Effective date: 18 January 2022

Urban is operated and published by First Chance Group Pty Ltd (referred to as “Urban” “us”, “we”, or “our”) and we are committed to protecting your privacy and the security of your personal information.

The objective of this privacy policy (“Privacy Policy”) is to explain how we handle your personal information. In particular, this Privacy Policy informs you how we collect, use, disclose or otherwise handle personal information in connection with your use of our website at https://www.urban.com.au/ or any Urban software application or other product that refers to or links to this Privacy Policy (the website and applications/products being referred to in this Privacy Policy as the “Platform”). This Privacy Policy also sets out the rights and choices you have associated with that personal information.

By using, browsing or accessing the Platform, you agree to the collection and use of personal information and other information in accordance with this Privacy Policy. This Privacy Policy may change from time to time and it is therefore important you review it regularly on our Platform or at https://www.urban.com.au/privacy.

Table of Contents

1. What personal information do we collect?
2. Why do we collect your personal information?
3. How do we collect your personal information?
4. Who we may disclose your personal information to?
5. How do we use cookies?
6. Direct marketing communications
7. How long do we retain your personal information?
8. How do we secure your personal information?
9. Links to other sites
10. What are your rights in relation to personal information?
11. Complaints
12. Changes to This Privacy Policy
13. Contact Us
14. Privacy Policy version

1    What personal information do we collect?

Personal information means information or data about a living individual who can be identified from that information or data (which includes information or data in our possession or which is likely to come into our possession).

We collect several different types of personal information for various purposes. In the table below we have categorised this personal information and describe what is it and how we may collect it.

1.2    Types of Data Collected

Category

Description of Category

User data

This is the personal information that is provided by you when you sign up for an account and use our Platform. Depending on your method of registering, this will likely include your name, phone number and email address.

Profile data

This includes personal information made available by you or the social network you use to log in and includes names, comments, posts, images or preferences, feedback and survey responses.

Preference data

This includes details about the kind of property you are looking for, your budget and pricing criteria, the locations you are interested in, and whether you are a first home buyer or investor, amongst other things.

Usage data

This includes information on how the Platform is accessed and used, as well as usernames and passwords, internet protocol (“IP”) addresses, browser types, time zone settings, the time spent on webpages, unique device identifiers and other diagnostic data.

Location data

We may use and store information about your location if you give us permission to do so, or through an IP address. We use this data to provide features of our Platform, and to improve and customise our Platform.

Marketing data

This includes your preferences in receiving marketing communications from us.

Cookies data

We use cookies and similar tracking technologies to track the activity on our Platform and hold certain information. Cookies are files with small amounts of data which may include an anonymous unique identifier. Cookies are sent to your browser from our Platform and stored on your device. For more information see the “How do we use cookies?” section below.

Certain aspects of your personal information, for example user data, are required for many of our Platform services and if you fail to supply such information as requested for any specific service, we may be unable to provide you with the products and services in full and your enjoyment of such products and services may be more limited.

1.2    Sensitive data

We do not collect any sensitive personal information about you (this includes details about your race or ethnic origin, political opinions or associations, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association or union, sexual orientation or practices, and criminal record information). Nor do we collect any information about your health, genetic background or biometric personal information.

1.3    Children’s data

Our services are not intended for use by children and should only be accessed by individuals who are at least 18 years old (the “Age Limit”). If you are under the Age Limit, please do not use the Platform and do not provide us with your personal information. If you are a parent or guardian and you are aware that an individual under the Age Limit has provided us with personal information, please contact us. We will upon notice or discovery take all reasonable efforts to erase or destroy any personal information that may have been collected or stored by us about those under the Age Limit.

2   Why do we collect your personal information?

1. To provide the services and to assess, maintain and improve the performance of our service and the Platform.
2. To ensure the Platform is relevant to you and your device, to notify you about changes to our services, and to deliver targeted content based on your user data, location and preferences.
3. For consumer research and to allow you to participate in surveys or interactive features of our Platform and services when you choose to do so.
4. To provide customer support and to process and respond to a request through our chat platform or any other complaint or request that you may have and submit to us.
5. To monitor the usage of our Platform and to detect, prevent and address technical issues.
6. To process any of your requests and to conduct business planning, reporting, and forecasting.
7. To deliver promotional materials about updates on property and projects, and/or to alert you to special offers and general information about other goods, services and events which we offer that are similar to those that you have already used or enquired about unless you have opted not to receive such information.
8. For the administration of our business including for fulfilling and exercising our obligations and rights, exercising or defending legal claims, and managing our relationship with you.
9. To comply with our legal obligations and law enforcement requests.
10. To verify your identity and to detect fraud and potential fraud, including fraudulent use of the Platform and our services.

