Privacy Policy
How Central Coast Commercial collects, holds, uses and discloses personal information.
1. Scope of this policy
Central Coast Commercial Pty Ltd ("CCC", "we", "us") handles personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles ("APPs"). This policy sets out what personal information we collect, how we hold and use it, to whom we disclose it, and how you may access it, correct it or complain about our handling of it.
CCC is a reporting entity under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth). Section 6E(1A) of the Privacy Act applies that Act to us in respect of personal information handled for those obligations. We apply this policy to all personal information we hold, whether or not the Act requires it.
2. The personal information we collect
The information we collect depends on your dealings with us. It may include:
All enquirers and correspondents
- Name, email address, telephone number and postal address
- The content of your enquiries and correspondence
Property alert subscribers
- Your property requirements, including suburbs, size range, budget, property type and any notes you provide
- Your communication preferences
Vendors, landlords and clients
- Property, title, tenancy and lease particulars
- Bank account details for the disbursement of rent or sale proceeds
- Identity and source-of-funds information required for customer due diligence under the AML/CTF Act
Tenants, applicants and guarantors
- Employment, income, trading and financial information, rental history and references relevant to a commercial tenancy application
- Guarantor particulars where a guarantee is offered
Website visitors
- IP address, device and browser information, pages viewed and referral source
- Technical information processed to keep the website working and to protect it from automated traffic, as described in section 9
We do not seek sensitive information as defined in the Privacy Act. Where sensitive information is provided to us unsolicited, we handle it in accordance with this policy and APP 4.
3. How we collect personal information
We collect personal information directly from you wherever it is reasonable and practicable to do so: through our website and enquiry forms, by telephone, by email, in person at inspections and appointments, and through signed agreements and application forms.
We also collect personal information from third parties, including property portals, referrers, your professional advisers where you have authorised them to deal with us, previous agents, and publicly available registers including ASIC and NSW Land Registry Services.
Where we collect your personal information from a source other than you, we take such steps as are reasonable in the circumstances to notify you of that collection in accordance with APP 5.
4. Why we collect, hold and use personal information
We collect, hold and use personal information for the following purposes:
- Responding to enquiries and providing sales, leasing and property management services
- Sending property alerts matching the requirements you have registered, and marketing communications you have requested
- Preparing appraisals, market analysis and campaign reporting
- Meeting our obligations under the Property and Stock Agents Act 2002 (NSW), the AML/CTF Act and taxation law, including customer due diligence and reporting to AUSTRAC
- Administering, improving and securing our services, systems and website
If you do not provide the personal information we request, we may be unable to act for you, to progress an application, or to provide the services you have asked for. Where information is required by law, including identity verification under the AML/CTF Act, we cannot proceed without it.
5. Disclosure of personal information
We may disclose personal information to:
- Parties to a transaction and their representatives, as necessary to negotiate and complete that transaction
- Professional advisers, including solicitors, conveyancers, accountants, valuers, surveyors and building and pest inspectors
- Trades and contractors engaged in respect of a managed property
- Property portals and marketing platforms where a property is advertised
- Government agencies, regulators, courts and tribunals, and law enforcement, where required or authorised by law, including AUSTRAC, NSW Fair Trading and the Australian Taxation Office
- Our service providers, including technology, communications, accounting and insurance providers
We do not sell personal information, and we do not supply our database to other agencies or to data brokers.
6. Artificial intelligence
We use artificial intelligence tools as part of the systems we use to deliver our services. Their use is limited to supporting our staff, and personal information we hold may be processed by those tools for the following purposes:
- Interpreting enquiries and property requirements, and matching them to available listings
- Organising, summarising and searching documents and correspondence
- Preparing internal drafts and working material for review by a member of our staff
Our position on that processing is as follows:
- No provider we use trains its models on the information we send. Our arrangements with our providers prohibit the use of our content for model training.
- We minimise what is sent. Personal information is provided to these tools only to the extent the task requires it.
- Processing may occur outside Australia. See section 7.
- No price, rent, appraisal or market figure we give you is generated by artificial intelligence. All such figures are prepared by a licensed agent from comparable sales and leases.
- No decision about you is made by artificial intelligence. Decisions affecting you are made by a person, who is accountable for them.
- No communication is sent to you because an artificial intelligence system determined that it should be sent. Property alerts are generated against the requirements you have registered; their content and the decision to contact you remain ours.
You may ask us to handle your matter without the use of these tools, and to have any outcome reviewed manually, at no cost and without giving a reason. Contact us on 02 4322 7000 or info@cccommercial.com.au.
Further information is set out in our AI Transparency Statement.
7. Disclosure outside Australia
Our records are hosted on infrastructure located in Australia.
