Privacy Policy.

Omega Communities takes seriously the privacy of those that visit our web site. We have established this Privacy Policy to communicate what information we collect and how that information is used and safeguarded.

By accessing this website (www.omegacommunities.com.au), you acknowledge the terms and conditions expressed herein. We reserve the right to change this policy at our sole discretion and without notice.

What information is collected, and why?

When a user visits our website, we collect information about the visit that does not identify the user personally. We track information such as the domain from which the user is visiting and the user's browser type. We also collect specific information regarding the user's session on our website. This includes items such as the date and time of the visit and the pages viewed.

Sometimes we ask a user to voluntarily provide personally identifiable information (PII). This information generally includes, but is not limited to, name, e-mail address, postal address, and telephone number. We request this information when the user requests one of the following:

• To register to attend an on-line seminar or demonstration
• To receive specific information from us such as a whitepaper or code sample
• To sign up for a mailing list
• To correspond with us
• Or any other such activity that we deem necessary

Omega Communities does not collect any personally identifiable financial or health-related information. We do not intentionally collect information from children under the age of 13.

How is the information used?

Non-personally identifiable information (non-PII) is collected to allow us to analyze how our website is used and to improve the content and service the website provides.

Personally identifiable information is collected for analysis to improve the content of the website and the services we provide the user.

Omega Communities owns the collected information and will not sell, trade, or rent the information to others. We may use the information to continue contact with the user. This may include contact such as follow-up calls, e-mail correspondence, or mail correspondence to follow-up on the contact or to provide marketing information about promotions, new services, or important website changes. Omega Communities may share this information with its business partners for the specific purpose of a promotion or service offering.

Are "Cookies" used on the website?

"Cookies" are small pieces of information that are placed on a web user's hard drive. We may use cookies to provide you with better service. Cookies are pieces of information that a Web site transfers to your computer's hard disk for record-keeping purposes. Cookies can make the Web more useful by storing information about your preferences for a particular site. The use of cookies is an industry standard, and many major Web sites use them to provide useful features for their customers. Cookies in and of themselves do not personally identify users, although they do identify a user's computer. Most browsers are initially set to accept cookies. If you prefer, you can set your browser to refuse cookies. However, you may not be able to take full advantage of the functionality of the Omega Communities site if you do so.

How is personally identifiable information safeguarded?

Omega Communities utilizes industry standard methods and mechanisms such as firewalls, intrusion monitoring, and passwords to protect electronic information. Multiple physical security methods such as locking devices and 24 hour premise monitoring are also employed. Finally, access to PII is limited to a small number of personnel and on a need-to-know basis.

Links to other web sites

Omega Communities web site may contain links to other internet web sites. Omega Communities neither controls nor endorses external sites and is not responsible for the content of such sites. This policy does not cover the privacy policies and data collection practices of non-Omega Communities web sites.

How to opt out of correspondence

Based on the information a user has provided, Omega Communities may send e-mail correspondence to the user. Each correspondence will contain an easy means to opt out of further correspondence.

General Privacy Policy

This policy, as amended from time to time, relates to the handling of ‘personal information’, which is any information or opinion (whether true or not) about an individual, from which the individual is or could be identified. Organizations are required under the Privacy Act 1988 (Cth) (the Act) to comply with 13 ‘Australian Privacy Principles’. The Omega Communities Pty Ltd (Omega) Privacy Policy is set out below.

1. Collection & Sensitive Information
   

1.1 We only collect personal information that is necessary for one or more of our functions or activities, being the provision of retirement village and support services. The type of personal information Omega collects includes your name, address, contact details and service requirements. We also collect your bank details in order to process direct debit payments for payment for our services. This list of personal information is not exhaustive. We need to collect such personal information to provide our services to you. If you do not agree to provide such personal information, we may not be able to provide our services to you.

1.2 Personal information will be collected by lawful and fair means. We will collect personal information in person, by telephone or correspondence by letter or email.

