Privacy Policy

This Privacy Policy applies to Rawson Group Pty Limited (ACN 000 382 329) and its subsidiaries and affiliates including but not limited to Rawson Homes Pty Ltd (ACN 053 733 841) (Rawson Homes), Thrive Homes Pty Limited (ACN 613 679 333) (Thrive Homes), Rawson Communities Pty Ltd (ACN 003 203 745) (Rawson Communities), and Rawson Real Estate Sales Pty Ltd (Licence No: 10134882) (collectively the Rawson Group, we, our and us). The Privacy Policy does not apply to Mint Loans Pty Ltd, a Rawson Group member, which has its own Privacy Policy.

We are committed to protecting your privacy. We respect the privacy and confidentiality of the personal information provided by you and adhere to the Privacy Act 1988 (Cth) (Privacy Act) and Australian Privacy Principles (APPs). Please read our Privacy Policy below carefully.

This Privacy Policy explains how we manage the personal information that is collected, used, disclosed and stored about you.

By providing personal information to us, you consent to our collection, use and disclosure of your personal information in accordance with this Privacy Policy and any other arrangements that apply between us.

1. The Rawson Group
A division of Daiwa House, Japan’s largest residential builder and developer, the Rawson Group is a diversified builder and developer, delivering homes and communities. We provide the following services: housing and housing development construction services; housing design services; interior design services; building project management services; real estate and property sales and marketing services; and the provision of display houses, display villages and the operation of sales centres (collectively, the Services).

Our sales centres and display homes are open to the public.

The Rawson Group maintains websites at www.rawsongroup.com.au, www.rawsonhomes.com.au¸ www.rawsoncommunities.com.au and www.thrivehomes.com.au (collectively, the Websites).

2. What is personal information?
When we refer to “personal information”, we mean information or an opinion about you, from which you are, or may reasonably be, identified (whether the information or opinion is true or not). This information may include (but is not limited to) your name, phone number, email address and address.

Personal information may also include information which is “sensitive information” under the Privacy Act. Sensitive information includes, for example, information or an opinion about an individual’s health, racial or ethnic origin, criminal record or membership of a professional association, trade association or trade union.

3. What information do we collect?
The personal information we collect depends on the nature of our relationship with you. For example:

• If you request a quotation for our Services, we may collect your name, address, email address and phone number, as well as the address of the build site, your timeframe to buy and whether your finances are secured, as well as evidence of conditional finance pre-approval from your financier.
• If you enter into a contract with us for the sale of land and/or the construction of a house, we may collect your name, address, email address and phone number, the address of the build site, your lawyer’s details (including his or her name, address, email address, phone number), your financier’s details where provided by you (including contact name(s), address, email address, phone number), specific details of the property (including an identification survey and details of encumbrances), evidence of funds at various stages of the contract lifecycle (such as conditional loan pre-approval, unconditional loan approval, authority to commence construction (which may be collected from your financier) and if there is gap between the loan and the price payable or if you are paying entirely in cash, a dated bank statement with your full name and account number) and on occasion, bank account details where provided by you to facilitate refunds into your account, your guarantor(s)’s details (including contact name(s), address, email address, phone number) if applicable and your power of attorney (if applicable).
• If you are a representative of a supplier, when we enter into an arrangement with your business for the supply of products or services, we will collect your name, business name and work contact details including address, phone number and email address. We will also collect your business’ Australian Business Number (ABN) and bank account details.
• If you are a consultant, contractor or subcontractor engaged to provide pre-construction or construction services, we may collect your name, address, email, phone number, ABN, bank account details and where required by us, licence details and insurance policy details.
• If you apply for a job with a Rawson Group subsidiary or affiliate or are an employee, we may collect, for example, your full name, date of birth, contact details (including address, phone number and email address), job title, bank account details, passport details, driver’s licence details, employment history, education details, performance information, names and contact details of referees, references, employment visa details (if applicable), next of kin details (in the event of an emergency), superannuation fund details and tax file number details, if required by law, for example, under the Superannuation Guarantee (Administration) Act, the Superannuation Industry (Supervision) Act, the Income Tax Assessment Acts and Taxation Administration Act, pre-existing medical information (if provided), grievance information and workers compensation claim information (only if applicable).

If you do not provide the information requested by us, we may not be able to, for example, provide you with our Services, consider your application for employment or engage you as a supplier or contractor.

