This website and our associated products and services (Services) are provided by IC4 Pty Ltd ACN 164 841 398 as trustee for IC4 Development Trust trading as Small is the New Big (us, we our).
By providing us with information, to the extent we are required to obtain consent, you consent to our use of that information in accordance with this Policy.
What information do we collect and hold?
We may collect and hold a variety of information from you when you use our Services. This may include information which can be used to personally identify you (Personal Information). Some types of Personal Information we may collect, depending on your use of our Services, includes your:
- age and date of birth;
- e-mail address;
- street and postal address;
- telephone number and other contact details;
- credit card details; and
- bank account details.
We may also collect and hold other information about your interaction with our Services, which may or may not include Personal Information, such as:
- data which provides descriptive, technical, statistical and other metadata type information regarding your use of our Services;
- details of your financial position and business situation;
- feedback about the progress or outcomes of our Services, such as our buyers agency service or property training courses,
- purchase and enquiry history with us;
- photographs of your property for testimonials and marketing (e.g. before/after renovation comparisons); and
- any other information you disclose to us through interacting with our Services, our support team, message boards, social media pages, online materials and courses, surveys, promotional offers, reviews or otherwise.
It is optional for you to provide us with Personal Information, in some circumstances you may even choose to not identify yourself or provide a pseudonym. However, we may not be able to provide some or all of our Services to you without certain Personal Information.
How do we collect Personal Information?
How we collect and store your Personal Information depends on which Services you use and how you choose to interact with them. We generally collect Personal Information directly from you in the following ways:
- through your use of our Services (e.g. attending our seminars or online events, participating in our courses);
- through communications between you and our representatives or support team (e.g. in person, via phone, video conference or interacting with us via our social media pages or website);
- whenever you create an account with us via our website;
- whenever you make purchases through us;
- whenever you participate in our promotional offers, surveys or complete our online forms; and
- whenever you provide us with feedback or any other information or documentation about our Services.
We may also collect your Personal Information from third parties such as:
- social media sites where you have connected your account with our Services or where you have visited our social media pages such as those on Twitter and Facebook;
- any third party who you have authorised to liaise with us in relation to our Services (e.g. your spouse, lawyer, accountant, builder, property agent).
How do we hold Personal Information?
We take the security and confidentiality of your Personal Information very seriously.
Any Personal Information held by us is securely stored on our business premises in Australia on physical hard drives and/or stored digitally on the cloud via our third party cloud computing service providers and software as a service providers.
Stored Personal Information about you may be combined or linked with any other information about you that we hold about you, including any information we receive from third parties.
We have taken all reasonable steps, including implementing a number of industry standard security systems and protocols, to prevent any misuse, loss, interference, modification or unauthorised access or disclosure of Personal Information held by us or our data processors. While we have implemented these safeguards, we cannot guarantee that your Personal Information will be 100% safe from disclosure in a manner which is inconsistent with this Policy. To the extent permitted by law, any provision of information to us by you is done so solely at your own risk.
We will only retain your Personal Information for as long as necessary to fulfil the purpose/s for which the Personal Information was obtained or, as applicable, for any other purpose you have consented to or for our legitimate business purposes as outlined in the section below.
We may however retain your Personal Information for a period longer than above where necessary for us to fulfil any legal obligation or in order to protect the vital interests of yourself or another person.
What do we use Personal Information for?
We will never share, sell or rent your Personal Information to third parties other than as disclosed in this Policy.
