1. Introduction
1.1 Data DIY Pty Ltd (ABN 57 702 479 892) ("we", "us", "our") operates Where2Live (the "Service"), which provides users with property market and locality information, including numbers of properties sold, average rental prices, and crime statistics, presented by suburb.
1.2 We are committed to protecting the privacy of individuals who use the Service, in accordance with the Privacy Act 1988 (Cth) (the "Privacy Act") and the Australian Privacy Principles (APPs) set out in that Act.
1.3 This Privacy Policy explains what Personal Information we collect, how we collect it, how we use and disclose it, how we keep it secure, and how you can access, correct, or complain about the handling of your Personal Information.
1.4 "Personal Information" has the meaning given in the Privacy Act — broadly, information or an opinion about an identified individual, or an individual who is reasonably identifiable.
1.5 This Privacy Policy forms part of, and should be read together with, our Terms and Conditions, available at [www.where2live.com.au].
1.6 By creating an Account or otherwise using the Service, you consent to the collection, use, and disclosure of your Personal Information as described in this Privacy Policy.
2. What Personal Information We Collect
2.1 In order to create an Account and use the Service, we collect the following Personal Information via our authentication provider, Auth0:
- first name;
- last name;
- email address;
- mobile phone number; and
- organisation name (optional).
2.2 We do not require or knowingly collect sensitive information (as defined in the Privacy Act), such as health, racial or ethnic origin, or religious belief information, and you should not provide any such information to us.
2.3 We may also automatically collect limited technical information when you use the Service, such as device type, browser type, IP address, general location (derived from IP address), and usage data (such as pages viewed, suburbs searched, and session duration). This information may or may not be identifiable, depending on the context.
2.4 The Content displayed within the Service — property sale numbers, average rental prices, and crime statistics — is aggregated, suburb-level, publicly sourced data. It does not identify, and is not about, any individual, and is not "Personal Information" for the purposes of the Privacy Act.
3. How We Collect Personal Information
3.1 We collect Personal Information directly from you when you register for an Account, update your Account details, or otherwise interact with the Service (for example, contacting us for support).
3.2 Account registration and login are handled through Auth0. When you register or log in, Auth0 collects and processes the Personal Information referred to in clause 2.1 on our behalf.
3.3 We may also collect technical and usage information automatically through cookies and similar technologies, as described in clause 9.
3.4 If you provide us with Personal Information about another individual (for example, as part of an organisation's registration), you must ensure that you are authorised to do so and that the individual is aware of this Privacy Policy.
4. Why We Collect, Use and Disclose Personal Information
4.1 We collect, hold, use, and disclose Personal Information for the following purposes:
- to create and administer your Account;
- to authenticate you and provide secure access to the Service;
- to provide, operate, maintain, and improve the Service;
- to communicate with you about your Account, the Service, or changes to our Terms and Conditions or this Privacy Policy;
- to send you marketing communications by email, SMS, or phone call about the Service, in accordance with clause 8;
- to respond to your enquiries, feedback, or support requests;
- to monitor and analyse usage of the Service, for security and product improvement purposes;
- to detect, investigate, and prevent fraudulent, unauthorised, or unlawful activity; and
- to comply with our legal obligations.
4.2 We will only use or disclose Personal Information for a purpose other than those set out above where you have consented, where you would reasonably expect us to do so, or where otherwise permitted or required by law.
4.3 We do not sell your Personal Information to third parties.
5. Who We Share Personal Information With
5.1 We may disclose your Personal Information to the following categories of third parties, solely for the purposes described in clause 4:
- Auth0 (our authentication provider), which collects, processes, and stores Account registration and login information on our behalf;
- our cloud hosting and infrastructure providers, who store and process data on our behalf;
- analytics providers, who help us understand how the Service is used;
- professional advisers (such as lawyers or accountants), regulators, or law enforcement, where required or permitted by law; and
- a prospective buyer or acquirer of our business or assets, in connection with a merger, acquisition, or sale, subject to appropriate confidentiality protections.
5.2 We require our service providers to handle Personal Information in accordance with applicable privacy laws and to use it only for the purposes for which it was disclosed to them.
6. Overseas Disclosure
6.1 Some of our service providers, including Auth0 and our cloud hosting providers, may store or process Personal Information on servers located outside Australia, including in the United States and other countries in which those providers or their sub-processors operate.
6.2 Before disclosing Personal Information to an overseas recipient, we take reasonable steps, where practicable, to ensure that the recipient does not breach the Australian Privacy Principles in relation to that information, including by relying on contractual protections with our service providers.
6.3 By using the Service, you acknowledge that Personal Information may be disclosed to recipients located outside Australia, and that clause 8.1 of the Privacy Act (which would otherwise make us accountable for an overseas recipient's handling of your information) applies to these disclosures.
