This privacy policy (Policy) describes how Zango ACT Pty Ltd, ACN 635 878 134 of Bellchambers Barrett, Suite 3 Level 3 44 Sydney Avenue Forrest ACT 2603 and any of its related parties (Zango) may collect, use and disclose Personal Information (as defined in paragraph 2).
This Policy has been formulated in accordance with the Australian Privacy Principles (APPs) set out in the Privacy Act 1988 (Cth) (Privacy Act) and any other applicable data protection laws including the EU General Data Protection Regulation (GDPR).
A copy of this Policy is available upon request by contacting Zango at the details set out below.
This Policy applies to any customer, user, or other person (the User, Users, You, or Your) who:
(a) accesses any Zango website or application (Site); and
(b) accesses or utilises any Zango product, service , feature, user-generated and other Zango generated content or resources (collectively, the Services).
This Policy applies only to Personal Information (as defined in paragraph 2) and location information that a User discloses or transmits to Zango via the Site or that is collected by Zango in the course of the provision of the Services.
Zango is not responsible for the privacy policies or content of any third-party websites (including advertisers) that You may access through links on Zango’s Site, and You must rely on that third-party Site for information about their privacy practices.
Personal information means information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether true or not and whether recorded in a material form or not (Personal Information).
By providing Zango with Personal Information, or through Your use of Zango’s Site, or by retaining Zango to provide the Services, You agree with the terms of this Policy. Whenever You submit Personal Information to Zango, You consent to the collection, handling, use, disclosure and storage of that Personal Information by Zango in accordance with this Policy, the Privacy Act (including the APPs), any other applicable data protection legislation including the GDPR and any other contractual relationship that You have with Zango. If You do not consent to the collection, use and disclosure of Your Personal Information or location as described in this Policy, You are not permitted to use the Site and Zango will not be able to provide Services to You.
Zango generally processes and stores Personal Information on its servers in Australia. In some cases, Zango may also rely on data processors, service providers, data hosting and servers located overseas. Consequently, You should be aware that Your Personal Information may be disclosed to overseas recipients. In addition, Zango may process some Personal Information to provide its own Services, and/or Services on behalf of and according to the instructions of a third party, such as Zango’s advertising partners, which may also include disclosure to overseas recipients.
This Policy is incorporated into and is subject to the Zango Terms and Conditions. Your use of the Services and Your provision of any Personal Information or location information to Zango is subject to the terms of this Policy, Zango’s Terms and Conditions and any other terms under which You have engaged with Zango.
Zango collects Personal Information that is reasonably necessary for it to perform its functions. This may include:
(a) information You give Zango when You request Services from Zango (including, without limitation, a real estate product or service);
(b) financial information about You such as Your financial position and information obtained from credit checks if You have authorised Zango to carry out those checks;
(c) communication between Zango and other professionals that You have authorised Zango to communicate with, such as Your mortgage broker or real estate agent; and
(d) transactional information about the use of a product if You have or have had a product with Zango.
The types of Personal Information Zango may collect may include Your name, address, telephone numbers, e-mail address, what Services You use, and when You use them, location information, information on how You use Zango’s Services and how much You spend, information on Your browsing activity when visiting Zango’s Site, and personal preferences regarding the use of Zango’s Services.
Zango will collect the Personal Information directly from You at the time You ask Zango to provide You with the Services, or if You access the Site.
Your use of the Site will determine the amount and type of information that Zango will collect about You.
If You browse Zango’s website, Zango’s internet service provider logs the following information:
(a) Your server (IP) address and top level domain name;
(b) the date and time of Your website visit;
(c) the country that Your server is located;
(d) the pages that You looked at;
(e) the type of browser You used;
(f) the previous Site You visited; and
(g) the Site You visited next.
Some of this information (such as browser type and version, operating system, sites visited) will not be Personal Information because it will not reveal Your identity. This information allows Zango to analyse User behaviour in an anonymous form, and is typically used to improve the quality and Services of Zango’s website and to prevent fraud, maintain the integrity of Zango’s IT systems, and to enhance the security of Zango’s network and IT systems.