3   How do we collect your personal information?

We will collect personal information directly from you wherever it is reasonable and practical to do so.
We may collect personal information from you via:

1. your use and access of the Platform, including during your registration as a user;
2. your response to any surveys or marketing materials we send out;
3. information and recommendations uploaded to the Platform by yourself or by other users; and
4. interactions between yourself, other users of the Platform, and our staff.

We may also collect your personal information from third parties including:

5. third parties, such as technology providers, who partner with us and help us provide our services and the Platform;
6. third parties that provide us with marketing leads;
7. third parties for whom we provide marketing and data analysis services; and
8. via public sources or when you connect with a social network service when using and accessing the Platform.

If you provide us with information about another person (like a person you will purchase a property with), you will let that other person know that we use their personal information in the ways set out in this Privacy Policy, and that they can access this Privacy Policy on the Platform or request a copy of it from us.

4   Who we may disclose your personal information to?

4.1    Third party disclosure

We may disclose your personal information to various third parties. These third parties are likely to
include:

1. real estate agents and property developers associated with listings and projects shared on our Platform so that they can provide you with information that may be of interest to you;
2. where you have signed up to request more information on a project development on our Platform, we will forward the details you provide to the relevant third party;
3. with any third parties if you select, at your discretion, to make your profile or comments public to third party registered and/or unregistered users on our Platform;
4. technology and media partners in connection with the services that these third parties perform for us;
5. our lawyers, accountants and professional advisors;
6. other third party service providers, such as third party branding, advertising and marketing service providers;
7. to Urban related companies;
8. to law enforcement authorities where we are required to do so by law or as a result of a legal process; and
9. in the event that we sell or transfer all or a portion of our business or assets, to any transferee of such business or assets. Should such a sale or transfer occur, we will use reasonable efforts to require that the transferee uses the personal information that you have provided to us in a manner that is consistent with this Privacy Policy.

When you make enquiries related to a property development or project, the information will be disclosed to the project developers and will include information about whether you have made any other enquires about any of the developer’s other projects, when those enquiries were made, and which locations you were looking into.

4.2    Disclosure of personal information to other countries

Urban may also subcontract certain activities of our business and share your personal information with third parties located outside of Australia. The countries in which these subcontractors and third party organisations are located will vary, but, in
the course of our business operations, we generally disclose personal information to organisations located in Australia, the United States, Philippines, Pakistan, Sri Lanka and New Zealand. Personal information, therefore, may be subject to privacy laws that are different to those in your country. Such transfers are made in order to provide the services on our Platform and carry out the activities specified in this Privacy Policy. Your consent to this Privacy Policy and using our Platform represents your agreement to such transfers. We take all steps reasonably necessary to ensure that personal information is treated securely and in accordance with this Privacy Policy. No transfer of your personal information will take place to an organisation or another country unless we believe there to be adequate controls in place including the security of your data and other personal information. For more details please see the How do we secure your personal information below.

5   How do we use cookies?

To help improve the service we provide through our Platform, certain information is collected from your browser or device. This information is collected as statistical information and includes the IP address, browser or device type, language, time zone location and access times. This Platform also uses cookies to track pages visited and information accessed within our Platform. This information is used for statistical references, site analysis and to remember your details and preferences when you return to our Platform. In many cases, the tools used on our Platform record information in a way that does not identify you as an individual. In other cases, information may be personal information in which case this Privacy Policy will apply. Below we summarise why we use cookies and the different types that we use:

1. Necessary cookies: are those that are essential to run our Platform or to enable you to receive a service that you have requested. For example, to enable you to complete the registration process and log into parts of our Platform and keep that information safe. Necessary cookies are also those that collect encrypted user session identifiers and device identifiers.
2. Performance cookies: are those that collect information about how visitors use and interact with our Platform so that we can improve it. For example, we use Google Analytics to track anonymous information about how visitors use our Platform. This only collects statistical information such as the number of visitors tothe Platform, how they arrived there (i.e. via a Google search or another website), whether it is a first-time or return visit, etc.
3. Functionality cookies: are those that allow us to recognise you and remember the choices you make. Without these cookies you may find that certain features are less convenient and reliable. For example, we use these to remember your language, location and to present relevant content.
4. Marketing cookies: are those that help us deliver advertising that is more relevant to you, your interests and is referred to as “online behavioural advertising”. These cookies include those placed by our third party partners and other advertisers who share cookie data with us. For example, we use these cookies to allow our Platform to serve up different versions of a page for marketing purposes.