1.3 We take steps to ensure that you are aware at the time of collection (or as soon as possible afterwards) of the identity of our organization, purpose of collection and possible use and disclosure of the personal information.

1.4 Except as provided below, we do not collect sensitive information without your prior consent. Sensitive information includes information such as racial or ethnic origin, political and religious beliefs, trade union membership, criminal history and health information.

1.5 Where we collect personal information in the course of providing a health service, all of the information is classified as ‘health information’ (which is one type of sensitive information). As far as possible, we seek your prior consent to collect health information about you.

1.6 However, there may also be occasions when we need to collect health information about you from a third party in order to provide our services. If you do not have the capacity to give consent, we will seek the consent of your attorney or a person who is responsible for you.

1.7 For example, we may need to collect health information without your prior consent in some situations, such as in an emergency. If the health information is necessary for us to provide a health service, we may also collect it without prior consent if the law requires. We will comply with rules of professional confidentiality in respect of any such health information we collect without your consent.

1.8 We may also need to collect health information from agencies who refer you to us or from other health service providers. We may also collect health information from your relatives in some circumstances. This type of collection may be necessary for us to provide a health service to you.

1.9 However, to the extent possible, we collect personal information directly from you unless you are not capable of providing the information. If we collect personal information about you from someone else, we take reasonable steps to inform the other person of the purpose of collection (eg send them a copy of our policy statement).

1.10 Where we collect personal information on a form, we will identify the personal information that is required, and the personal information that is optional (if any). Collection forms will contain a reference to this Privacy Policy.

1.11 Applications for employment and information relating to future employment with us are personal information for the purposes of the Act. We will only retain this type of information with your consent. However, we do not require consent to collect this type of personal information, unless it is sensitive information. (Employee records for current and former employees are not personal information for the purposes of the Act.)

1. Use & Disclosure

2.1 In this paragraph 2, ’use’ means use within the organisation and ‘disclosure’ means disclosure outside of the organisation.

2.2 We only use personal information for the primary purpose for which it was collected, being the provision of retirement village and support services, or for a related purpose that is within your reasonable expectations. Where sensitive information is involved (eg health information), we will limit use and disclosure of the information to the primary purpose of collection and directly related purposes.

2.3 We do not disclose your personal information outside of our organisation unless you are aware of, or would expect, such a disclosure and the disclosure is directly related to our primary purpose.

2.4 When using or disclosing personal information, we consider the source of the information – eg how and when it was collected, and what you knew at the time of collection. This will assist us in identifying the purpose of collection, and therefore the permitted use of the information.

2.5 We may disclose your health information to a person who is responsible for you if you cannot consent to a disclosure, and the disclosure is necessary to provide appropriate care, or for compassionate reasons. (Unless you have expressed a wish that the information not be disclosed in this way.) A person who is “responsible” for you includes a parent, child or sibling (over 18 years of age), guardian, attorney etc.

2.6 We will only use personal information to send out marketing material, such as newsletters, if you would reasonably expect us to use the information for that purpose. If we do so, we will give you the opportunity to “opt out” of receiving future communications. For example, we may include a tear-‐off slip that can be returned to us requesting that no further material be sent. If you “opt out” we will not use your personal information to send marketing material again.

2.7 We are obliged to disclose personal information if required under an Australian law or court order, or if reasonably required by an enforcement body (eg the Australia Federal Police).

2.8 Our staff are trained to comply with our obligations under the Privacy Act and this policy.

1. Data Quality

3.1 We take all reasonable steps to ensure that personal information is accurate, complete, up to date and relevant.

3.2 We encourage you to assist us by informing us of any changes to your personal information. For example, we may include a tear-‐off slip on correspondence or mail-‐ outs that can be used to correct or update personal information.

3.3 If we become aware that personal information is incorrect or incomplete, we will ensure that it is corrected immediately.

1. Information Storage and Data Security

4.1 We store all personal information securely. The personal information can only be accessed by authorised members of our staff.

