Privacy Policy

Directly from you

3.1. In many instances, Pro-Active Strata Management collects Personal Information directly from you. For example, if you are a customer, we may collect your information from an application form you have completed, or when you contact us by phone, email, through our website or via social media sites.

3.2. Your calls to Pro-Active Strata Management may be recorded and monitored for training, service quality control, verification and compliance purposes.

3.3. Some other examples of how Pro-Active Strata Management collects Personal Information include:

• If you use our registration system to visit our offices and site locations.
• If you work with us or apply for a job with us.
• If you engage with us via our website, officers or call centres regarding our activities.
• When you or your organisation offer to provide, or provide, products and or services to us.
• When you enter a Pro-Active Strata Management competition or participate in a survey.

From our partners

3.4. If you are a customer or potential customer, Pro-Active Strata Management may collect information about you through our service providers who provide customer acquisition and onboarding services to us. These service providers may be companies who provide energy comparison or moving assistance services. They collect your information from you and then provide it to Pro-Active Strata Management for the purpose of assisting you to become our customer.

From other third parties

3.6. Pro-Active Strata Management may also collect information about you from other third parties such as electricity and gas distributors, credit reporting bodies, market data research firms, government agencies and regulators and other third party service providers.

Through other means

3.7. Pro-Active Strata Management may collect Personal Information via our website – see Part 5 Using our Website and Cookies below.

3.8. Pro-Active Strata Management may also collect Personal Information that you provide to us when signing up to mailing lists, creating a MyAccount profile, registering for our events, using our mobile App, or when submitting a form or feedback on your experience with our website or mobile App.

Anonymity

3.9. Whenever it is lawful and practicable, Pro-Active Strata Management will allow you to interact with us anonymously or by using a pseudonym.

3.10. However, for most of our functions and activities Pro-Active Strata Management usually requires your name, contact information and enough information about the particular matter to enable us to fairly and efficiently handle your inquiry, request, complaint or application, or to respond to you, the relevant authorities or to another effected individual/organisations.

4.1. Pro-Active Strata Management collects, holds, uses and shares your Personal Information for our business functions and activities, which includes delivering our products and services, managing our business and complying with the law. We handle your information so we can:

• confirm and/or validate your identity;
• communicate with you (by sending service, support and administrative messages, reminders and notices) and to keep you updated regarding our activities;
• lessen or prevent a serious threat to the life, health or safety of any individual, or to public health;
• deal with customer care related activities;
• set or reset your password (where you have one) for our portal;
• operate and administer accounts and to facilitate payments, refunds and managing debts (for example issuing bills, setting up direct debits, processing payments and refunds, recovering debts, selling debts and otherwise managing our financial activities);
• respond to your enquiries and resolve complaints and disputes;
• send you marketing and promotional messages and other information that may be of interest to you;
• consider an individual for employment;
• improve and optimise our services and our customers’ experience (for example, by performing analytics and conducting research for advertising and marketing);
• carry out certain checks (for example, in relation to credit); and
• comply with our regulatory obligations, report to regulators and authorities and assess our legal compliance (including through internal and external audits).

4.2. If Pro-Active Strata Management does not have your Personal Information, we may not be able to deliver the products or services you have asked for or respond to your questions or comply with the law.

Who we disclose Personal Information to?

4.3. Pro-Active Strata Management may disclose your Personal Information for the purposes described in this Policy to:

• our employees and Australian based related bodies corporate;
• CV checking agencies (if you have applied for a position with us);
• third persons you have authorised us to provide your information to (such as secondary account holders or your authorised representatives);
• financial institutions and payment system operators (including merchants);
• our insurance brokers, providers and consultants;
• our professional advisers, dealers and agents (including independent auditors, legal and tax advisers);
• debt collection agencies and others that assist us with debt recovery;
• the sponsors or promoters of any competitions that we conduct;
• credit reporting bodies (for more information, see our Credit Reporting Policy);
• Regulatory bodies and Law Enforcement Agencies (e.g., the Office of the Australian Information Commissioner, the Energy Ombudsman, the Australian Energy Market Operator and the Police); and
• other persons as required or permitted by law.