Certain of our service providers are located overseas, and our use of those providers involves disclosing personal information outside Australia:
| Category of recipient | Location | Information disclosed |
|---|---|---|
| Artificial intelligence and model hosting providers | United States | Information processed for the purposes described in section 6 |
| Email delivery providers | United States | Your name, email address and the content of communications sent to you |
| Website security and infrastructure providers | United States | IP address and technical request information, processed to protect the website from automated traffic and to produce aggregate visitor statistics (section 9) |
We take such steps as are reasonable in the circumstances to ensure that overseas recipients handle personal information in a manner consistent with the APPs. We remain accountable to you under section 16C of the Privacy Act for the acts of an overseas recipient that would breach the APPs. We do not control the laws of the jurisdictions in which those recipients operate.
8. Direct marketing
We send property alerts and marketing communications only to those who have requested them.
Every marketing communication identifies CCC as the sender and contains a functioning unsubscribe facility, as required by the Spam Act 2003 (Cth). You may change your preferences at any time from the link in every message we send, or by telephoning 02 4322 7000.
Unsubscribing from marketing does not affect operational communications we are required to send you, including correspondence concerning a lease you hold or a property we manage.
9. Cookies and similar technologies
We do not use analytics cookies, advertising cookies or tracking pixels on this website. We do not track your browsing across other websites, we do not operate advertising retargeting, and we do not sell or disclose information about your browsing activity.
The technologies we use are limited to the following:
- Security and bot protection. Our website is protected by Cloudflare, which processes technical request information, including your IP address, in order to distinguish genuine visitors from automated traffic. Our enquiry and alert forms use Cloudflare Turnstile for the same purpose.
- Site functionality. Where you log in to an alerts or preferences account, a session cookie maintains that login. A small amount of information is stored in your browser to keep the site working correctly as you navigate it, and it remains in your browser.
- Visitor statistics. We use Cloudflare Web Analytics to count visits to this website in aggregate: which pages are viewed, the website that referred the visit, and the general type of device, browser and country. It sets no cookies and stores nothing in your browser, and we do not use it to identify you or to follow you across other websites. Browser settings or extensions that block third-party scripts will also stop it.
- Advertising measurement. When you arrive from a Facebook or Instagram ad and send us an enquiry, we tell Meta that an enquiry was made, using only the ad click identifier in the link you followed. We do not send Meta your name, email, phone or any other details. This helps us see which ads work.
Because we set no analytics or advertising cookies, there is nothing on this site to consent to or to opt out of beyond the technologies described above. The functional and security technologies cannot be disabled without preventing the website from working. All major browsers allow cookies and site data to be blocked or deleted if you wish.
Where information collected in this way identifies you, it is personal information and is handled in accordance with this policy.
10. Security and retention
We hold personal information in our own property management system, hosted on infrastructure in Australia with access restricted to CCC staff on individual accounts. Physical records are held securely at our West Gosford office. We take reasonable steps to protect personal information from misuse, interference, loss, and unauthorised access, modification or disclosure.
We retain personal information for as long as it is required for the purposes described in this policy and for as long as the law requires, including:
- AML/CTF records: seven years from the end of the customer relationship or the transaction, as required by the AML/CTF Act
- Agency records: three years under the Property and Stock Agents Act 2002 (NSW), and longer where a trust account or a dispute is involved
- Alert subscribers: until you unsubscribe, following which we retain a suppression record so that we do not contact you again
Where we no longer require personal information and are not required to retain it, we destroy it or ensure it is de-identified.
Where a data breach occurs that is likely to result in serious harm, we will notify affected individuals and the Office of the Australian Information Commissioner in accordance with the Notifiable Data Breaches scheme.
11. Access and correction
You may request access to the personal information we hold about you, and request its correction. Contact us on 02 4322 7000 or info@cccommercial.com.au.
We will respond within 30 days. No fee is charged for making a request. Where we refuse access or correction, we will give you written reasons and information about how to complain.
Alert subscribers may view and amend their own requirements at any time from their preferences page.
12. Complaints
If you believe we have mishandled your personal information, please contact us first. Write to the Director, Central Coast Commercial Pty Ltd, 4/4 Stockyard Place, West Gosford NSW 2250, or email info@cccommercial.com.au.
We will acknowledge your complaint within 5 business days and provide a written response within 30 days.
If you are not satisfied with our response, you may complain to the Office of the Australian Information Commissioner:
- oaic.gov.au
- 1300 363 992
- GPO Box 5218, Sydney NSW 2001
13. Changes to this policy
We review this policy at least annually. The current version is available at cccommercial.com.au/privacy-policy. Material changes will be notified to alert subscribers by email.
