Last Updated: 17 September 2018
1.1 Examples of Personal Information which you may provide us include, but are not limited to (depending on the nature of your interaction with us): your name, passport number or other identification number, student number, telephone number(s), mailing address, email addresses and any other information relating to you which you have provided us in any form you may have submitted to us (i.e. student accommodation application forms, job application forms, etc.), or in our other forms of interaction with you;
1.2 Certain types of Personal Information are regarded as sensitive information. Examples of sensitive information include information about an individual’s:
Any sensitive information which we collect will either be collected with the individual’s consent or as permitted by law.
2.1 Generally, dwell collects your Personal Information in the following ways:
If you provide Personal Information of a third party (e.g. information of your dependant, spouse, children and/or parents) to us, you represent and warrant that you have obtained the consent of that third party for the collection, use and disclosure of their Personal Information for the purposes set out above.
3.1 In general, dwell may collect, hold, use and disclose your Personal Information for the following purposes:
a. to provide you with products or services;
b. to help manage the delivery of and enhance our products and services, including analysing current customer needs and identifying potential future needs;
c. to update your records in our databases;
d. to monitor and maintain a copy of your record of previous transactions with dwell;
e. to communicate and respond to your queries, requests and complaints;
f. to provide ongoing marketing and publicity information about our products and services and upcoming events which may be of interest to you;
g. to ascertain security clearances and access controls at dwell facilities;
h. for security, surveillance and employee monitoring purposes;
i. to handle disputes and complaints and conduct and facilitate investigations and proceedings when required;
j. to protect and enforce dwell’s contractual and legal rights and obligations;
k. to prevent, detect and investigate crime, and to analyze and manage other commercial risks;
l.to manage the infrastructure and business operations of dwell and to comply with other dwell internal policies and procedures;
m. to facilitate business asset transactions (which may extend to any merger, acquisition or asset sale) involving dwell; and
n. to comply with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant
In addition, dwell may collect, hold, use and disclose your Personal Information for the following purposes, depending on the nature of our relationship with you:
o. If you are a prospective customer or a customer:
p. If you use or download any of our mobile applications (“apps”):
q. If you are a prospective tenant/resident or a tenant/resident:
r. If you are a prospective vendor/contractor or a vendor/contractor:
s. If you submit a job application to us as a candidate for employment:
3.2 In relation to particular products or services or during your interactions with dwell, we may also notify or have specifically notified you of other purposes for which dwell collects, holds, uses or discloses your Personal Information. If so, we will collect, hold, use and disclose your Personal Information for these additional purposes as well, unless we have specifically notified you
3.3 Your Personal Information will be protected and kept confidential, but subject to the provisions of any applicable law, your Personal Information may, depending on the products or services concerned, be disclosed to the following third parties:
3.4 For the purposes of compliance with the APPs, dwell requires that third party organisations which handle or obtain Personal Information, such as service providers to dwell, acknowledge the confidentiality and sensitivity of Personal Information that we disclose to them, undertake to respect any individual’s right to privacy and comply with the Privacy Act. dwell also requires that these organisations use this information only for limited purposes which have been agreed upon and follow dwell’s reasonable directions with respect to this information.
For individuals not in the EU, dwell may send you marketing material which you may choose to “opt-out” of by emailing the DPO. We will not charge you any additional cost or in any way disadvantage you for choosing to “opt-out” of receiving marketing material.
dwell endeavours to ensure that Personal Information stored by us is accurate and up-to-date. dwell also understands that Personal Information may change frequently, such as changes of address and other personal circumstances. As such, dwell encourages you to contact the DPO to update your Personal Information. Incomplete or outdated Personal Information may result in our inability to provide you with products and services you have requested.
6.1 Cookies are small files containing a string of characters that is sent to your computer when you visit any website owned or operated by dwell (“Websites”). Depending on the type of cookies, they may store user preferences and other information.
However, you may not be able to enter certain part(s) of the Websites, and some of the functions and services may not be able to function without cookies. This may also impact your user experience while on our Websites.
8.1 We will safeguard the confidentiality of your Personal Information, whether you interact with us personally, by telephone or mail, over the Internet or through forms of other electronic media. We hold Personal Information in a combination of secure computer storage facilities and paper based files and other records and take steps to protect the Personal Information we hold from misuse, loss, unauthorised access, modification or disclosure. Where we no longer require any Personal Information that we hold, that Personal Information would be destroyed or have particulars or information which may identify individuals removed.
8.2 We may store Personal Information using services provided by us to third parties that are located outside Australia or that use servers that are located outside Australia. This may involve Personal Information that we collect being stored in Singapore.
8.3 All electronic storage and transmission of Personal Information is secured and encrypted with appropriate security technologies.
8.4 Although every reasonable effort has been made to ensure that all Personal Information will be so protected, dwell cannot be responsible for any unauthorised use or misuse of such information and from risks which are inherent in all internet communications. In the event that there is a data breach, dwell will act in accordance with the requirements under the Notifiable Data Breaches scheme in the Privacy Act.
We may disclose your Personal Information to other Related Bodies Corporate of dwell which are located outside of Australia in locations that include United Kingdom, United States of America and Singapore. For the purposes of compliance with the APPs, dwell has arrangements in place to ensure that the overseas Related Bodies Corporate adequately safeguard any Personal Information that dwell discloses to them.
10.1 Please contact the DPO should you wish to have access to, or withdraw the consent to collect and use your Personal Information.
10.2 Your email should identify yourself and state which Personal Information and information about its use and / or disclosure is requested. If you withdraw your consent to any or all purposes and depending on the nature of your request, dwell may not be in a position to continue to provide our products or services to you.
12.2 You have the right to request that we erase your Personal Information. In a number of circumstances (for example, where your Personal Information has been unlawfully processed). We will review your request and will delete your information without undue delay, unless we are legally obligated to process your Personal Information (for example, for the establishment, exercise or defence of legal claims).
12.3 You have the right to obtain a restriction on processing of your Personal Information in a number of circumstances (for example, where you object to the accuracy of the Personal Information held by us, or where we no longer need your Personal Information). If you make such a request, your Personal Information may only be processed in certain limited circumstances (for example, with your consent, or for the establishment, exercise or defence of legal claims).
12.4 You have the right to object at any time to the processing of your Personal Information, including for direct marketing purposes. Upon such a request, we will no longer process your Personal Information, unless we have compelling legitimate grounds for doing so.
12.5 You have the right to request and receive your Personal Information that you have provided to us in a structured, commonly used and machine-readable format. You may also request that your Personal Information you have provided to us be transferred to another entity.
12.6 If you would like to receive marketing material, you may choose to “opt-in” to receive this material by emailing the DPO.
|Business Entity||Title||Contact Number||Email Address|
|Dwell Student Living||Data Protection Officer||+65 6740 firstname.lastname@example.org|