We collect, hold, use and disclose Personal Information and other information for the following legitimate business purposes:
- to assess your identity and eligibility to be in receipt of our Services;
- to provide our Services;
- to provide you with updates on our Services;
- to arrange for our Services to be provided or received by you, as applicable (for example, your Personal Information may be received by our chosen postal service or obtained by conference centre staff in relation to organising our Property Training Courses);
- to provide to any real estate agents in assisting you with the purchase of a property (if relevant to the Services we are providing to you);
- to provide you with news and information on promotional offers or competitions, upcoming events and products and services offered by us;
- to provide support and communicate to you as our customer;
- to manage any accounts you have with us;
- to assess the performance of persons providing the Services;
- to promote our Services to you;
- to investigate any complaint or issue arising in connection with the Services;
- to process payments, transactions and delivery of orders to you;
- to collect and pay any amount on your behalf or to make a payment to you;
- to provide information to construction industry and property professionals in order for those entities to assist us with the provision of our Services (e.g. if you sign up for our property renovation services);
- for us and our industry partners to identify if any referral fee is payable in relation to you becoming a customer of ours or our industry partners;
- to assist our customer support team in providing the Services;
- to provide to our professional advisers, such as our solicitors, insurers or accountants, for the purpose of obtaining advice or acting on our behalf in relation to a matter;
- to display content and/or advertising that is relevant to you via the Services;
- for our internal business purposes, such as marketing, planning, research and business maintenance;
- to develop and display testimonials from you about our Services on our website or at our events;
- to audio and or video record any meetings we have with you as part of our Services (e.g. development coaching sessions);
- to process a payment to or from you;
- to maintain our customer and mailing list database;
- to investigate any complaint made by or against you or to investigate any unlawful or improper use of our Services;
- to obtain an overview of how you use our Services;
- if we elect to, to intervene in and resolve disputes between you or us and another person;
- as part of a transfer of our assets should we propose or proceed to sell, merge or otherwise alter ownership or control of our business;
- to initiate or respond to a claim or other legal action;
- to monitor and improve the Services;
- to exercise or defend our rights, including disclosing information to credit reporting agencies, courts, tribunals and other regulatory agencies; and
- as permitted or required by law (e.g. to comply with a court order or regulation).
Some of these purposes may or may not apply to you, depending on how you use our Services.
To the extent necessary to carry out the above purposes, some of the third parties we may disclose your Personal Information to include:
- our employees and officers;
- entities affiliated with or related to us (e.g. other entities controlled by or related to our directors and/or shareholders);
- software, IT, marketing tool, social media platforms and cloud computing service providers;
- payment processors;
- off-site data storage service providers;
- postal service providers;
- professional industry agencies and governing bodies (e.g. Housing Industry Association);
- our construction and property industry partners (e.g. builders, plumbers, electricians, insurance specialists, staging and furnishing specialists, photographers, real estate agents);
- our lawyers, accountants, insurers and other professional advisers;
- persons we contract to assist in providing our educational Services (e.g. development coaches, conference facility providers);
- government agencies (e.g. police).
If your Personal Information is required or intended to be disclosed for any purpose other than as is disclosed in this Policy, we will seek your consent prior to doing so.
If you are an European Economic Area (EEA) resident, please note that we process your Personal Information to the extent necessary to carry out our legitimate business purposes and interests as listed above or otherwise, unless we are required by law to obtain your consent to process your Personal Information in a specific way, in which case we will rely on any consent obtained from you in order to carry out that processing. Depending on how you use our Services, processing of your Personal Information may also be necessary in order for us to fulfil contractual obligations to you (such as where you have placed an order with us, require written advice from us or require input from a third party), and we will rely on this as the basis for carrying out that processing. We may also process your Personal Information in order to comply with a legal obligation, protect your vital interests, or as may be required of us for the public good.
When Personal Information is disclosed by us to any third parties as listed above, Personal Information will only be disclosed to that party to the extent necessary for the disclosure purpose identified in the list above to be carried out by that party.
Where we determine it is commercially viable to do so, we will attempt to carry out any of the above listed purposes without using Personal Information or by de-identifying Personal Information first, so that an individual cannot be recognised by that information.
Except where retention is required by law, we will take reasonable steps to de-identify or destroy any Personal Information where it is no longer needed for the purposes provided for in this policy.
Other Information & Third Parties
Whilst you are using our Services, we, our advertisers, business partners and other third parties may also collect and hold other non-personal information by using cookies or other technologies. Cookies allow tracking and storage of information about your use of the internet and our Services either directly or through third parties, such as Google Analytics, Facebook Business Platform & customer messaging platform(s).
Cookies are used by us for various reasons including to:
- store your username and password for any account you hold with us on a device so you do not have to re-enter it;
- generate statistical information and reports about your use of the internet and our Services;
- to understand your interests, demographic and location details to provide you with a more customised experience when using our Services;
- to personalise advertising to suit your interests and prevent the same advertisement appearing to you repeatedly; and
- to combine information about your usage patterns with similar information obtained from other users to help enhance our Services (e.g. to learn which pages are visited most or what features are most attractive).
