Privacy Policy

Last updated: 01 March 2022

Real Tenure Pty Ltd

  1. We respect your privacy

    1. Real Tenure Pty Ltd (ABN 81 644 230 320) and VALTER (“Real Tenure”, “VALTER”, “Company”, “we”, “our” or “us”) are committed to respecting your right to privacy and safeguarding the privacy of our customers and website visitors at valte.com.au (“this site”, “our website”).
    2. We adhere to the Australian Privacy Principles contained in the Privacy Act 1988 (Cth). If you require any further information about the Privacy Act and the Australian Privacy Principles, you can visit the Office of the Australian Information Commissioner at https://www.oaic.gov.au/.
    3. “Personal information” is information we hold which is identifiable as being about you. This Privacy Policy details how we collect and treat your personal and other information.

  2. Collection of personal and other information

    1. Real Tenure Pty Ltd will, from time to time, receive and store personal information you enter onto our website, provided to us directly or given to us in other forms.
    2. We will only collect personal information that is necessary for us to conduct our business as a digital lease and real estate management platform.
    3. You may be asked to provide personal information such as your name, phone number, address and email address when you access our website, to enable us to send information, correspond and interact with you and provide you our services. We may collect additional information at other times, including but not limited to, when third parties, such as other clients, provide it to us on a lawful basis, when you provide feedback, when you provide information about your personal or business affairs, change your content or email preference, respond to surveys and/or promotions, provide financial or credit card information, communicate with our customer support.
    4. We may also collect additional information when you input or upload information related to leasing and/or real estate, including but not limited to:
      1. Commercial lease information, such as the location of properties, rent details, lease expiry and other milestone dates, rental incentives;
      2. Building details;
      3. Client details of landlord users;
      4. Workplace and occupancy data, such as employee numbers, aggregate employee attendance and how leased space is occupied;
      5. Property and lease strategies; and
      6. Construction and equipment costs (together, “Property Information”).
    5. Additionally, we may also collect any other information, whether personal information or Property Information, you provide while interacting with us, whether electronically or in person.
    6. No one is obliged to provide personal information or Property Information. However, please note that failure to do so may result in us being unable to provide you with our products, services, information and other content, including where requested by you.
    7. Where practicable, we will allow you to deal with us on an anonymous or pseudonymous basis. If this is practicable, our collection channels will only seek information in this way. However, where it is not practicable for the purposes for which information is collected, we will seek the personal information identified above. It will not be practicable to deal with you on an anonymous or pseudonymous basis when we wish to provide you information about our services as requested by you.
    8. Personal information will not be collected from any person who is known by the Company to be under the age of sixteen (16) without the consent of a parent or legal guardian or as has been provided to us lawfully by third parties, including our clients. Persons under age sixteen (16) may only use our website with the involvement and consent of a parent or legal guardian.

  3. Use of your personal and other information

    1. Real Tenure Pty Ltd may use personal information and Property Information collected from you to provide you with information, updates and our services. We may also make you aware of new and additional products, services and opportunities available to you. We may use your personal information and Property Information to improve our products and services and better understand your needs, and for any other purpose reasonably considered necessary or desirable by the Company in relation to the operation of our business.
    2. Real Tenure Pty Ltd may also use Property Information collected from you for data aggregation purposes related to the operation of our business as a digital lease and real estate management platform, including but not limited to:
      1. Compilation and analysis of statistics and trends;
      2. Providing aggregate benchmarking data, in addition to external data sources, including but not limited to:
        • Average rental per location precinct;
        • Lease expiry profile per precinct;
        • Lease expiry profile per building;
        • Cost per work point;
        • Work point density per business sector; and
        • Attendance ratios per precinct and business sector.

      Property Information will be treated by Real Tenure Pty Ltd as strictly confidential information and it will not be used in any other manner other than as set out in this Privacy Policy.

