We may disclose your personal information or personal data to third parties connected with the marketing process who assist us in providing or marketing our products and services to you.
• All other personal information or personal data you provide to us as part of your engagement may be disclosed as follows:
  • Service providers (including IT service providers and consultants) who assist Indi in providing our products and services.
  • Related bodies corporate of Indi (including related entities).

• We will also disclose your personal information or personal data as required or authorised by law.

As much as possible or unless provided otherwise in this Privacy Policy or a notification, we will collect your personal information or personal data directly from you.

When you engage in certain activities, such as by submitting an online enquiry or participating in one of our surveys, we may ask you to provide certain information. It is completely optional for you to engage in these activities.

Depending upon the reason for requiring the information, some of the information we ask you to provide may be identified as mandatory or voluntary. If you do not provide the mandatory information or any other information we require in order for us to provide our products or services to you, we may be unable to provide our products or services to you in an effective manner, or at all.

(a) where you have expressed interest in, or applied for an inspection of, a property over a third party website or platform (such as realestate.com.au or domain.com.au), your personal information may be provided to us from the operator of the website or platform; 

(b) from third parties who are engaged to manage our build to rent properties; 

(c) if you are under age 18, when we collect personal information or personal data about you from your parent/custodian or relative;

(d) your previous landlord/s or letting agent/s;

(e) when we collect personal information or personal data about you if we are required to conduct a personal criminal check, credit check or personal referee checks; or

(f) when we collect personal information or personal data about you from publicly available sources including but not limited to, court judgments, directorship and bankruptcy searches, Australia Post, White Pages directory, and social media platforms (such as Facebook, Twitter, Google, Instagram, LinkedIn etc).

 

(a) where you are listed as an emergency contact for one of our residents;

(b) where information is collected from any previous landlord or letting agent, or personal referee you have listed on any application form (including any employment application) with Indi or its third parties;

(c) where information is collected from publicly available sources including but not limited to court judgments, directorship and bankruptcy searches, social media platforms (such as Facebook, Twitter, Google, Instagram etc); or

(d) where your information has been provided by a third party website or platform (such as realestate.com.au or domain.com.au) under 1.2(a), above; 

(e) as otherwise required or authorised by law.

1.4 How we hold your personal information or personal data

Once we collect your personal information or personal data, we will either hold it securely and store it on infrastructure owned or controlled by us, or (as permitted under Australian law) and/or with a third party service provider who has taken reasonable steps to ensure it complies with the Privacy Act 1988 (Cth).

We provide more general information on our security measures in Section 8 Data security and quality.

1.5 Cookies and IP addresses

A cookie is a small data file that contains information about your visit to a website. This information is provided by your computer during your first visit to a web server.

The server records this information in a text file and stores this file on your hard drive. When you visit the same website again, the server looks for the cookie and structures itself based on the information provided.

The types of cookies we use include:

• Essential cookies (these are required for the Indi Websites in relation to security, accessibility and functionality);
• Performance and functional cookies (we use these to improve the user experience on the Indi Websites);
• Advertising and marketing cookies (we use these to improve how we communicate with you, including being able to show you ads that are relevant to the way you interact with the Indi Websites); and
• Social media cookies (these are third-party cookies used by third-party companies which supply a service to Indi, such as including or excluding you from social media advertising).

Most browsers are initially set up to accept cookies. You can reset your browser to refuse all cookies or to warn you before accepting cookies. If you have set your browser to warn you before accepting cookies, you will receive the warning message with each cookie. Alternatively, you may wish to visit www.aboutcookies.org, which contains comprehensive information on how to manage cookies on a wide variety of desktop browsers.

We do not use cookies or web bugs to keep personal profiles of our customers’ use of the Indi Website. 

 

2. Uses and disclosures of personal information or personal data

 

2.1 Use and disclosure details

 We provide a detailed list above of some common uses and disclosures we make regarding the personal information or personal data we collect.

2.2 Other uses and disclosures

We may also use or disclose your personal information or personal data and in doing so we are not required to seek your additional consent:

(a) when it is disclosed or used for a purpose related to (or in the case of sensitive information, directly related to) the primary purposes of collection detailed above and you would reasonably expect your personal information or personal data to be used or disclosed for such a purpose;

(b) if we reasonably believe that the use or disclosure is necessary to lessen or prevent a serious or imminent threat to an individual’s life, health or safety or to lessen or prevent a threat to public health or safety;

(c) if we have reason to suspect that unlawful activity has been, or is being, engaged in; 

(d) if it is required or authorised by law; or 

(e) as otherwise permitted under the Privacy Act.

