Privacy Policy

Background

Torn Marketing Pty Ltd ABN 20 625 493 665 (“Torn”, “we”, “us”, “our”) is a marketing company based in Melbourne, Australia. We are committed to protecting your privacy, in accordance with applicable Australian privacy laws. This policy is designed to give you a greater understanding of how we collect, use, disclose, and otherwise handle personal information.

A copy of this Privacy Policy is available on our website at www.torndigital.com, or you can request a copy by contacting our Privacy Officer (details under heading 11 below).

What is Personal Information?

Personal information means information or an opinion, whether true or not and whether recorded in a material form or not, about an individual who is identified or reasonably identifiable. Examples include your name, address, date of birth, and email address.

Our Obligations

We are required to comply with the Australian Privacy Principles (APPs) in the Privacy Act 1988 (Cth) (Privacy Act). The APPs regulate the manner in which personal information is handled throughout its lifecycle, from collection to use and disclosure, security, accessibility, and disposal. We are also required to comply with specific privacy legislation in some circumstances, such as:

  • Applicable State and Territory health privacy legislation (including the Victorian Health Records Act) when we collect and handle health information in the relevant jurisdiction
  • The Spam Act and the Do Not Call Register Act

Employee Records

We are generally exempt from the Privacy Act when we collect and handle employee records, and this Privacy Policy does not apply to that information. However, where State or Territory health privacy legislation applies, we are still required to protect the privacy of employee health information. This Privacy Policy will apply in those circumstances.

Facebook Policy – Data Collected via Meta Platforms

In addition to our general privacy practices, we also handle information collected through Meta (formerly Facebook) platforms, following both Australian privacy laws and Meta’s data handling policies.

What is Platform Data?

“Platform Data” includes information received directly from Meta’s systems and services, such as:

  • Meta user IDs
  • Email addresses
  • Profile pictures
  • API user access tokens and app secrets

We handle Platform Data solely for the purposes outlined in this policy and only as allowed by Meta’s terms and our own privacy practices.

How We Use Platform Data

Torn collects and uses Platform Data to:

  • Provide analytics, insights, and advertising services to our clients
  • Help clients optimise their campaigns and marketing strategies
  • Analyse and report on campaign performance, budgeting, and user engagement
  • Facilitate secure and efficient data management within our business systems

Platform Data is used exclusively for these agency functions and is not shared with third parties except as disclosed in this policy.

Data Processors and Service Providers

To provide the best service to our clients, we may use specific data processors or service providers to assist in managing and storing Platform Data, including:

  • Data Integration Services: We use services such as Airbyte to synchronize data between Meta and our secure databases.
  • Database Management: Platform Data is stored securely for streamlined access and analysis.
  • Internal Data Handling: Access to Platform Data is restricted to authorised personnel responsible for client support, campaign management, and analytics.

Each service provider that assists us is required to adhere to strict confidentiality and data handling standards in compliance with Meta’s data privacy guidelines.

Data Retention and Deletion

Platform Data is retained only as long as necessary to achieve the purposes described in this policy. Once Platform Data is no longer needed, we take steps to securely delete or anonymize it in compliance with Meta’s data retention policies.

Transparency and User Rights

Individuals whose personal data is collected through Meta’s systems can request access to, or the correction of, their data by contacting us at [email protected]. We also provide clear options for users to opt out of direct marketing communications in line with Meta’s transparency guidelines.

Cross-Border Data Transfers

Currently, we do not transfer Platform Data to parties located outside Australia. If this policy changes, we will update our practices to comply with all relevant cross-border data transfer requirements, including those stipulated by Meta’s privacy policies.

Security Measures

To protect Platform Data, we use encryption, firewall protection, and strict access control measures within our systems. All data processing and handling is conducted in compliance with industry standards and Meta’s requirements.

What We Collect

General

The type of personal information that we collect about you depends on the type of dealings you have with us. For example, if you:

  • Are a purchaser or prospective purchaser of a property, we will collect your name, age, address, contact details, details of the property that you are interested in or have agreed to purchase, and other relevant information.
  • Are a supplier to us, we will collect your name, contact details, details about the goods or services you supply, and payment details.
  • Send us an enquiry, complete an enquiry form, or provide us with feedback, we may collect your name, contact details, and information relevant to your inquiry or feedback.