4.2 We take all reasonable steps to protect personal information from unauthorised access, modification, misuse, interference and loss. For example, we use passwords for access to computer records, and keep hard copy files secure.

4.3 The more sensitive the personal information, the more steps we take to protect the information.

4.4 We destroy personal information that is no longer required or we ensure the personal information is de-‐identified. Most records are destroyed after 7 years.

1. Openness

5.1 We will take all reasonable steps to provide this Privacy Policy free of charge.

5.2 A copy of this Privacy Policy is available free of charge at www.omegacommunities.com.au. We will provide you with a hard copy of the Privacy Policy on request.

5.4 On request, we will explain in general the types of personal information we hold, for what purposes, and how we collect, hold, use and disclose the personal information. Please contact our General Manager (details provided below) if you have any queries.

1. Access & Correction

6.1 In general, you are allowed to have access to your personal information held about you. There are some exceptions, for example:

6.1.1 if providing access would pose a serious threat to the life, health or safety of any individual;

6.1.2 if providing access would have an unreasonable impact on the privacy of other individuals;

6.1.3 if the request for access is frivolous or vexatious;

6.1.4 if providing access would reveal a commercially sensitive decision-‐making process; or

6.1.5 if giving access would be unlawful.

6.2 We only accept written requests for access to personal information. Requests are to be directed to our General Manager and will be responded to within 10 business days. The General Manager may require proof of identity before releasing the personal information and in special cases may require a reasonable fee for providing the personal information (for administration costs if the request is voluminous)

6.3 Please direct requests to Omega Communities Pty Ltd on (08) 8334 4095, alternatively, write to: General Manager Omega Communities 17 Tusmore Avenue Leabrook SA 5068

6.4 If you are incapable of requesting access to your personal information, then a person acting on your behalf may request access. This person may be your authorised attorney or some other person who is responsible for you. We take reasonable steps to ensure that the person has the authority to make a request for access.

6.5 We may choose to give supervised access to personal information in some situations. For example, it may be appropriate for a health professional to be present to explain personal information contained in health records.

6.6 If we refuse to give access, we will give written notice setting out the reasons for our refusal and the mechanisms available to complain about the refusal.

6.7 If you gain access to the personal information and can establish that your personal information is incorrect or incomplete, then we will take all reasonable steps to correct the personal information to ensure that the personal information is accurate, up to date, complete, relevant and not misleading. We will do this within a reasonable period of time.

6.8 If we disagree that the personal information is incorrect, then we may refuse to alter the personal information. In this case, we will give written notice setting out the reasons for the refusal and the mechanisms available to complain about the refusal. If requested, we will make a note of the objection on the file.

1. Identifiers

7.1 We do not use government identifiers (such as Medicare numbers) as a substitute identifier for an individual. (We only use Medicare numbers as required in the provision of health services.)

7.2 We will not disclose an individual’s identifier unless required to under Australian law.

1. Anonymity

8.1 If it is practical, we will allow you to remain anonymous, or use a pseudonym, when dealing with us. For example, where you make general inquiries about our organization and its services, you may wish to remain anonymous.

8.2 If we consider that it is not appropriate to allow you to remain anonymous then we will explain the consequences of remaining anonymous. For example, we may not be able to provide a particular service.

8.3 We will also require you to identify yourselves if we are required by law to deal with individuals who are identifiable

1. Unasked for Information

9.1 If we receive personal information that we did not ask for, that we could not have collected ourselves and is not contained in a government record, we will destroy the information (if lawful and reasonable to do so).

1. Trans-‐border Data Flows

10.1 We do not generally disclose personal information overseas. If it is necessary for us to transfer or disclose information overseas, we will take steps to ensure the recipient will apply similar privacy principles.

1. Complaints

11.1 Please direct complaints to Omega Communities Pty Ltd on (08) 8334 4095, alternatively, write to: General Manager Omega Communities 17 Tusmore Avenue Leabrook SA 5068