2.3 Use and disclosure procedures

In the event we propose to use or disclose such personal information or personal data other than for reasons set out above or as otherwise outlined in this Privacy Policy, we will first notify you or seek your consent prior to such disclosure or use.

Your personal information or personal data is disclosed to these organisations or parties only in relation to the products or services we provide to you or for a purpose permitted by this Privacy Policy.

We take such steps as are reasonable to ensure that these organisations or parties are aware of the provisions of this Privacy Policy in relation to your personal information or personal data.

2.4 Communications opt-out

If you have received communications from us and you no longer wish to receive those sorts of communications, you should contact us via the opt out link on the end of those communications and we will ensure the relevant communication ceases. Any other use or disclosure we make of your personal information or personal data will only be as required or authorised by law or as permitted by this Privacy Policy or otherwise with your consent.  

 

3. Sensitive information

3.1 Sensitive information generally

Sensitive information is a subset of personal information or personal data. It means information or opinion about an individual’s racial or ethnic origin, political opinions, membership of a political organisation, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual orientation or practices, criminal record, health information about an individual, genetic information, biometric information that is to be used for the purpose of automated biometric verification or biometric identification or biometric templates. 

3.2 Collection and use of sensitive information

Given the nature of our business, we do require the collection of some sensitive information if you wish to utilise our services. However, we attempt to limit the collection of sensitive information we may collect from you, and we do not collect sensitive information from you without your consent.

The type of sensitive information we may collect about you is dependent on the services provided to you by Indi and will be limited to the purpose(s) for which it is collected. We set out some types of sensitive information we may collect about you listed above.

We do not use sensitive information to send you Direct Marketing Communications without your express consent.

3.3 Consent

We may collect other types of sensitive information where you have consented and agree to the collection of such information. Generally speaking, we will obtain this type of consent from you at (or around) the point in time in which we collect the information.

 

4. Direct marketing

 

4.1 Express informed consent

You give your express and informed consent to us using your personal information or personal data set out above to provide you with information and to tell you about our products, services or events or any other direct marketing activity (including third party products, services, and events) which we consider may be of interest to you, whether by post, email, SMS or the Indi website or related mobile app (Direct Marketing Communications). 

4.2 Inferred consent and reasonable expectations of direct marketing

Without limitation if you have provided inferred or implied consent (e.g. not opting out where an opt-out opportunity has been provided to you) or in the case of Direct Marketing Communications by post, if we have collected your personal information directly from you, and it is within your reasonable expectation that we send you Direct Marketing Communications given the transaction or communication you have had with us, then we may also use your personal information or personal data for the purpose of sending you Direct Marketing Communications which we consider may be of interest to you.

4.3 Opt-out

If at any time you do not wish to receive any further Direct Marketing Communications from us or others under this Section you may ask us not to send you any further information about products and services and not to disclose your information to other organisations for that purpose. You may do this at any time by using the “unsubscribe” facility included in the Direct Marketing Communication or by contacting us via the details set out at the top of this document.

 

5. Anonymity and pseudo-anonymity

 

Our general practice is not to permit individuals to deal with us on an anonymous basis or through the use of a pseudonym. Generally, your personal information or personal data is required in order to provide you with our products and services or to resolve any issue you may have.

 

6. Cross border disclosure

 

6.1 Cross border disclosures

Any personal information or personal data collected and held by Indi may be disclosed or transferred to, and held at, a destination outside Australia, where we utilise third party service providers to assist Indi with providing our goods and services to you.

Personal information or personal data may also be processed by staff or by other third parties operating outside Australia who work for us or for one of our suppliers, contractors or agents.

As we use service providers and platforms which can be accessed from various countries via an Internet connection, it is not always practicable to know where your information may be held. 

