Privacy Policy
This Privacy Policy applies to Deep Blue Company Pty Ltd (ABN 91 614 675 160) (DBC) and its subsidiaries and related bodies corporate, including:
- CCA Digital Pty Ltd (CCA Digital) (ABN 24 629 749 882)
- Conveyancing.com.au Pty Ltd (ABN 68 160 922 387)
- First Class Legal Pty Ltd (ABN 98 164 673 643)
- Rapid Building Inspections Pty Ltd (ABN 75 614 843 131)
- Blue Intellectual Property Pty Ltd (ABN 75 614 320 295)
- Rapid Building Inspections IP Pty Ltd (ABN 52 614 886 038)
- By The Rules Conveyancing Pty Ltd (ABN 98 149 102 554)
- Bytherules Franchising Pty Ltd (ABN 96 618 089 839)
- Bytherules NSW Pty Ltd (ABN 45 646 307 020)
- Think Support Services Inc. (Philippines SEC Regn. No. CS201730586)
(together us, we, our, DBC Group)
DBC Group operates the following websites across desktop, mobile and tablet:
- Deepbluecompany.com.au
- Conveyancing.com.au
- Firstclasslegal.com.au
- Rapidbuildinginspections.com.au
- Bytherules.com.au
collectively known as “Websites” in this Privacy Policy.
We also operate mobile application(s) (App).
We respect your right to privacy and we are committed to safeguarding the confidentiality and security of personal information. We adhere to the Australian Privacy Principles contained in the Privacy Act 1988 (Cth) (Privacy Act). This Privacy Policy sets out how we collect, store, use,
disclose and protect your personal information provided to us via these Websites or by any other means in connection with any product or service we offer.
Personal information is information we hold about you that identifies you, or from which your identity can be reasonably determined.
1. Types of personal information we collect
2. Why we collect your personal information
3. How we collect your personal information
4. Disclosure of your personal information
5. Our marketing and your personal information
6. Security of your personal information
7. Access to your personal information
8. Digital Channels and Cookies
9. Complaints about privacy
10.Changes to this Policy
1. Types of personal information we collect
1.1 We will, from time to time, receive and store personal information that you enter into one or more of our Websites, Apps or external software integrations with our platform, provided to us directly or given to us in other forms. The types of personal information may include your:
- Name
- Age or date of birth
- Contact details
- Residential/business address
- Occupation details
- Property title, ownership, and transfer details
- Bank account and credit card details
- Mortgage and loan application details and other financial information
- Photo ID
- Your device ID, device type, geo-location information, computer and connection information, statistics on page views, traffic to and from the sites, ad data, IP address and standard web log information
2. Why we collect your personal information
2.1 Your personal information enables us to send information, provide updates and process your product or service order including:
- processing and facilitating arrangements for conveyancing, building inspections of various types and any additional products or services requested by you during the conveyancing and home buying process;
- verifying your identity; and
- communicating with you before, during and after conclusion of your conveyancing matter.
2.2 We may also use personal information collected from you to:
- identify and facilitate delivery of products and/or services through our related bodies corporate or business partners or both;
- contact you in relation to our market and consumer research activities, competitions and events, where you have advised us that you would like to participate in these;
- contact you with marketing and promotional materials regarding our offers or promotions, and those of our related entities, partners and other third parties. See section 5 below – our marketing and your personal information – for further detail.
2.3 At other times, we collect your personal information to develop insights about you so that we can better understand your preferences and interests. We do this to personalise your experience, identify products and services that may be of interest to you and enhance the products and services offered by us, our related entities and our business partners. We may also use trusted service providers to undertake the process of developing and analysing these insights.
2.4 You are under no obligation to provide your personal information to us. However, without certain information from you, we may not be able to provide our products and/or services to you.
2.5 We may contact you by a variety of measures including, but not limited to telephone, email, sms or mail.
3. How we collect your personal information
3.1 We collect your personal information when you enter it into one or more of our Websites for the purposes of obtaining a quote or otherwise engaging with us. We also receive and store personal information you enter into one of our Apps or external software integrations with our platform, provided to us directly or given to us in other forms.
3.2 We may collect additional information at other times, including but not limited to, 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, or communicate with our customer support.
3.3 Additionally, we may also collect any other information you provide while interacting with us, including when you interact with us electronically or in person, when you access our Websites, Apps or platform and when we provide our services to you.
3.4 We collect personal information in a variety of ways directly and indirectly from third parties (in some cases for a fee or another benefit). These include our related companies, service providers and other businesses referring you to our services or those of our related companies.
3.5 If we receive personal information about you from a third party without having asked for it we will only continue to hold it if it is personal information that we could have collected from you ourselves in accordance with this Policy. If it is personal information which is not reasonably necessary for our business functions and activities, we will destroy or de-identify it.
3.6 We will protect all personal information, whether collected directly or indirectly, as set out in this Policy.
4. Disclosure of your personal information
4.1 We may disclose your personal information to any of our employees, officers, related companies, insurers, professional advisers, agents, suppliers or subcontractors insofar as reasonably necessary for the purposes set out in this Policy.
4.2 We may also share your information with:
our service providers and other third parties (who may be located overseas) so that they can assist us to provide you with the requested products and services; and an organisation that has an alliance with us to share information for marketing or analytics purposes (and any of its outsourced service providers or agents), to enable them or us to provide you with products or services; and/or to promote a product or service that may be of interest to you (refer to section 5 below for further detail).