Sensitive Information

Sensitive information is a subset of personal information that is generally afforded a higher level of privacy protection, such as health information. We only collect sensitive information where it is reasonably necessary for our functions or activities.

Collection of Information Other Than Personal Information Through Our Website

When you visit our website, some of the information that is collected about your visit is not personal information, as it does not reveal your identity.

Site Visit Information

We record your server address, date and time of visit, pages visited, documents downloaded, previous site visited, and browser details. This information is used for purposes like statistical analysis and improving our website. We may use this information to locate an individual if unlawful or inappropriate activity is suspected.

Cookies

A cookie is a small string of information that a website transfers to your browser for identification purposes. We only use non-persistent cookies, which are stored in your browser’s memory for the duration of your session. You can adjust your internet browser to reject cookies; however, this may limit website functionality.

Online Behavioural Advertising

We use advertising programs that place cookies on your computer to collect browsing history for customised advertising. You can opt out of these programs anytime.

What If You Don’t Provide Us With Your Personal Information?

We will provide individuals the option of not identifying themselves when dealing with us if it is lawful and practicable. However, in some cases, providing personal information is necessary, such as for entering into a contract.

How We Collect Personal Information

We may collect personal information through:

  • Enquire about or request our service/s or product/s; 
  • Ask to be placed on one of our mailing lists or to receive updates from us; 
  • Apply for a job with us; 
  • Visit one of our Websites or contact us via one of our Websites;  
  • Make a phone call in relation to our Service; or 
  • Become a subscriber to our Service or client of us. 
  • Third parties, including builders, real estate agents, financial service providers, and data brokers.

Importantly, in some circumstances if you do not provide the information that we request, you may not be able to engage with us and we may not be able to provide services to you.  

We may from time to time receive and store certain automatic non-identifiable information relating to your use of, and behaviour on our Website/s. This information is commonly referred to as “clickstream” information. For example, we may record information such as the areas of the Website accessed by you, the time, date and URL of the pages requested by you, your browser software, your IP address, and/or the previous web site that you have linked to the Website from. The recording of such information enables us to identify the areas of our sites that are most popular and to tailor the Website accordingly. 

We may also collect personal information from third party service providers, corporate partners, affiliates, related entities (as defined in the Corporations Act), or from publically available sources. 

Collection Notices

Where we collect personal information, we provide collection notices detailing the purpose of collection and potential disclosures.

Why We Collect Personal Information

The primary purposes of collecting personal information include:

  • Designing, constructing, and delivering developments.
  • Processing transactions (e.g., land or house sales).
  • Promoting products and services, including through direct marketing, events, and advertising.
  • Complying with legal obligations.
  • Conducting research and statistical analysis to improve customer satisfaction and tailor our services to your preferences.
  • Performing business analytics to offer you more relevant products and services.

We may also use your personal information to track the effectiveness of our marketing campaigns, advertisements, and user interactions across our website and other platforms.

We will use your personal information for the reason we collected it and for any other reasonable business purposes in that we may database, store and process information to provide you with the products and services you have requested. 

We will generally use personal information to: 

  1. provide you with the products and services you have requested; 
  1. personalise and customise the advertising, products and services included in the Service; 
  1. manage our business and enhance our products and services; 
  1. future promotional and marketing purposes including direct marketing purposes;  
  1. to inform you of valuable related services, special offers, promotions and competitions; 
  1. contact you on behalf of our corporate partners including to discuss and provide you with valuable related products and services;  
  1. comply with applicable legal and regulatory requirements; and 
  1. any other customer support purposes. 

From time to time, we may provide aggregated statistical information about access patterns, navigational techniques, product sales, etc. to reputable third parties. However, in all instances such information will simply comprise aggregated data, and will not include any personal information that identifies any individual. 

We may sometimes use the personal information we collect for a secondary purpose, that is, for use in a way different from the original reason for collection. We will only do this in the following circumstances: 

  1. Where you have consented; 
  1. Where the secondary purpose is directly related to the primary purpose, and you would reasonably expect us to use or disclose the information in such a way; or 
  1. Where we are permitted or required by law, or it is in the interests of public safety to do so. 