6.2 Provision of informed consent

By submitting your personal information or personal data to Indi, you expressly agree and consent to the disclosure, transfer, storing or processing of your personal information or personal data outside of Australia. In providing this consent, you understand and acknowledge that countries outside Australia do not always have the same privacy protection obligations as Australia in relation to personal information or personal data. However, we will take steps to ensure that your information is used by third parties securely and in accordance with the terms of this Privacy Policy.

Where the Australian Privacy Law applies, the Privacy Act 1988 requires us to take such steps as are reasonable in the circumstances to ensure that any recipients of your personal information or personal data outside of Australia do not breach the privacy principles contained within the Privacy Act 1988. By providing your consent, under the Privacy Act 1988, we are not required to take such steps as may be reasonable in the circumstances. However, despite this, we acknowledge the importance of protecting personal information or personal data and have taken reasonable steps to ensure that your information or data is used by third parties securely and in accordance with the terms of this Privacy Policy.

6.3 If you do not consent

If you do not agree to the disclosure of your personal information or personal data outside Australia by Indi, you should (after being informed of the cross border disclosure) tell Indi that you do not consent. To do this, either elect not to submit the personal information or personal data to Indi after being reasonably informed in a collection notification or please contact us via the details set out at the top of this document.

 

7. Data security and quality

 

7.1 Indi’s security generally

We have taken steps to help secure and protect your personal information or personal data from unauthorised access, use, disclosure, alteration, or destruction. You will appreciate, however, that we cannot guarantee the security of all transmissions or personal information or personal data, especially where human error is involved or malicious activity by a third party.

Notwithstanding the above, we will take reasonable steps to:

(a) make sure that the personal information or personal data we collect, use or disclose is accurate, complete and up to date;

(b) restrict the number of staff who have access to your personal information or personal data on a “need to know” basis;

(c) protect your personal information or personal data from misuse, loss, unauthorised access, modification or disclosure both physically and through computer security methods; and

(d) destroy or permanently de-identify personal information or personal data if it is no longer needed for its purpose of collection. 

 

8. Accuracy

 

The accuracy of personal information or personal data depends largely on the information you provide to us, so we recommend that you:

(a) let us know if there are any errors in your personal information or personal data; and

(b) keep us up-to-date with changes to your personal information or personal data (such as your name or address).

We provide information about how you can access and correct your information in Access to and correction of your personal information or personal data. 

 

9. Access to and correction of your personal information or personal data

 

You are entitled to have access to any personal information or personal data relating to you which we hold, except in some exceptional circumstances provided by law (including under Privacy Law). You are also entitled to edit and correct such information if the information is inaccurate, out of date, incomplete, irrelevant or misleading.

If you would like access to or correct any records of personal information or personal data we have about you, you are able to access and update that information (subject to the above) by contacting us via the details set out in this document.

 

10. Resolving privacy complaints

10.1 Contacting us generally

If you have any questions or feedback about this Privacy Policy or your personal information, please contact the Privacy Officer at:

Privacy Officer
Investa 
Level 30
420 George Street
Sydney NSW 2000
Phone: (02) 8226 9300
Email: PrivacyOfficer@investa.com.au  

10.2 Contacting Indi regarding complaints

If you wish to make a privacy complaint, you may contact the Privacy Officer using the contact details above. You will need to provide us with sufficient details of your complaint, as well as any supporting evidence and/or information.

The Privacy Officer will investigate the issue and decide the steps we will take to resolve your complaint. We will contact you if we need any other information and will notify you in writing of the outcome. We will aim to ensure that your complaint is resolved in a prompt and appropriate manner.

If you feel that we have not adequately dealt with your complaint, you may contact the Office of the Australian Information Commissioner via:

Website: www.oaic.gov.au

Phone: 1300 363 992
Post: GPO Box 5218 Sydney, NSW 2001

 

11. Consent, modifications and updates

 

11.1 Acknowledgement

By using our website, purchasing a product or service from Indi, where you have been provided with a copy of our Privacy Policy or had a copy of our Privacy Policy reasonably available to you, you are acknowledging and agreeing:

11.1.1 to provide the consents given by you in this Privacy Policy; and

11.1.2 that you have been informed of all of the matters in this Privacy Policy.

11.2 Modifications and updates

We reserve the right to modify our Privacy Policy as our business needs require. We will take reasonable steps to notify you of such changes (whether by direct communication or by posting a notice on our website).

 

This Privacy Policy was last updated May 2024.