    3. Real Tenure Pty Ltd may contact you by a variety of measures including, but not limited to telephone, email, SMS or mail.
    4. If you would prefer not to receive promotional or other material from us, please let us know and we will respect your request. You can unsubscribe from such communications at any time if you choose.

  4. Disclosure of your personal and other information

    1. We may disclose your personal and other information, including Property Information, to any of our employees, officers, insurers, professional advisers, agents, suppliers or subcontractors insofar as reasonably necessary for the purposes set out in this Policy. Personal information and Property Information are only supplied to a third party when it is required for the delivery of our services.
    2. We may from time to time need to disclose personal information and Property Information to comply with a legal requirement, such as a law, regulation, court order, subpoena, warrant, in the course of a legal proceeding or in response to a law enforcement agency request.
    3. We may also use your personal information and Property Information to protect the copyright, trademarks, legal rights, property or safety of Real Tenure Pty Ltd, VALTE, its customers or third parties.
    4. Information that we collect may from time to time be stored, processed in or transferred between parties located in countries outside of Australia.
    5. If there is a change of control in our business or a sale or transfer of business assets, we reserve the right to transfer to the extent permissible at law our user databases, together with any personal information and non-personal information (including Property Information) contained in those databases. This information may be disclosed to a potential purchaser under an agreement to maintain confidentiality. We would seek to only disclose information in good faith and where required by any of the above circumstances.
    6. By providing us with personal and other information, including Property Information, you consent to the terms of this Privacy Policy and the types of disclosure covered by this Policy. Where we disclose your personal information to third parties, we will request that the third party follow this Policy regarding handling your personal information.

  5. Security and retention of your personal information

    1. Real Tenure Pty Ltd is committed to ensuring that the information you provide to us, including Property Information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures (including but not limited to data encryption and secure and regular backup cycles) to safeguard and secure information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.
    2. Please note that any requests to access data located in our backup storage will be subject to the timing of any Real Tenure Pty Ltd retrieval processes and be at your own expense.
    3. Real Tenure Pty Ltd will also take all reasonable measures to not misuse or permit any unauthorised use of all personal information and Property Information.
    4. The transmission and exchange of information is carried out at your own risk. We cannot guarantee the security of any information that you transmit to us, or receive from us. Although we take reasonable measures to safeguard against unauthorised disclosures of information, we cannot assure you that personal information and Property Information that we collect will not be disclosed in a manner that is inconsistent with this Privacy Policy. However, we will inform you about any serious data breaches as may be required of us under the Privacy Act 1988 (Cth).
    5. We will only keep your data for as long as is necessary for the purpose for which it was collected, subject to satisfying any legal, accounting or reporting requirements. At the end of any retention period, your data will either be deleted completely or anonymised (for example, by aggregation with other data so that it can be used in a non-identifiable way for statistical or trend analysis and business planning). In some circumstances, you can ask us to delete your data.

  6. Access to your personal information

    1. You may request details of personal information that we hold about you in accordance with the provisions of the Privacy Act 1988 (Cth). A small administrative fee may be payable for the provision of information. If you would like a copy of the information, which we hold about you or believe that any information we hold on you is inaccurate, out of date, incomplete, irrelevant or misleading, please email us at info@valte.com.au.
    2. We reserve the right to refuse to provide you with information that we hold about you, in certain circumstances set out in the Privacy Act. We may also refuse access where the personal information relates to existing or anticipated legal proceedings, and the information would not be accessible by the process of discovery in those proceedings.
    3. If we refuse to provide you with the requested information we will provide you with the reasons for our refusal.

  7. Complaints about privacy

    1. If you have any complaints about our privacy practises, please feel free to send in details of your complaints to info@valte.com.au. We take complaints very seriously and will respond as soon as practicable after receiving written notice of your complaint.

  8. Changes to Privacy Policy

    1. Please be aware that we may change this Privacy Policy in the future. We may modify this Policy at any time without notice to you, in our sole discretion and all modifications will be effective immediately upon our posting of the modifications on our website. Please check back from time to time to review our Privacy Policy.