Direct Marketing

We may use your personal information to inform you about our products and services or those of third parties (such as house and land packages), either where we have your express or implied consent, or where we are otherwise permitted by law. This includes the use of cookies to track your online behaviour and display targeted ads.

Opting Out: You can opt out of receiving marketing communications at any time by contacting us (details in Section 11) or using the unsubscribe feature in our electronic communications (e.g., emails or SMS).

Who We May Share Your Personal Information With

We may share your personal information with third parties, such as:

  • Related entities of Torn Marketing Pty Ltd.
  • Vendors, builders, and sales agents.
  • Third-party service providers, such as marketing agencies, IT providers, business analytics consultants, and event organizers.
  • Legal or financial institutions to process payments or comply with regulations.
  • Partners who assist us in advertising or offer relevant promotions based on your preferences.

Cross Border Disclosure of Personal Information

Currently, we do not disclose personal information to overseas parties. Should this change, we will update our Privacy Policy accordingly.

Data Quality and Security

We hold personal information in secure databases, email contact lists, and hard copy documents. We take reasonable steps to ensure the accuracy, security, and destruction of personal information as required by the APPs.

Security Measures

We employ website protection, restricted access to computer systems, and secure storage practices to protect your information.

Online Credit Card Payment Security

We use EFTPOS and online payment processing in compliance with industry security standards.

Website Security

We take reasonable steps to ensure the personal information we collect is accurate, up to date, and secure. Our security measures include:

  • Website protection (e.g., firewalls and antivirus software).
  • Restricted access to personal information.
  • Physical security measures for documents and storage.

While we make every effort to safeguard your personal information, we are not responsible for unauthorized access, disclosure, or use of personal information by third parties beyond our control, including linked websites.

Access and Correction

You can request access or corrections to your personal information by contacting our Privacy Officer. We may charge a fee to cover reasonable costs for providing access. In case of a disagreement, we will provide written reasons and available complaint mechanisms.

Complaints

If you have a complaint about how we handle your personal information, please contact our Privacy Officer. We aim to resolve complaints within one week; more complex complaints may take longer. If you are dissatisfied with our response, you can refer your complaint to the Office of the Australian Information Commissioner.

Our Contact Details

Mail: Privacy Officer, Torn, Level 18, 1 Nicholson Street, East Melbourne, VIC 3002
Email: [email protected]

Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or regulatory requirements. The current version will be posted on our website, and a copy can be obtained by contacting our Privacy Officer. Continued use of our services after any updates will constitute your acceptance of the revised terms.

Disclosure of Personal Information

We do not provide your information to mailing list companies and will not otherwise disclose your personal information without your consent.  

By providing your personal information you consent to us and our related entities (as defined in the Corporations Act) and corporate partners using your personal information to provide you valuable related services. Based on your preference, this includes making contact with you by telephone, mail or email to discuss products and services. You also consent to us and our related entities and corporate partners offering you products and/or services which you may agree to purchase, and this extends to goods or services from us or any third party. We may also send information to you on behalf of our related entities or corporate partners.  

We may share your personal information with our related entities and corporate partners including property, loan or finance professionals who may contact you in relation to assisting you in exploring your property, loan or finance options and may offer you related products and services.  

We may share your personal information with third party suppliers who provide IT, administrative and business support functions and other assistance in relation to the functions as set out in this Privacy Policy.  

We are not however liable for any personal information that you provide directly to our corporate partners including via their websites or over the phone. This personal information will be dealt with in accordance with the individual privacy policy of those partners.  You should check these individual privacy policies before you engage with or supply personal information to our corporate partners. 

We will not allow access from or transfer your personal information to recipients outside of Australia.  

We may disclose personal information: 

  1. Where you have consented; 
  1. Where disclosure is necessary to achieve the purpose for which it was submitted; 
  1. To our affiliates or related entities when it is necessary to provide you with the goods or services you have requested; 
  1. In special situations where we have reason to believe that doing so is necessary to identify, contact or bring legal action against anyone damaging, injuring, or interfering (intentionally or unintentionally) with our Service’s rights or property, users of the Service, or anyone else who could be harmed by such activities; or 
  1. If we are required or authorised by law to disclose the information.