4. How do we collect your personal information?
We will collect personal information about you if you choose to provide it to us. Personal information may be collected from you in a variety of ways, including at different places and times on our Websites. We may collect your personal information when you do any of the following, for example:

• complete an online enquiry form on one of our Websites or a website we operate with our partners, such as a land developer;
• request a quotation for a Service;
• enter into a contract for a Service;
• visit one of our display homes, sales centres or design studios and, if applicable, pay a holding deposit;
• attend a promotional event we host or sponsor;
• enter into a commercial relationship with us for the purpose of supplying us with products or services;
• enter into a joint venture arrangement with us in respect of a project or development;
• complete a service authority form for us to arrange the connection of relevant services with the relevant authorities or providers, such as gas, electricity, telecommunications and water etc;
• submit an application for employment with us;
• complete onboarding and performance reviews as part of the employment cycle;
• subscribe to receive our newsletters or promotional materials or sign up to a mailing list;
• enter competitions or promotions we conduct;
• respond to surveys;
• interact with us via any of our social media pages or advertisements we place on social media, for example, via Facebook, Instagram and LinkedIn; or
• engage with us by phone, email, mail or in person.

We may also collect personal information about you from third parties. These third parties may include (but are not limited to):

• third parties we are working with to provide Services to you, including but not limited to builders, land developers, joint venture partners, designers, suppliers of building products, real estate websites and authorities involved in the pre-construction and construction services provided by us (such as councils, building inspectors and other certifying authorities);
• other third parties we have relationships with, such as financial services providers, insurance providers, law firms, sales and marketing service providers;
• your lenders and valuers;
• someone duly authorised to act on your behalf;
• recruiters and managed verification service providers (who conduct executive background checks) that we may engage; and
• where you have provided consent, for example, from third parties, such as referees.

Our server automatically collects information about your use of the Websites (Navigational Data). Navigational Data includes the type of browser you are using, your IP address, the URL you have come from and the time spent at that URL, cookies and your domain type and server. We use this information to monitor your use of our Websites. See Section 8 (Cookies) below for further information about our use of cookies.

If you provide personal information to us about someone else, you must ensure that you are entitled to disclose that information to us. For example, you should take reasonable steps to ensure the individual concerned is aware of the various matters detailed in this Privacy Policy.

5. How is personal information used?
We may use your personal information for the following purposes:

• to provide you with the Services you have requested, for example, providing you a quotation providing design services or other pre-construction services; submitting documentation to relevant authorities on your behalf or constructing your house;
• to respond to your enquiry or complaint;
• to verify your identity and comply with Know Your Customer (KYC) requirements;
• for complaints handling;
• data analytics;
• to send surveys to you to complete (and to analyse the results of those surveys);
• to improve our Services and Websites;
• to send you direct marketing messages (by email, SMS and post) which we consider may be of interest to you (including third party offers);
• to send targeted advertising to various media platforms with which you may engage;
• to assess your application for employment with us or to manage your employment throughout the employment lifecycle;
• the prevention of fraud and/or identifying and investigating any suspicious use of our Websites;
• for our internal business and management processes, for example, accounting or auditing purposes;
• for any other purpose to allow us to comply with our obligations under law; and
• for any other purposes that would reasonably be expected by you.

If you are a representative of a supplier or a contractor, we will use your personal information to administer and manage our relationship with your business, including obtaining products and services from you, paying accounts and making warranty claims.

If you are a job applicant, employee or contractor with us, we will use your personal information for purposes relating to your engagement, training, performance management, payroll, superannuation, health and safety, for administration and staff management purposes. Where we consider it appropriate, we may also conduct reference checks (or engage a third party to do so on our behalf).

We may use personal information which has been deidentified to create marketing statistics, identify user demands and to conduct audience research and audience targeting.

6. Will personal information be disclosed to third parties?
Personal information may be disclosed to third parties in the circumstances below.

6.1 Customer
If you are a customer, your personal information will be shared with third parties, including but not limited to our contractors and consultants (such as builders, landscapers, drafting and estimating contractors and siting contractors), certifying authorities, local councils and other authorities, your lender and lawyers, our lawyers, valuers, building inspectors, suppliers providing products or services in connection with your building project or related service providers such as insurers or finance providers (including, where relevant, banks and mortgage brokers), our joint venture partner (where applicable) and in limited circumstances, your name only to a subsequent purchaser of your land who may be provided with the building plans or limited parts of the colour selection after evidence of acquisition of the land from you.

Subsidiaries and affiliates of the Rawson Group including but not limited to Rawson Homes, Rawson Communities and Thrive Homes may share your personal information for direct marketing purposes where they have your consent (which may be express or inferred from their relationship with you).

6.2 Third party partners, contractors, suppliers and service providers
Personal information collected by us may be disclosed to third parties to whom we contract out specialised functions and to service providers who facilitate your transactions with the Rawson Group and assist us with the operation of our business. These third parties include but are not limited to providers of digital marketing services, third party software platform providers, customer relationship management software, event ticketing services, website development, invoice processing and mortgage brokering services.