Some of the Services may feature or include various location-based components. Location information includes, but is not limited to, any information Zango derive in order to identify a User’s geographic position. This information may be collected directly from a User, or from a User’s wireless carrier or from certain third party service providers. A User’s location information, however, is only displayed and shared in accordance with his or her established privacy settings.
Zango will not use information obtained from Your browsing activities to send You any unsolicited information.
The only Personal Information which Zango collects about You when You use the Site is what You tell Zango about yourself: for example, by completing an online form such as an application form, or by asking for a disclosure document for Zango’s products, or by sending Zango an email.
Whenever Zango collects “sensitive information” (such as certain financial information) from You, then such information will be treated in accordance with the relevant rules and requirements of the Privacy Act.
Zango will take reasonable steps to ensure that the Personal Information Zango collects, uses or discloses is accurate, complete, up-to-date and stored in a secure environment protected from unauthorised access, modification or disclosure.
Zango will only retain Your Personal Information for as long as it is reasonably necessary to fulfil the purpose/s for which it was collected or as required for a reporting, legal or accounting purpose.
The Personal Information You provide to Zango will enable Zango to provide Zango’s Services to You. This information may also be used to help Zango develop and make available Services to suit Your needs. In particular, the Personal Information You provide Zango may be collected, used and disclosed for a number of purposes connected with Zango’s business operations, which may include:
(a) verifying Your identity or transactions which You may enter into with Zango (including as required pursuant to applicable anti-money laundering and anti-terrorism financing legislation);
(b) administering and managing the provision of Zango’s Services;
(c) providing You with information, products and/or Services requested;
(d) responding to queries or complaints;
(e) complying with Zango’s risk management policies and procedures;
(f) training Zango’s staff;
(g) telling You about other products or Services that may be of interest to You;
(h) billing You and/or administering or otherwise managing Your account;
(i) dealing with requests, enquiries or complaints and other customer Service activities;
(j) carrying out market and product analysis and marketing products and Services;
(k) assisting in arrangements with other organisations in relation to the promotion or provision of a product or Service;
(l) purposes relating to any third party acquisition or potential acquisition of an interest in Zango or its assets; and
(m) carrying out any activity in connection with a legal, governmental or regulatory requirement that Zango have to comply with or in connection with legal proceedings, crime or fraud prevention, detection or prosecution, including investigating any fraud, unlawful activity or misconduct.
Zango may also use Your Personal Information for purposes related to those described above which would be reasonably expected by You. For example, Zango may use Your Personal Information to keep You informed about features of its products and Services or to conduct analysis in order to provide better customer Service. As noted above, if You provide information that may be deemed sensitive information for the purpose of Privacy Act, Zango will manage and treat that information in accordance with the APPs.
If You do not provide some or all of the information requested, Your experience of Zango’s Service may be impaired. Zango may have to discontinue its business or sales relationship with You, or Zango may not be able to provide You with particular Services or access to certain features on Zango’s Site. For example, there may be parts of Zango’s Site that You are unable to access, Zango may be unable to provide You with information about products and Services that may interest You, and You may also miss out on offers and special deals.
Zango uses cookies and other tracking software to provide You with an enhanced Service and a more personalised experience. Cookies may also be used to analyse trends, diagnose problems, track Your engagement with the Site and Services, gather data on search patterns, administer its website, and gather broad information. The information Zango collects through cookies may be Personal Information. Where it is not by itself Personal Information, it may become Personal Information if it is linked to Personal Information about an individual. If the information collected is Personal Information, Zango will use and manage that information in accordance with this Policy, the Privacy Act and other relevant legislation.
You can choose not to accept cookies, or You can set Your browser to block cookies, in which case Your experience of Zango’s Site may be impaired. You can also clear stored cookies from Your browser.
Due to the nature of some of Zango’s business activities, Zango’s use of some Personal Information may be exempt from the operation of the Privacy Act. These exemptions may include:
(a) dealing with Personal Information contained in Your employment record in certain circumstances where Zango has a current or former employment relationship with You; and
(b) dealing with Your Personal Information in the course of journalism (Media Exemption). Where the Media Exemption applies, Zango will comply with the Australian Press Council Privacy Standards. If You require more information on the collection and use of Personal Information in the course of journalism, please visit the Australian Press Council Privacy Standards at www.presscouncil.org.au/privacy-principles.