Comments, promotional offers, blogs, advice, opinions or any other content or website that is created or hosted by a third party, but is accessed by you via our Services (through embedding, hyperlink or otherwise), may be subject to that third party’s own privacy and data collection policies and practices which may vary from our own.
If you voluntarily disclose Personal Information via a publicly accessible feature of our Services (such as leaving a testimonial), you do so at your own risk, as this information may be publicly available around the world and third parties may access and use this Personal Information to send you unsolicited material or otherwise use your Personal Information in a manner we cannot control.
You may interact with third parties in connection with our Services. Any services or content provided by a third party may be subject to that party’s own privacy and data collection policies and practices which may vary from our own.
Please do not provide us with Personal Information of a third party unless requested by us. If you provide us with Personal Information about a third party, you warrant that you have the consent of that third party to provide that Personal Information.
We may use automated decision making or profiling technologies from time to time. This is to allow us to show you content or marketing which is more personalised. If you are an EEA resident, please note that these technologies will not be used in a way that would have a significant effect on you, unless such use is necessary to fulfil a contractual obligation we have to you, your consent to such use has been obtained or we are required to use those technologies in that manner by law.
International Disclosure of Personal Information
Whilst our offices are located in Australia, some of our third party service providers (such as our cloud data storage hosts) are based internationally. Accordingly, we may disclose your Personal Information outside of Australia and outside of the EEA for any of the purposes identified in this Policy.
We take reasonable steps to ensure that overseas recipients handle your Personal Information in accordance with our Policy. Specifically, if you are an EEA resident, we ensure that the transfer of your Personal Information to any country outside of the EEA will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission, a copy of which can be obtained from the European Commission website, by ensuring the recipient has adopted binding corporate rules or ensuring that the recipient provides an appropriate level of data protection based on an adequacy decision of the European Commission.
Accessing, updating and deleting your Personal Information
You have a right to request access to and seek correction of any Personal Information we hold about you, such as information which you believe is incorrect, incomplete, outdated, misleading or irrelevant. You may also request additional information from us regarding the purposes for which we process your Personal Information and the types of third parties to whom we disclose your Personal Information. You may access and amend your Personal Information by sending us an email via the contact details provided at the end of this Policy.
If you are an EEA resident, in addition to the above, you have the following rights in relation to your Personal Information:
- the right to withdraw consent or ‘opt out’ from us processing your Personal Information (the lawfulness of processing prior to the withdrawal of consent will not be affected);
- the right to have us delete your Personal Information from our database without undue delay if you withdraw your consent (where our use was based on consent) or the information is no longer required for the purpose/s for which it was obtained;
- the right to restrict how we process your Personal Information, such as where the information is inaccurate or the use is unlawful;
- the right to receive access to your Personal Information as held by us, in a form that is accessible and commonly used; and
- the right to object to the processing of your Personal Information in a particular way (including direct marketing purposes, profiling or automated decision making for direct marketing purposes).
The above is a summary of your rights only, for example, some rights may only be exercisable in certain circumstances or our obligation to fulfil your request may be subject to certain exemptions. You should make your own enquiries into the full extent of your rights at law.
If you wish to exercise any of the above rights in relation to your Personal Information, you can make this request via the email or postal contact details at the end of this Policy. Where applicable to you, some of the above rights, such as to ‘opt out’ of further emails from us or to delete the Personal Information held by us can be carried out by deleting your account with us or clicking the ‘unsubscribe’ link at the bottom of an email from us.
If you have complaints, comments or concerns regarding the Act or this Policy, please first contact us directly via the details at the end of this Policy. We will endeavour to get back to you as soon as possible, but we ask that you allow us up to 30 days to respond before taking any other action. We will investigate your complaint in a timely manner and advise you of the outcome of our investigation, including what steps, if any, we propose to take to handle or remedy your complaint.
If you are an EEA resident, despite the above, you have the right to complain directly to a supervisory authority which is responsible for data protection at any time.
For any queries relating to this Policy, please contact:
If you live within Australia or outside of the European Economic Area:
IC4 Pty Ltd as trustee for IC4 Development Trust
PO Box 1584
Buderim QLD 4556
+61 (07) 5450 8334
If you live within the European Economic Area
Please use our Contact Us form.
We may update this Policy from time to time; the most current version of this Policy will always apply. We may notify you of updates to this Policy by email or our Services from time to time.
Last updated: November 2020