Gartland (De Stefano Holdings Pty Ltd as Trustee for The Gartland Geelong Unit Trust ABN: 33 915 468 577) recognise the importance of protecting the privacy and the rights of individuals in relation to their personal information. This document is our privacy policy and it tells you how we collect and manage your personal information.

Who this Privacy Policy applies to

This Privacy Policy applies to personal information we handle about:

(i)       website visitors and other individuals who access or use our website or online services;

(ii)      our agency clients and prospective clients, including buyers, sellers, landlords and tenants;

(iii)     job applicants and individuals who enquire about employment with us; and

(iv)     vendors, suppliers, contractors and other service providers (and their personnel) who provide services to us.

The types of personal information we collect, and how we collect, use and disclose it, may differ depending on the nature of your relationship with us and the context in which you interact with us (for example, as a website visitor, a client or prospective client, a job applicant, or a vendor/service provider).

What is your personal information?

When used in this privacy policy, the term “personal information” has the meaning given to it in the Privacy Act 1988 (Cth) and the Australian Privacy Principles. In general terms, it is any information that can be used to personally identify you. This may include your name, date of birth, address, telephone number, email address and profession or occupation. If the information we collect personally identifies you, or you are reasonably identifiable from it, the information will be considered personal information.

What personal information do we collect and hold?

We may collect your name, mailing or street address, email address, telephone number, facsimile number, age or birth date, profession, occupation or job title, governmental identification details and any additional information relating to you that you provide to us directly through our websites or indirectly through use of our websites or online presence, through our representatives or otherwise and information you provide to us through our service centre, customer surveys or visits by our representatives from time to time, including (as applicable) information collected in connection with property sales, leasing and property management services (such as identity verification information, application and tenancy information and payment-related details), recruitment (such as CVs, qualifications, work history, referee details and interview notes) and vendor and service provider management (such as business contact details, licences and qualifications and payment-related details).

We may also collect some information that is not personal information because it does not identify you or anyone else. For example, we may collect anonymous answers to surveys or aggregated information about how users use our website.

How do we collect your personal information?

We collect your personal information directly from you unless it is unreasonable or impracticable to do so. When collecting personal information from you, we may collect in ways including:

• through your access and use of our website
• by telephone, letter, fax or email
• during conversations between you and our representatives
• by contracting with us
• by entering competitions, promotions or requesting information or material from us
• completing surveys, providing feedback or complaining to us

We may also collect personal information from third parties including:

• from third party companies such as credit reporting agencies, law enforcement agencies and government entities
• your representatives (lawyers, accountants and financial advisers)
• your employer
• publicly available sources of information or any other organisations where you have given your consent

Cookies

When you access our website, we may send a “cookie” (which is a small summary file containing a unique ID number) to your computer. This enables us to recognise your computer. It also enables us to keep track of your activity on our website for a period of time. We also use cookies and similar technologies (including online identifiers) to measure traffic patterns, to determine which areas of our website have been visited and to measure transaction patterns in the aggregate. We use this to research our users’ habits so that we can improve our online products and services. Our cookies do not collect personal information. If you do not wish to receive cookies, you can set your browser so that your computer does not accept them. Where available, you can also use any on-site cookie preference tools to manage your cookie settings.

We may log IP addresses (that is, the electronic addresses of computers connected to the internet) and other online identifiers to analyse trends, administer the website and track users movements.

In some cases, third parties may place cookies through our website. For example, Google Analytics, one of the most widespread and trusted website analytics solutions, may use cookies de-identified data about how long users spend on this site and the pages that they visit;

What happens if we can’t collect your personal information?

If you do not provide us with the personal information described above, some or all of the following may happen:

• we may not be able to provide the requested products or services to you, either to the same standard or at all;
• we may not be able to provide you with information about products and services that you may want; or
• we may be unable to tailor the content of our websites to your preferences and your experience of our websites may not be as enjoyable or useful.

For what purposes do we collect, hold, use and disclose your personal information?

We collect personal information about you so that we can perform our business activities and functions (including providing and administering agency services such as sales, leasing and property management) and to provide the best possible quality of customer service.

We collect, hold, use and disclose your personal information for the following purposes:

• to provide products and services to you (including sales, leasing and property management services) and to send communications requested by you;
• to answer enquiries and provide information or advice about existing and new products or services, including screening and onboarding clients, tenants and prospective tenants where applicable;
• to provide you with access to protected areas of our website;
• to assess the performance of the website and to improve the operation of the website;
• to conduct business processing functions including providing personal information to contractors, service providers or other third parties for vendor engagement and service delivery;
• for the administrative, marketing (including direct marketing), planning, product or service development, quality control, survey and research purposes of Gartland, real estate agents and employees or service providers, including recruitment and staffing;
• to update our records and keep your contact details up to date, including for fraud prevention and compliance;
• to process and respond to any complaint made by you; and
• to comply with any law, rule, regulation, lawful and binding determination, decision or direction of a regulator, or in co-operation with any governmental authority of any country (or political sub-division of a country).

Your personal information will not be shared, sold, rented or disclosed other than as described in this Privacy Policy.

To whom may we disclose your information?

We may disclose your personal information to:

• our employees, contractors, or service providers for the purposes of operation of our website or our business, fulfilling requests by you, and to otherwise provide products and services to you including, without limitation, web hosting providers, IT systems administrators, mailing houses, couriers, payment processors, data entry service providers, electronic network administrators, debt collectors, utility providers, maintenance, trades and other property-service vendors, and professional advisors such as accountants, solicitors, business advisors and consultants;
• suppliers and other third parties with whom we have commercial relationships, for business, marketing, and related operational purposes; and
• any organisation for any authorised purpose with your express consent, including relevant counterparties in a transaction (such as landlords, tenants, buyers and sellers where applicable).