Your personal information may be disclosed to our professional advisors including lawyers, accountants, tax advisors and auditors.

Your personal information may also be shared between Rawson Group’s companies for the purposes outlined in this Privacy Policy, including for direct marketing purposes.

Personal information which has been deidentified may be shared with third parties for the purposes of advertising and/or website enhancement; or with land development partners to measure the success of joint development ventures.

Third parties that assist us in providing Services to you are required to maintain the confidentiality of your information and to use your personal information only in the course of providing the Services and only for purposes for which we have permitted.

From time to time, these third parties may be located overseas including in the USA, European Union, Vietnam, Philippines and Japan. Please be aware that the privacy laws in other countries might not be the same as in Australia. Before we disclose personal information to overseas recipients, we take reasonable steps to ensure that the overseas recipients will handle personal information in accordance with the Privacy Act and the APPs.

6.3 Job applicants and employees
Personal information collected by us may be disclosed to third parties to whom we contract out specialised functions and assist us with the operation of our business including but not limited to providers of culture and engagement surveys and learning and development programs, recruiters and managed verification service providers (who conduct executive background checks).

Your personal information may be disclosed to our professional advisors including but not limited to lawyers, accountants, tax advisors, auditors, insurers and insurance brokers.

Your personal information may also be shared between Rawson Group’s companies for the purposes outlined in this Privacy Policy.

6.4 Disclosures required by law
For legal reasons, other disclosures may need to be made to law enforcement agencies, government agencies, courts or external advisors or as otherwise required or authorised by law.

6.5 Sale of Business
We reserve the right to transfer information (including your personal information) to a third party in the event of a sale, merger or other transfer of all or substantially all of the assets of the Rawson Group (or a Group subsidiary or affiliate) provided that the third party agrees to adhere to the terms of this Privacy Policy and handle personal information in accordance with the APPs.

7. Direct marketing
From time to time, we may use your personal information to provide you with information about our services, special offers you may find of interest or new services being offered by us or any business we are associated with. Direct marketing messages may be sent by or on behalf of any subsidiary or affiliate of the Rawson Group including but not limited to Rawson Homes, Rawson Communities and/or Thrive Homes. Direct marketing messages may be sent by email, SMS or post.

If you do not wish to receive marketing information, you can at any time opt out by contacting our Privacy Officer using the contact details in section 16 (Contacting us) below or by using the opt-out facilities provided (such as an unsubscribe link in an email). Please note that if you opt-out, we may still send you non-promotional messages, such as transactional messages regarding engagements, payments or information about your account.

8. Cookies
We may collect personal information about you when you use and access our Websites. We may record certain information about use of the Websites, such as the pages visited, form submissions, the time and date of the visit, the type of device and browser used and the internal protocol or IP address assigned to the computer or device.

Our Websites also use cookies or similar tracking technologies to help us track Website use and remember user preferences. Cookies are small files that store information on your computer, mobile phone or other device. A cookie enables the entity that put the cookie on your device to recognise you when you use different websites, devices and/or browsing sessions. We use cookies for different purposes such as:

• Authentication: to determine if a user is logged in, and then deliver the right experience and features to that unique user.
• Security: to impose security measures on the Websites. Cookies also help to detect unusual and suspicious activities.
• Advertising: to deliver a better advertising experience for both users and advertisers. Cookies help connect advertisers to users who are interested in their products based on the user’s browsing history.
• Performance: to help our Websites learn how services work for different users and how to route traffic between servers.
• Analytics and Research: to learn which of our services are most frequently used and accessed. This helps determine what areas of our Websites and services to improve, what to remove and what to leave the same.

We may also use cookies to collect data that may include personal information, for example, where a cookie is linked to your user account. Where we collect personal information via cookies, the personal information will be handled in accordance with this Privacy Policy.

You can disable cookies through your internet browser. However, our Websites may not work as intended if you do so.

9. Social Media
Our Websites use interfaces with social media sites such as Facebook, Instagram, LinkedIn, Twitter and others. If you choose to “like” or “share” information from our Websites through these services, you should review the privacy policy of that service. If you are a member of a social media site, the interfaces may allow the social media site to connect your visits to this site with other personal information. Please also see section 11 (Re-marketing) below.

10. Google Analytics
Our Websites use Google Analytics, a service which transmits website traffic data to Google servers in the United States. Google Analytics does not identify individual users or associate your IP address with any other data held by Google. We use reports provided by Google Analytics to help us understand Website traffic and webpage usage.

We use Google Analytics’ third party audience data such as age, gender, and interests to better understand the behaviour of our customers and work with companies that collect information about your online activities to provide advertising and informational material targeted to suit your interests and preferences. For example, you may see certain advertisements on our Websites or other websites because we contract with Google and other similar companies to target our advertisements based on information we or they have collected, including information that was collected through automated means (such as cookies and web beacons). These companies also use automated technologies to collect information when you click on our advertisements, which helps track and manage the effectiveness of our marketing efforts.