Zango may disclose or receive Personal Information or documents about You to/from:
(a) Zango’s employees and related bodies corporate, in the course of their role as employees and as related bodies corporate, respectively;
(b) any organisation that is in an arrangement with Zango to jointly offer products and or has an alliance with Zango to share information for marketing purposes to enable that organisation or Zango to provide You with products or Services or promote a product or Service;
(c) parties involved in any third-party acquisition or potential acquisition of an interest in Zango or its assets;
(d) Service providers or agents (some of whom may be overseas) who assist Zango in providing its Services, including organisations that assist Zango with archival, research, mail and delivery, auditing, consulting, financial and legal advisory, banking, security, storage or technology Services;
(e) regulatory bodies, government agencies, law enforcement agencies and courts and any organisation that assist Zango to identify, prevent or investigate fraud, unlawful activity or misconduct;
(f) Your authorised agents, executor, administrator or trustee in bankruptcy, Your legal representative, attorney or anyone acting for You in connection with Your account;
(g) a real estate agent or agency where You submit an agent review on that real estate agent or agency when using the Service;
(h) overseas recipients, in certain circumstances; and
(i) any other party as otherwise permitted by law (including the Privacy Act).
Where information is disclosed to overseas recipients, Zango will take reasonable steps to ensure that any overseas recipient does not breach the APPs. You should be aware, however, that Your rights to make a claim against Zango in relation to any misuse of Your Personal Information by an overseas recipient will be limited.
You may nominate third parties to view or access the account details maintained by Zango in respect of You for any purpose. If You nominate a third party, that third party may be able to view and/or access Your information. By nominating a third party, You explicitly consent to the sharing of Your information with that third party by Zango.
Zango may combine the Personal Information and/or the location information that You submit to Zango with information from other Services or third parties in order to provide You with an enhanced experience and/or to improve the overall quality of the Services. For certain Services, Zango may give You an opportunity to opt-out of the combination of such information.
Where You submit an agent review when using the Service and Your Personal Information is disclosed to the real estate agent or agency pursuant to the above sub-paragraph (g), You further permit that real estate agent or agency to disclose or publish the agent review (including any Personal Information as contained in that agent review) on their own platforms and channels.
The General Data Protection Regulation (GDPR) is a comprehensive European data protection law that provides greater data rights for individuals and increases compliance responsibilities for organizations. The GDPR grants EU residents greater control over their Personal Data (as defined in Article 4 GDPR and in general terms meaning data which, in isolation or in combination with other information, enables You to be identified directly or indirectly) and gives national regulators new powers to impose significant fines on organizations that breach this law.
Where the GDPR applies with regard to any Personal Data Zango collects, then this section applies to that Personal Data. For the purpose of GDPR, Zango is the ‘controller’.
If You are a resident in the European Economic Area (EEA), You have these rights with respect to Your Personal Data:
You can request to exercise any of these rights in relation to Your Personal Data by sending the request to the Privacy Officer at the contact details provided at the end of this Policy.
If You have a complaint with respect to Your Personal Data and You are based in the EEA, or the issue You would like to complain about took place in the EEA, please refer to Your local data protection authority.
When You purchase goods or Services from Zango, any credit card information or other information (if any) You give Zango to purchase the goods or Services is used to process the payment. The original request/application/enrolment form may be stored securely in the Zango office for audit/taxation requirements and to assist individuals who request duplicate information for their own records. These documents are then destroyed. Zango’s database only records that You attended an activity or purchased a Service and how much You paid for it. Zango does not store Your credit card details on Zango’s database.
Zango takes appropriate measures to protect unauthorised access to, or unauthorised alteration, disclosure or destruction of, the Personal Information and location information transmitted or disclosed to Zango. These include internal reviews of Zango’s data collection, storage and processing practices and security measures, as well as physical security measures to guard against unauthorised access to systems where User data is collected, stored, and/or maintained.
