The Apartment Service (“TAS”, “we”, “us” or “our”) respects the privacy of our property owners, guests, clients, contractors and other individuals with whom we deal.

We are committed to handling personal information responsibly and, where applicable, in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).

This Privacy Policy explains how we collect, hold, use, disclose and protect personal information in connection with our accommodation, property management, leasing and associated services.

Personal information is information or an opinion about an identified individual, or an individual who is reasonably identifiable.

Depending on the nature of our relationship with you, the personal information we collect may include:

• your name, residential or postal address;
• telephone number and email address;
• date of birth;
• identification information where reasonably required;
• bank account and payment details;
• property ownership and property-related information;
• correspondence and communications with us;
• booking, accommodation and transaction information;
• billing, invoicing and financial records;
• insurance information;
• strata, building or property management information;
• information concerning maintenance, repairs or incidents at a property;
• photographs, documents or information you provide to us;
• information relating to guests or occupants where relevant to the management of a property; and
• any other information reasonably necessary for us to provide our services.

We will only collect sensitive information where it is reasonably necessary for our functions or activities and where we are permitted to do so by law.

When you appoint The Apartment Service to manage, market or provide accommodation services for your property, we may collect information necessary to establish and manage that relationship.

This may include:

• your contact information;
• proof of ownership or authority to appoint us;
• banking information required to make payments to you;
• information about the property and its contents;
• insurance details;
• strata or building information;
• utility and service provider information;
• emergency contact information;
• maintenance and contractor information;
• financial and transactional records;
• records relating to bookings, rental income, fees and expenses; and
• communications between you and The Apartment Service.

We use this information primarily to manage your property, process bookings, account to you, arrange payments, coordinate services and fulfil our contractual, legal and administrative obligations.

In operating short-term and furnished accommodation, we may also collect personal information about guests and prospective guests.

This may include:

• name and contact information;
• booking and accommodation details;
• payment information;
• identity verification information where reasonably required;
• information relating to the purpose or requirements of a stay;
• communications with our team;
• information regarding additional occupants;
• information concerning incidents, damage, maintenance or complaints; and
• other information necessary to process or manage a reservation.

Guest information may be received directly from guests or through booking platforms, travel agents, corporate accommodation providers or other booking partners.

We do not provide property owners with copies of guest identification documents merely because the guest has stayed at their property. Such information will only be disclosed where there is an appropriate legal, operational or safety basis to do so.

Where practical, we collect personal information directly from the individual concerned.

We may collect information:

• when you contact us by telephone, email, website, online form or in person;
• when an owner enters into a management, leasing or accommodation arrangement with us;
• when a guest makes or enquires about a booking;
• through our website and online booking systems;
• through property management and reservation systems;
• from booking platforms such as Airbnb, Booking.com, Vrbo and similar services;
• from corporate accommodation providers or travel agents;
• from payment providers;
• from owners, strata managers, building managers and contractors;
• through third-party software providers used to deliver our services;
• from publicly available sources; and
• where otherwise permitted or required by law.

If you provide personal information to us about another person, you should ensure that you are authorised to provide that information.

We may collect, hold, use and disclose personal information for purposes including:

• providing accommodation and property management services;
• marketing and managing properties;
• responding to booking enquiries;
• processing and managing reservations;
• communicating with owners and guests;
• processing payments, refunds and owner disbursements;
• preparing owner statements and financial records;
• arranging cleaning, linen, maintenance and repair services;
• coordinating access to properties;
• managing check-in and check-out processes;
• verifying identity where reasonably necessary;
• preventing or investigating fraud, unlawful activity or security incidents;
• managing complaints, claims, disputes, damage or insurance matters;
• complying with strata, building or property requirements;
• responding to emergencies and safety concerns;
• maintaining our business and accounting records;
• improving our systems and services;
• communicating with you about services that may be relevant to you; and
• complying with our legal and regulatory obligations.

We may also use information for related purposes that would reasonably be expected in connection with our services.

To provide our services, we may disclose personal information where reasonably necessary to third parties including:

• online travel agents and booking platforms;
• property management and reservation software providers;
• payment processors and financial institutions;
• accountants, auditors and professional advisers;
• cleaners, linen providers and maintenance contractors;
• tradespeople and other service providers;
• strata managers and building managers;
• insurers and insurance assessors;
• information technology and cloud service providers;
• communication and messaging providers;
• identity or fraud verification providers;
• government departments, regulators or law enforcement agencies where legally required or otherwise permitted by law; and
• other parties with your consent or where permitted by law.

We seek to limit information provided to contractors and service providers to what is reasonably necessary for them to perform the relevant service.

For example, a cleaner may need a guest’s arrival or departure information but would not ordinarily require access to the guest’s payment information.