7. Automated Decision-Making
7.1 We do not currently use Personal Information in any automated decision-making process that is intended or likely to significantly affect your rights or interests.
7.2 If this changes, we will update this Privacy Policy to describe the kinds of Personal Information used, and the kinds of decisions made, in any such automated decision-making process, in accordance with our obligations under the Privacy Act.
8. Direct Marketing
8.1 We may contact you for marketing purposes by email, SMS/text message, or phone call, to send you information about the Service, including updates, new features, or newly available suburbs or data sets.
8.2 You may opt out of receiving marketing communications (by any or all of these channels) at any time by using the unsubscribe function in the relevant communication, informing us during a marketing call, or by contacting us via the "Contact Us" section of this Privacy Policy. We will not charge you for giving effect to your request.
8.3 We will not send you direct marketing communications from or on behalf of a third party without your consent.
9. Cookies and Similar Technologies
9.1 The Service uses cookies and similar technologies to enable core functionality (such as keeping you logged in), remember your preferences, and collect analytics about how the Service is used.
9.2 Most browsers allow you to control or disable cookies through their settings. If you disable cookies, some features of the Service may not function correctly.
9.3 We may use third-party analytics providers who use cookies or similar technologies to help us understand usage patterns. These providers may collect information about your use of the Service and other websites over time.
10. Data Quality and Security
10.1 We take reasonable steps to ensure that the Personal Information we collect, use, and disclose is accurate, complete, and up to date, including by allowing you to review and update your Account details.
10.2 We take reasonable technical and organisational steps to protect Personal Information from misuse, interference, loss, and unauthorised access, modification, or disclosure, including access controls, encryption in transit, and restricting access to Personal Information to personnel and service providers who need it to perform their functions.
10.3 No method of storage or transmission over the internet is completely secure. While we take reasonable steps to protect your Personal Information, we cannot guarantee its absolute security.
10.4 We retain Personal Information only for as long as necessary to fulfil the purposes described in this Privacy Policy, or as required by law. Where Personal Information is no longer needed, we will take reasonable steps to destroy or de-identify it.
11. Data Breach Notification
11.1 We maintain a data breach response plan and will comply with our obligations under the Notifiable Data Breaches scheme in the Privacy Act.
11.2 If we become aware of a data breach involving Personal Information that is likely to result in serious harm to any individual, we will notify the Office of the Australian Information Commissioner (OAIC) and affected individuals in accordance with the Privacy Act.
12. Access to and Correction of Your Personal Information
12.1 You may request access to the Personal Information we hold about you, or request that we correct any inaccurate, out of date, incomplete, irrelevant, or misleading Personal Information, by contacting us via the "Contact Us" section of this Privacy Policy or through your Account settings.
12.2 We will respond to your request within a reasonable period. We will not charge you for making a request, but may charge a reasonable fee for giving you access, to the extent permitted by law.
12.3 We may decline a request for access or correction in circumstances permitted under the Privacy Act, in which case we will provide reasons for our decision, unless it would be unreasonable to do so.
13. Anonymity and Pseudonymity
13.1 Where practicable, you may interact with us anonymously or using a pseudonym, for example when making a general enquiry. However, you must provide the Personal Information described in clause 2.1 to create an Account and access the Service, as this information is reasonably necessary for us to provide the Service to you.
14. Children's Privacy
14.1 The Service is not directed to, and is not intended for use by, children. We do not knowingly collect Personal Information from children. If you believe a child has provided us with Personal Information, please contact us via the "Contact Us" section of this Privacy Policy so that we can take appropriate action.
15. Changes to This Policy
15.1 We may update this Privacy Policy from time to time to reflect changes in our practices, the Service, or applicable law. Where changes are material, we will provide reasonable notice, for example by email or a notice within the Service, before the changes take effect.
15.2 The current version of this Privacy Policy will always be available at [www.where2live.com.au]/privacy, together with the date it was last updated.
16. How to Contact Us or Make a Complaint
16.1 If you have any questions about this Privacy Policy, or wish to make a complaint about how we have handled your Personal Information, please contact us via the "Contact Us" section of this Privacy Policy.
16.2 We will acknowledge your complaint and aim to investigate and respond within a reasonable period, ordinarily within 30 days.
16.3 If you are not satisfied with our response, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC):
- Website: www.oaic.gov.au
- Phone: 1300 363 992
- Post: GPO Box 5218, Sydney NSW 2001
Contact Us
If you have any questions about this Privacy Policy, please contact us via the "Contact Us" page on our website:
Data DIY Pty Ltd
ABN: 57 702 479 892
Website: [www.where2live.com.au]