Your web browser or device can also be configured to reject cookies. If you set up your web browser or device to reject cookies, certain functions of our Platform may become unavailable to you.

6   Direct marketing communications

From time to time we may send you direct marketing communications regarding development projects, property, our product solutions and services. We may contact you by electronic messages (e.g. email newsletter), online (e.g. through our Platform), by mail and by other means, unless you opt-out or we are subject to legal restrictions from doing so. You may opt-out of receiving electronic messages from us at any time by contacting us via the contact details at the bottom of this Privacy Policy or by using the opt-out mechanism included in our marketing messages.

7   How long do we retain your personal information?

We will retain your personal information for the period necessary to fulfil the purposes outlined in this Privacy Policy and in each case in accordance with applicable legal and regulatory requirements in respect of permitted or required retention periods and limitation periods relevant to legal action.

8   How do we secure your personal information?

We have put in place appropriate security measures to prevent your personal information from being accidently lost, used or accessed in an unauthorised way, altered or disclosed.

If you have an Urban user account, your account will be protected by a user-generated password. We implement basic minimum password requirements, however it is up to you to keep your password safe, and ensure your account and device are not affected by any intrusion that may affect your privacy or information security. If you believe your personal information stored in your Urban profile has been compromised, contact us immediately by using the contact details at the bottom of this Privacy Policy or send an email to hello@urban.com.au.

In addition, we limit access to your personal information to employees, agents, contractors and other third parties who have a business need for access. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security. Therefore, we have put in place procedures to deal with any suspected personal information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

9   Links to other sites

From time to time, our Platform (including this Privacy Policy) may contain links interfacing with other websites that are not operated by us for your information or convenience. This includes Urban profiles and the comments section which are populated by Platform users.

These websites operate independently from our service and may be subject to alternative terms of use, including terms concerning the use of personal information. We have not reviewed these third party websites and do not control and are not responsible for how they are operated, their content or privacy policies.

If you decide to access or interact with any of these third party websites, you do so at your own risk. As such, we strongly encourage you to review the privacy policy of every website you visit.

10   What are your rights in relation to personal information?

The accuracy of the personal information we hold and use is important to us. We take reasonable steps to ensure that the personal information we handle is accurate, complete and up-to-date. To help us keep your personal information accurate, please let us know if there are any errors or changes in your personal information.

You can request access to the personal information we hold about you at any time by contacting us via the contact details at the bottom of this policy. You may request that we delete any personal information that we hold about you, subject to any legal obligations we have to retain your personal information by contacting us using the contact details below. You may also request the correction of any of the personal information we hold about you. In most cases, we can help you promptly and informally with these requests. In other cases, we may need to verify your identity and ask you to make your request in writing.

From time to time, we may need to reject your request to access or correct the personal information we hold about you if we believe it to be necessary and to the extent allowed by law. We will provide our reasons if we deny your request for access to, or correction of, your personal information. Where we decide not to make a requested correction to your personal information and you disagree, you may ask us to make a note of your requested correction with the information we hold about you. We won’t charge you for simply making a request to access or correct personal information. However, we may charge reasonable costs for carrying out your request.

You may also contact us using the contact details below if you wish to obtain further information regarding our privacy practices and the way we handle your personal information.

11   Complaints

We take your privacy concerns seriously. If you have a complaint regarding our handling of your personal information or concerning our privacy practices, you may file a complaint with us using the contact details set out at the bottom of this Privacy Policy. We will confirm receipt of your complaint and, if we believe necessary, we will open an investigation into your complaint.

We may need to contact you to request further details of your complaint. If an investigation has been opened following a complaint made by you, then we will contact you with the result of that complaint as soon as possible. If you are not satisfied with the manner in which we have dealt with your complaint, you may contact the Office of the Australian Information Commissioner.

12   Changes to This Privacy Policy

We may update our Privacy Policy from time to time and it is therefore important you review it regularly. We will notify you of any changes by posting the new Privacy Policy on the Platform. We will let you know via email and/or a prominent notice on our Platform prior to the change becoming effective and update the “effective date” at the top of this Privacy Policy. Changes to this Privacy Policy are effective when they are posted on this page unless otherwise set out in the email and/or prominent notice.

13   Contact Us

If you have any questions about this Privacy Policy, our privacy practices or if you would like to make a request about any personal information we may hold about you, please contact us:

• By email using privacy@urban.com.au
• 4/651 Victoria Street, Abbotsford, Victoria, 3067, Australia

14   Privacy Policy version

This Privacy Policy v2 was last updated on 18 January 2022