4.4. Pro-Active Strata Management takes reasonable measures to ensure that the parties we share your information with are bound by confidentiality and the Privacy Act.

What we will not do with your Personal Information

4.5. Pro-Active Strata Management will not use or disclose your Personal Information for another purpose (a secondary purpose) unless:

• we first obtain your consent;
• you would reasonably expect us to use or disclose your Personal Information for a secondary purpose that is related to the primary purpose or, in the case of Sensitive Information, directly related to the primary purpose;
• it is set out in this Policy;
• we are required to by Law;
• a permitted general purpose exists;
• a permitted health situation exists;
• we believe it is reasonably necessary for one or more enforcement-related activities conducted by, or on behalf of, an enforcement body.

4.6. If Pro-Active Strata Management collects Sensitive Information about you, you consent to us collecting, using and disclosing the Sensitive Information for the purpose for which it was collected as disclosed and as permitted by the Privacy Act or other relevant legislation.

Overseas disclosure

4.7. Pro-Active Strata Management may disclose your Personal Information to entities outside of Australia for our business functions or activities or for the purposes of providing services to you. Where we do so, we will take reasonable steps to ensure that the disclosure of, and access to, your Personal Information is secure, that appropriate controls are in place and that your Personal Information is handled in a manner consistent with the Privacy Act.

Direct marketing

4.8. Pro-Active Strata Management and/or our business partners may send you direct marketing communications and information about products and services that we or third parties offer, including competitions that we think you might be interested in. This may take the form of emails, SMS, mobile App push notifications, mail or other forms of communication.

4.9. These marketing communications may also be sent to you even if you are not, or no longer, a customer of Pro-Active Strata Management.

4.10. Where push notifications are available and you have enabled to receive them, the mobile App will use an installation ID and token to identify your mobile App for the purpose of receiving the push notification. You can deactivate mobile App push notifications by changing the notification setting in the mobile App or on your mobile device at any time.

4.11. You may opt-out of receiving these marketing communications by clicking on the unsubscribe link in the electronic communication.

4.12. Even if you opt-out of receiving marketing communications, Pro-Active Strata Management may still contact you to send important administrative and safety messages, as well as to manage your account.

5.1. Pro-Active Strata Management website, www.proactivestrata.com.au, is hosted in Australia and there are a number of ways in which we collect information through our website. 

5.2. Pro-Active Strata Management may collect Personal Information about you when you use and access our website or mobile App (for example, when you submit an enquiry or online form, set up your account on the MyAccount platform, sign up to our newsletter, or enter a competition on our website or mobile App).

5.3. Pro-Active Strata Management’s website includes pages that use cookies which are small amounts of data sent by our website and other third parties and stored on your computer’s hard drive. This allows our servers to recognise your computer when you visit our website in the future. Although cookies are used to collect data about your browser type, the operating system you are using, the web page you visited, your internet service provider and your State location, Pro-Active Strata Management does not use this data to identify you personally.

5.4. Pro-Active Strata Management’s website and mobile App also uses Google Analytics, a web analytics service provided by Google, Inc. (Google). Google Analytics also uses cookies. Although these cookies do not identify you personally, they allow information about your use of our website (including your IP address and installation ID) to be transmitted to Google. For more information, please see Google’s site “How Google uses data when you use our partners’ sites or apps”, located at www. google.com/policies/privacy/partners/. By using our website and/or mobile App, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

5.5. Pro-Active Strata Management also collects data crash reports which contain information such as IP addresses and installation ID.

5.6. You can configure your internet browser to accept all cookies, reject all cookies or notify you when a cookie is sent. If you refuse the use of cookies in this way you may not be able to access the full functionality of Pro-Active Strata Management’s website. Please refer to your internet browser’s instructions or help screens to learn more about these functions.

5.7. To assess the effectiveness of Pro-Active Strata Management’s website and mobile App design and layout, as well as monitor traffic to the website, we may contract with third parties to collect statistical data. However no Personal Information is collected during this process.