Direct marketing materials

We may send you direct marketing communications and information about our products and services that we consider may be of interest to you. These communications may be sent in various forms, including mail, SMS, fax and email, in accordance with applicable Australian marketing laws, such as the Spam Act 2003 (Cth). If you indicate a preference for a method of communication, we will endeavour to use that method whenever practical to do so. In addition, at any time you may opt-out of receiving marketing communications from us by contacting us (see the details below) or by using opt-out facilities provided in the marketing communications and we will action your request within a reasonable timeframe, including where your contact details were obtained from third parties, and we will then ensure that your name is removed from our mailing list.

How can you access and correct your personal information?

You may request access to any personal information we hold about you at any time by contacting us (see the details below). Where we hold information that you are entitled to access, we will try to provide you with suitable means of accessing it (for example, by mailing or emailing it to you). We may charge you a fee to cover our administrative and other reasonable costs in providing the information to you and, if so, the fees will be disclosed on our website. We will not charge for simply making the request and will not charge for making any corrections to your personal information.

There may be instances where we cannot grant you access to the personal information we hold. For example, we may need to refuse access if granting access would interfere with the privacy of others or if it would result in a breach of confidentiality. If that happens, we will give you reasons for any refusal.

If you believe that personal information we hold about you is incorrect, incomplete or inaccurate, then you may request us to amend it. We will consider if the information requires amendment. If we do not agree that there are grounds for amendment then we will add a note to the personal information stating that you disagree with it.

What is the process for complaining about a breach of privacy?

If you believe that your privacy has been breached, please contact us using the contact information below and provide details of the incident so that we can investigate it. We will deal with the complaint in accordance with our then current Complaints Handling Procedure. If you are not satisfied with our response, you may make a complaint to the Office of the Australian Information Commissioner (OAIC) (www.oaic.gov.au) or by calling 1300 363 992.

Do we disclose your personal information to anyone outside Australia?

We may disclose personal information to third-party suppliers and service providers located overseas (including IT and data hosting providers) for some of the purposes listed above. We take reasonable steps to ensure that the overseas recipients of your personal information do not breach the privacy obligations relating to your personal information, including by conducting due diligence on overseas recipients and requiring appropriate contractual protections.

We may disclose your personal information to entities located outside of Australia, including the following:

• our data hosting and other IT service providers, located in various countries; and
• other third parties located in various foreign countries.
• We may disclose your personal information to entities within Australia who may store or process your data overseas. In the event that a disclosure is made in an overseas country (which we consider unlikely), the information will not be protected by the Australian Privacy Principles. We will only disclose or store personal information overseas where we have taken reasonable steps to ensure the overseas recipient handles the information in a way that is consistent with the Australian Privacy Principles (for example, by assessing the recipient’s privacy and security practices and requiring appropriate contractual protections), or where another exception under the Privacy Act 1988 (Cth) applies.

Security

We take reasonable steps to protect personal information we hold from misuse, interference and loss, and from unauthorised access, modification or disclosure. If we suspect or become aware of a data breach involving personal information, we will take steps to assess the suspected breach and, where appropriate, to contain and manage it, including by investigating the circumstances, taking remedial action to reduce the risk of harm, and reviewing our security measures. Where we are required to do so under the Notifiable Data Breaches scheme in the Privacy Act 1988 (Cth), we will notify affected individuals and the Office of the Australian Information Commissioner as soon as practicable after becoming aware that an eligible data breach has occurred, and we will provide information about the breach and recommended steps individuals should take in response.

We take reasonable steps to protect personal information from misuse, interference and loss, and from unauthorised access, modification or disclosure, including by implementing administrative, technical and physical safeguards and appropriate vendor and security governance. As our website is linked to the internet, and the internet is inherently insecure, we cannot provide any assurance regarding the security of transmission of information you communicate to us online. We also cannot guarantee that the information you supply will not be intercepted while being transmitted over the internet. Accordingly, any personal information or other information which you transmit to us online is transmitted at your own risk.

Retention and Storage

We retain personal information only for as long as it is necessary to fulfil the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law. When personal information is no longer required for those purposes (and we are not required or permitted by law to retain it), we will take reasonable steps to destroy it or to de-identify it so that it can no longer be used to identify you. By way of example, we may retain: agency and property management files (including correspondence, inspection reports and tenancy or sales records) for as long as needed to manage the relevant matter and to meet our legal and regulatory obligations; recruitment records (including job applications, resumes and interview notes) for as long as needed to assess your application and manage recruitment processes, and for a reasonable period afterwards to respond to queries or complaints and to meet legal obligations; and vendor, supplier and payment records (including invoices, payment details and transaction records) for as long as needed to administer our relationship with you, process payments, manage accounts, and meet taxation, accounting and audit requirements.

Links

Our website may contain links to other websites operated by third parties. We make no representations or warranties in relation to the privacy practices of any third-party website and we are not responsible for the privacy policies or the content of any third party website. Third party websites are responsible for informing you about their own privacy practices.

If you have any questions about this privacy policy, any concerns or feedback regarding the treatment of your privacy, please use the contact link on our website or contact our Privacy Officer using the details set out below.

We will treat your requests or complaints confidentially. Our representative will contact you within a reasonable time after receipt of your complaint to discuss your concerns and outline options regarding how they may be resolved. We will aim to ensure that your complaint is resolved in timely and appropriate manner, and will keep you informed of the progress of your complaint.

Please contact our General Manager at:

General Manager
Gartland
P.O Box 636, Geelong  VIC  3220
Email: [email protected]

Changes to our privacy policy

We may change this privacy policy from time to time. Any updated versions of this privacy policy will be posted on our website. This privacy policy was last updated on 13 August 2026.