Our properties may be advertised or booked through third-party platforms such as Airbnb, Booking.com, Vrbo and other accommodation distribution channels.

These providers operate under their own privacy policies and may independently collect and process personal information.

We also use third-party technology providers to assist with reservations, property management, guest communications, payments, cleaning, maintenance, pricing and other aspects of our operations.

Where you interact directly with a third-party service, we recommend reviewing that provider’s privacy policy.

Some of the technology providers, booking platforms, cloud service providers and other service providers we use may store or process information outside Australia.

As a result, personal information may be disclosed to or accessible from overseas jurisdictions.

Where required by the Australian Privacy Principles, we will take reasonable steps in relation to the protection of personal information disclosed to overseas recipients.

Because the service providers and technology systems used by our business may change from time to time, the countries in which information is processed or stored may also change.

Where it is practicable to identify the countries in which overseas recipients are located, further information may be obtained by contacting us using the details below.

From time to time, we may use your contact information to communicate with you about our services, property management opportunities, accommodation offers, company updates or other information we reasonably believe may be relevant to you.

Where required, you may opt out of receiving marketing communications at any time by using the unsubscribe facility contained in the communication or by contacting us.

Operational communications relating to an existing property, booking, account or service may still be sent where necessary.

We take reasonable steps to protect the personal information we hold from misuse, interference, loss and unauthorised access, modification or disclosure.

These measures may include:

• access controls and password protection;
• multi-factor authentication where appropriate;
• restricted staff access based on operational requirements;
• secure cloud-based business systems;
• appropriate security measures for payment information;
• staff procedures relating to confidentiality and information handling;
• monitoring and updating our technology and business processes; and
• limiting the personal information disclosed to contractors and other third parties.

No electronic transmission or storage system can be guaranteed to be completely secure. We therefore continually review our procedures and take reasonable measures appropriate to the nature of the information we hold.

If we become aware of a data breach involving personal information, we will investigate and respond in accordance with our legal obligations.

Where the Notifiable Data Breaches scheme applies and a breach is likely to result in serious harm to affected individuals, we will take the steps required by law, which may include notifying affected individuals and the Office of the Australian Information Commissioner.

We retain personal information for as long as reasonably necessary for the purposes for which it was collected and to meet our legal, accounting, taxation, insurance, dispute management and record-keeping obligations.

When personal information is no longer required and we are not legally required to retain it, we will take reasonable steps to securely destroy or de-identify it.

Some information may remain within secure system backups for a period after it has been removed from active systems.

You may request access to personal information that we hold about you.

We will generally provide access within a reasonable period, subject to any exceptions permitted under applicable privacy laws.

We may need to verify your identity before providing access to personal information.

In some circumstances we may refuse access, including where permitted or required by law. If this occurs, we will generally provide an explanation for the refusal where required.

We take reasonable steps to ensure that personal information we use or disclose is accurate, current, complete and relevant.

If you believe that information we hold about you is inaccurate, incomplete or out of date, please contact us and request that it be corrected.

We may need to verify the information before making the requested change.

Where it is lawful and practical to do so, individuals may have the option of interacting with us anonymously or using a pseudonym.

However, because of the nature of accommodation bookings, property management, payments, contracts and property access, it will often be impractical for us to provide our services without knowing an individual’s identity.

When you visit our website, certain technical information may be automatically collected, such as:

• IP address;
• browser type;
• device information;
• pages visited;
• referring website;
• time and date of access; and
• website usage information.

Our website and third-party services may use cookies or similar technologies to help operate the website, analyse usage and improve our services.

You may be able to adjust your browser settings to restrict cookies, although doing so may affect some website functionality.

If you believe we have not handled your personal information appropriately or have not complied with our privacy obligations, please contact us.

Please provide sufficient information for us to understand and investigate your concern.

We will acknowledge and investigate privacy complaints and aim to respond within a reasonable period.

If you are not satisfied with our response and the Privacy Act applies to the matter, you may be able to lodge a complaint with the Office of the Australian Information Commissioner (OAIC).

Further information about privacy rights and complaints is available from the OAIC at www.oaic.gov.au.

We may update this Privacy Policy from time to time to reflect changes in:

• our business operations;
• technology and systems;
• third-party service providers;
• booking and distribution platforms; or
• applicable laws and regulatory requirements.

The current version will be made available through our website or upon request.

For questions about this Privacy Policy, requests for access or correction of personal information, or privacy complaints, please contact:

Privacy Officer
The Apartment Service (Australia) Pty Limited
ABN 14 050 210 896
17/332 Military Road, Cremorne NSW 2090, Australia

Telephone: +612 9953 7288
Email: info@apartmentservice.com.au
Website: www.apartmentservice.com.au