5.8. Pro-Active Strata Management’s website may contain links to websites operated by third parties. Those links are provided for convenience and may not remain current or be maintained. Unless expressly stated otherwise, Pro-Active Strata Management is not responsible for the privacy practices of, or any content on, those linked websites, and we have no control over or rights in those linked websites. The privacy policies that apply to those other websites may differ substantially from this Privacy Policy, so we encourage individuals to read them before using those websites.

6.1. Pro-Active Strata Management generally hold Personal Information in our electronic databases, but we may also store Personal Information in hard copy form and in various third party databases and platforms.

6.2. Pro-Active Strata Management is committed to the security of your Personal Information and takes reasonable steps to protect your Personal Information from misuse, interference and loss, as well as unauthorised access, modification or disclosure.

6.3. Pro-Active Strata Management uses a number of physical, administrative, personnel and technical measures to protect your Personal Information, which include, but are not limited to:

• implementing internal processes and policies in relation to the collection, use and secure storage of Personal Information and educating our personnel in relation to these obligations;
• storing Personal Information in secure, encrypted data centres;
• using secure networks or encryption when transmitting electronic customer data and Personal Information;
• using ID cards, cameras and sign in procedures to prevent unauthorised access to our offices and buildings;
• requiring the third parties we engage to take adequate security measures and handle your Personal Information in a manner consistent with the Privacy Act;
• complying with payment card industry security standards with respect to the storage and transmission of payment card details;
• regularly assessing the risk of misuse, interference, loss, and unauthorised access, modification or disclosure of that information;
• taking measures to address those risks; and
• having mandatory annual training for all our staff on our privacy obligations, with a focus on how to keep your information safe and secure.

7.1. You can request access to the Personal Information that Pro-Active Strata Management holds about you at any time by contacting us using the details at the end of this Policy. We will ask you to verify your identity before we provide access to your information and we will try to make the process as simple as possible.

7.2. Pro-Active Strata Management will endeavour to respond within a reasonable period of receiving your request. Where reasonable, we will provide you with a copy or details of your Personal Information in the manner requested.

7.3. Sometimes Pro-Active Strata Management may be unable to provide you with access to some or all of your personal information (for example we reasonably believe that providing access would have an unreasonable impact on the privacy of other individuals, would pose a serious threat to the life, health or safety of any individual/to public health/public safety or would be unlawful/prejudicial). Where this is the case, we will tell you why.

8.1. Pro-Active Strata Management takes reasonable steps to ensure that the Personal Information we collect, use and disclose is accurate, complete, up to date and relevant.

8.2. If you believe the Personal Information that we hold about you is inaccurate, incomplete or outdated, please contact us. We will endeavour to respond within a reasonable period of receiving your request.

8.3. We will ask you to verify your identity before we make any corrections.

8.4. If we do not think that the information needs to be corrected, we will tell you why. If we do not correct your Personal Information, you can ask us to include a statement (that will be attached to that information) that you believe the information is incorrect and why.

9.1. When Pro-Active Strata Management no longer needs the Personal Information collected for any purpose for which the Personal Information may be used or disclosed, Pro-Active Strata Management will destroy/de-identify the Personal Information in accordance with the Privacy Act requirements.

10.1. If you believe that we have breached the Privacy Act, or you wish to make a complaint about the way we have handled your Personal Information, we encourage you to contact us using the details at the end of this Policy.

10.2. Please include your name, email address and/or telephone number and clearly describe your complaint. We will respond within a reasonable period of receiving your complaint.

10.3. If we receive a complaint from you about how we have handled your Personal Information we will determine what (if any) action we should take to resolve the complaint.

10.4. If we decide that a complaint should be investigated further, the complaint will usually be handled by a more senior officer than the officer whose actions you are complaining about.

10.5. If you are not satisfied with Pro-Active Strata Management’s handling of your complaint, you can lodge a complaint with the Office of the Australian Information Commissioner (OAIC). For further information regarding how to make a complaint to the OAIC, you can visit oaic.gov.au/privacy/privacy-complaints.