4.3 We may receive a referral fee from the third parties to whom we disclose your personal information.
4.4 We will take reasonable steps to ensure that any such third party treats your personal information in accordance with the terms of this Policy.
4.5 We may from time to time need to disclose personal 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.
4.6 We may also use your personal information to protect our copyright, trademarks, legal rights, property or safety and those of our related entities, customers or third parties.
4.7 Information that we collect may from time to time be stored, processed in or transferred between parties located in countries outside of Australia. These may include, but are not limited to the Philippines, United Kingdom, US, NZ and Singapore.
4.8 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 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.
4.9 By providing us with personal information, you consent to the terms of this 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 comply with all relevant privacy obligations regarding handling your personal information. If the third party is located overseas, we will take reasonable steps to ensure that the overseas third party complies with all relevant privacy obligations or is bound by a substantially similar privacy scheme unless you consent to the disclosure or it is otherwise required or permitted by law.
5. Our marketing and your personal information
5.1 We use personal information that we hold about you to identify services and products that may be of interest to you.
5.2 We may contact you by email, text message or other digital service (such as through our applications that you install on your device such as mobile or iPad), phone or post to let you know about our offers and promotions, and those of our business partners; or any new or existing products or services that may be of interest to you pre and/or post conveyancing.
5.3 We also use internet-based marketing including targeted online advertising and online behavioural marketing. We may disclose your personal information to our related entities and business partners to allow them to tell you about a product or service that may be of interest to you, based on your transactions with us. Our marketing agencies may also contact you using your personal information that they already hold, or we may provide your personal information to them, in order to serve you with more relevant advertising about our services and products.
5.4 You can contact us at any time if you no longer wish to receive marketing materials from us, our related entities or business partners that involved the use of your personal information. If you receive a marketing email from us, you can opt-out from that particular category of marketing email by clicking on the “Manage Preferences” link or the “Unsubscribe” link at the bottom of the email, or by managing your subscription on our website.
6. Security of your personal information
6.1 We are committed to ensuring that the information you provide to us is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.
6.2 Given the online nature of our service, we cannot guarantee the security of any information that you transmit to us, or receive from us. Although we take measures to safeguard against unauthorised disclosures of information, we cannot assure you that personal information that we collect will not be intercepted while being transmitted, or disclosed in a manner that is inconsistent with this Policy. Accordingly, the transmission and exchange of information is carried out at your own risk.
7. Access to your personal information
7.1 You are entitled to request details of personal information that we hold about you in accordance with the provisions of the Privacy Act. We will validate the identity of anyone making an access request, to ensure that we do not provide information to anyone who does not have the right to that information.
7.2 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 privacy@deepbluecompany.com.au.
7.3 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.
8. Digital Channels
8.1 When you visit our App or one of our Websites
When you visit our App(s) or any of our Websites (together “Digital Channels”) we may collect certain information such as browser type, operating system, device identifiers (like IP address), location data (where available and not disabled by the user), the time of visit, pages visited, file metadata etc. This information is used in an aggregated manner to analyse how people use our site, such that we can improve our service.
8.2 Cookies
We may from time to time use cookies, pixels and other tracking technologies on our Websites. 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 cookies collect your IP address or MAC address, the city associated with your IP or MAC address, the date and time of your visit to our website, pages or advertisements viewed, the URL of the website that you viewed before visiting our Website and the type of browser you use.
We also use web tracking/analytic tools that generate detailed statistics about traffic to our Websites, traffic sources and how you interact with advertisements on our Websites and third party websites. 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. These tools can also measure and record conversions and sales.
The cookies and web-tracking tools allow our Websites and mobile applications to interact more efficiently with the device you are using and to help us improve the content and functioning of our Websites and mobile applications.
In some cases, third parties may use cookies, pixels and other technologies as part of our Digital Channels. These technologies may be used in connection with activities like surveys, online behavioural advertising, website analytics, and email campaign management. The services we may use from time to time include, but not limited to, those offered by Google (including Analytics, Display Network, AdSense, and DoubleClick), Salesforce Marketing Cloud (Audience Studio and Ad Studio) and other software providers and marketing or direct mail agencies. We encourage you to read the individual privacy policies of those services, including information on how to opt-out of certain functions. You may need to opt out separately from each service. You can contact us to request further details of the services we use. Many of these services operate without collecting or using any Personal Information.
Not all information we collect in relation to our Digital Channels is related to an individual. Quite often the information relates only to a device or is of an aggregated or statistical nature, and we will have no way of determining the identity of the user. In some cases, we may associate information about your use of our Digital Channels over time with your Personal Information, for example, when on any occasion you have logged in, followed a link sent to you by email, or we have otherwise been able to identify you.
8.3 Third party sites
Our site may from time to time have links to other websites not owned or controlled by us. Links to third party websites do not constitute sponsorship or endorsement or approval of these websites. Please be aware that we are not responsible for the privacy practises 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.
9. Complaints about privacy
9.1 If you have any complaints about our privacy practices, please feel free to send in details of your complaints to privacy@deepbluecompany.com.au. We take complaints very seriously and will respond shortly after receiving written notice of your complaint.
10. Changes to this Policy
10.1 Please be aware that we may update this Policy at any time, in our reasonable discretion. All modifications will be effective immediately upon our posting of the modifications on our Websites and App(s). Please check back from time to time to review our Privacy Policy.