  9. Website

    1. When you visit our website
      When you come to our website (VALTE) we may collect certain information such as browser type, IP address, operating system, website visited immediately before coming to our site, etc. This information is used in an aggregated manner to analyse how people use our site, such that we can improve our service and/or for security purposes to help prevent and detect any misuse of, or fraudulent activities involving, this site.
    2. Cookies
      We may from time to time use cookies on our website. Cookies are very small files which a website uses to identify you when you come back to the site and to store details about your use of the site. Cookies are not malicious programs that access or damage your computer. Most web browsers automatically accept cookies but you can choose to reject cookies by changing your browser settings. However, this may prevent you from taking full advantage of our website. Our website may from time to time use cookies to analyses website traffic and help us provide a better website visitor experience, including but not limited to remembering your preferences for using our website, showing relevant notifications to you and/or remembering details of data that you choose to submit to us. In addition, cookies may be used to serve relevant ads to website visitors through third party services such as Google Adwords. These ads may appear on this website or other websites you visit. Any data so collected by Google and/or other third-party services will be used in accordance with their own respective privacy policies. If you would like to adjust or opt out of these advertising settings please refer to the settings pages of the relevant third-party service.
    3. Third party sites
      Our site may from time to time have links to other websites not owned or controlled by us. These links are meant for your convenience only. Links to third party websites do not constitute sponsorship or endorsement or approval of these websites. Please be aware that Real Tenure Pty Ltd is not responsible for the privacy practices of other such websites. We encourage our users to be aware, when they leave our website, to read the privacy statements of each and every website that collects personal identifiable information because this Privacy Policy applies to our website only and the Company assumes no responsibility for the content of any third party websites.

  10. GDPR

    1. The Company welcomes the General Data Protection Regulation (“GDPR”) of the European Union (“EU”) as an important step forward in streamlining data protection globally. Although we do not operate an establishment within the EU and do not target any offering of services towards clients in the EU specifically, we intend to comply with the data handling regime laid out in the GDPR in respect of any personal information of data subjects in the EU that we may obtain.
    2. The requirements of the GDPR are broadly similar to those set out in the Privacy Act and include the following rights:
      1. you are entitled to request details of the information that we hold about you and how we process it. For EU residents, we will provide this information for no fee;
      2. you may also have a right to:
        • have that information rectified or deleted;
        • restrict our processing of that information;
        • stop unauthorised transfers of your personal information to a third party;
        • in some circumstances, have that information transferred to another organisation; and
        • lodge a complaint in relation to our processing of your personal information with a local supervisory authority; and
      3. where we rely upon your consent as our legal basis for collecting and processing your data, you may withdraw that consent at any time.
    3. If you object to the processing of your personal information, or if you have provided your consent to processing and you later choose to withdraw it, we will respect that choice in accordance with our legal obligations. However, please be aware that:
      1. such objection or withdrawal of consent could mean that we are unable to provide our services to you, and could unduly prevent us from legitimately providing our services to other clients subject to appropriate confidentiality protections; and
      2. even after you have chosen to withdraw your consent, we may be able to continue to keep and process your personal information to the extent required or otherwise permitted by law, in particular:
        • to pursue our legitimate interests in a way that might reasonably be expected as part of running our business and which does not materially impact on your rights, freedoms or interests; and
        • in exercising and defending our legal rights and meeting our legal and regulatory obligations.
    4. Data that we collect about you may be stored or otherwise processed by third party services with data centres based outside the EU, such as Google Analytics, Microsoft Azure, Amazon Web Services, Apple, etc and online relationship management tools. We consider that the collection and such processing of this information is necessary to pursue our legitimate interests in a way that might reasonably be expected (eg, to analyse how our clients use our services, develop our services and grow our business) and which does not materially impact your rights, freedom or interests.
    5. The Company requires that all third parties that act as “data processors” for us provide sufficient guarantees and implement appropriate technical and organisational measures to secure your data, only process personal data for specified purposes and have committed themselves to confidentiality.