By using our Websites, you consent to the processing of your data by Google in the manner described in Google’s Privacy Policy and for the purposes set out above. You can opt out of Google Analytics if you disable or refuse the cookie in your browser settings, disable JavaScript, or use the opt-out service provided by Google (see below).

You can also prevent the data generated by cookies about your use of the Websites (including your IP address) from being passed to Google, and the processing of these data by Google, by downloading and installing the browser plugin available at the following link: https://tools.google.com/dlpage/gaoptout?hl=en.

11. Re-marketing
We use third party vendor re-marketing tracking cookies, including the Google Ads tracking cookie and Meta Pixel. This means we will continue to show advertisements to you across the internet, specifically on the Google Display Network, Facebook and Instagram. We respect your privacy and are not collecting any identifiable information through the use of Google’s or any other third party re-marketing system.

Third-party vendors, including Google, whose services we use, will place cookies on web browsers to display advertisements based on past visits to our Websites. This allows us to make special offers and continue to market our Services to those who have shown interest in our Services.

We also use Facebook Custom Audiences to deliver advertisements to Website visitors on Facebook. We use cookies to serve you with advertisements that may be relevant to you and your interests. The information may also be used for frequency capping purposes (e.g. to ensure we do not display the same advertisement to you repeatedly) and to help us regulate the advertisements you receive and measure their effectiveness.

12. Accessing and correcting your personal information
We will take reasonable steps to ensure that the personal information we collect, use or disclose is accurate, complete and up-to-date. You can help us to do this by letting us know if you notice errors or discrepancies in information we hold about you and letting us know if your personal details change.

You are entitled to access and correct your personal information we hold on request. To request access to and/or correction of your personal information, please contact our Privacy Officer using the contact details set out below. After receiving a request from you, we will take reasonable steps to correct the information.

You will not be charged for making an access and/or correction request but you may be charged for the reasonable time and expense incurred in compiling information in response to your access request.

We may decline your access and/or correction request in certain circumstances in accordance with the APPs. If we do refuse your request:

• we will provide you with a reason for our decision; and
• in the case of a request for correction, we will include a statement with your personal information about the requested correction (if you ask us to do so).

13. Is personal information stored safely?
We take reasonable steps to ensure the security of personal information held by us from such risks as loss or unauthorised access, destruction, use, modification or disclosure. Our IT systems are password protected and comply with our security standards, and if personal information is held on paper files, it is stored in premises that are locked when unattended.

We use technology services providers that store personal information securely primarily in Australia, Japan, the European Union and USA.

14. Third party websites
Sometimes our Websites contains links to other websites for your convenience and information. When you access a website via our Websites, please understand that we are not responsible for the privacy practices of that site. We recommend that you review the privacy policies of each site you visit.

Any information you provide to third party websites will be governed by the terms of the websites’ privacy policies. We have no responsibility or liability whatsoever for the content, actions or policies of third party websites.

15. Further information and complaints
You may contact us at any time if you have any questions or concerns about this Privacy Policy or about the way in which your personal information has been handled.

You may make a complaint about privacy to our Privacy Officer using the contact details set out in section 16 (Contacting us) below.

The Privacy Officer will first consider your complaint to determine whether there are simple or immediate steps which can be taken to resolve the complaint.

Your complaint will then be investigated. We may ask you to provide further information about your complaint and the outcome you are seeking. We will then typically gather relevant facts, locate and review relevant documents and speak with individuals involved.

In most cases, we will investigate and respond to a complaint within a reasonable time, usually within 30 days of receipt of the complaint. If the matter is more complex or our investigation may take longer, we will let you know.

If you are not satisfied with our response to your complaint, you may make a complaint to the Office of the Australian Information Commissioner (OAIC). The OAIC can be contacted by telephone on 1300 363 992 or by using the contact details on the website www.oaic.gov.au.share

16. Contacting us
You can contact our Privacy Officer by:

• emailing us at privacy.officer@rawson.com.au
• by writing to:

Privacy Officer
Level 7, 5 Rider Boulevard
Rhodes NSW 2138

17. Changes to this Privacy Policy
We may change this Privacy Policy from time to time. When we make changes, we will post a notice on our Websites’ homepages and make a new copy of the updated Privacy Policy available on our Websites. Where changes to the Privacy Policy are material, we will provide you with reasonable notice before the changes take effect. If you continue to use our Websites after the effective date of the changes, you will be taken to have accepted the amended Privacy Policy.

Last Updated: 9 November 2023