Zango requires that when You log in to the Site or utilise Services that require a log in, a secure connection between Your computer and Zango’s server be established. Zango cannot warrant or ensure the security of any Personal Information and location information that it receives on behalf of Users or any other information that a User transmits, shares or discloses to Zango. For improved security, Zango recommends that Users use the https:// prefix when using its Services. Zango may also use technology such as Secure Socket Layer (SSL) encryption technology to increase the encryption of connections between Zango and You. Despite the possibility that Zango is using technology such as SSL encryption to safeguard the confidentiality of Personal Information as far as possible, You should be aware that no Internet or e-mail transmission is ever fully secure or error free.
Zango cannot guarantee that information will not be accessed, shared, disclosed, altered, or destroyed by a breach of any of Zango’s physical, technical, or other safeguards. Zango recommends that You take special care in deciding what information is shared, transmitted or disclosed to Zango.
Zango processes Your Personal Information only for the purposes for which it was collected and in accordance with this Policy or any applicable terms that You agree with Zango. Zango review data collection, storage, and processing practices to ensure that Zango only collect, store and process the Personal Information needed to provide or improve the Services. Zango will take reasonable steps to ensure that the Personal Information Zango processes is accurate, complete, and current, but Zango depends on You to update or correct Your Personal Information wherever necessary.
From time to time it may be necessary for Zango to review and amend this Policy. Subject to the terms of the Privacy Act and the APPs, Zango reserve the right to amend this Policy at any time. You should check Zango’s website from time to time for Zango’s latest Policy. Your continued use of the Services constitutes Your agreement to this Policy and any future revisions.
Once Zango has collected Your Personal Information, You are entitled under APP 12 to request the details of the information Zango is holding about You. In order to request such information, You need to contact Zango by letter, email or telephone and outline the nature of Your enquiry. Zango will take reasonable steps to let You know, generally, what sort of Personal Information Zango hold, for what purposes and how Zango collect, use and disclose that information.
Upon Your request and verification of Zango’s identity, Zango will provide access to Your Personal Information Zango hold, except in certain circumstances, including emergency situations, specified business imperatives, law enforcement, public interests reasons, where it would interfere with the privacy of others or where it would result in a breach of confidentiality.
Zango will endeavour to keep and maintain the data held by Zango as accurate, complete, relevant and up to date as possible. It is important that the information that Zango hold about You is up to date. You must let Zango know if information that You have provided to Zango has changed.
The APPs also give You a right to request correction of Your Personal Information. If You establish that Personal Information held by Zango is not accurate, complete, relevant, up-to-date or is misleading, Zango will take reasonable steps in accordance with its obligations under the Privacy Act and APPs to correct the information so that it is accurate, complete, relevant, up-to-date and not misleading.
If You would like to access or correct Your Personal Information, please contact:
The Privacy Officer
Email: [email protected]
To opt-out of receiving certain Zango marketing materials, You will need to tell Zango.
To do this please send Zango an email with "unsubscribe" in the Subject Field to [email protected]
Please note that if You have an account with Zango, Zango will still need to send You essential information about Your account.
If You have a question, concern or complaint regarding the way in which Zango handle Your Personal Information please contact Zango on the details listed below. You are entitled to lodge a complaint if You believe that Zango have breached the APPs. If You wish to lodge a complaint with Zango, You need to write to Zango setting out the details of Your complaint as addressed to:
The Privacy Officer
Email: [email protected]
Zango will issue You with a response to any complaint within a reasonable time that, if appropriate, will outline the measures that Zango will take to resolve the complaint.
If You feel that Zango has not satisfactorily addressed Your complaint, You may also make a complaint to the Office of the Australian Information Commissioner (OAIC) by visiting www.oaic.gov.au or by writing to GPO Box 5218 Sydney NSW 2001 in accordance to instructions listed on OAIC website.
If You have any additional questions or concerns about this Policy, please feel free to contact Zango any time by email at [email protected].
This Policy was last updated 25/02/2021