1. Background

This Privacy Policy relates to:

  • Airlie House Developments Pty Ltd ACN 126 880 171 as trustee for Airlie House Development Trust ABN 14 922 870 780;
  • Asian Pacific Building Corporation Pty Ltd ACN 053 997 989;
  • Asian Pacific Group Pty Ltd ACN 147 287 769;
  • Asian Pacific Group Holdings Pty Ltd ACN 606 662 266;
  • Asian Pacific Property Management Pty Ltd ACN 055 530 302 as trustee for the WHD Family Trust ABN 11 384 712 064;
  • Asian Pacific Serviced Offices Pty Ltd ACN 068 012 653;
  • Buffalo Valley Pty Ltd ACN 626 498 904;
  • Chapel Street Developments Pty Ltd ACN 121 132 536 as trustee for The Chapel Street Trust ABN 97 387 578 359;
  • Deague Capital Pty Ltd ACN 637 888 281;
  • Kings Technology Park Pty Ltd ACN 095 090 592 as trustee for the Kings Technology Park Trust;
  • Melbourne Commercial Office Sales and Leasing Pty Ltd ACN 088 643 181;
  • Office Search Pty Ltd ACN 159 149 532 as trustee for Central House Toorak Trust ABN 46 905 830 365;
  • Deague Group Holdings No 7 Pty Ltd ACN 606 348 083 as trustee for The Johnson Hotel Trust ABN 86 475 076 373;
  • Ovens River Pty Ltd ACN 138 132 797 as trustee for The Ovens River Trust ABN 17 264 284 309;
  • The Schaller Studio Pty Ltd ACN 123 696 319 as trustee for The Schaller Studio Trust ABN 38 321 953 228; and
  • Walkerville Developments Pty Ltd ACN 141 226 477 as trustee for Walkerville Developments Trust ABN 44 541 848 464,

and each of their related entities (collectively, the Deague Group, and referred to in this Privacy Policy as “we”, “us”, “our”, “Deague Group” or “DG”).

We are committed to complying with applicable privacy laws in relation to the personal information that we collect in the course of running our business.

This Privacy Policy explains how we will collect and treat your personal information that you provide to us, and your rights in relation to any of your personal information that we hold about you. We review our Privacy Policy regularly to ensure it is up-to-date so we encourage you to review it from time to time on our websites located at https://www.deaguegroup.com.au/, https://www.mco.com.au/, https://apso.com.au/, https://kingsclub.com.au/, https://brightvalley.com.au/,

https://www.centralhouse.com.au/, https://melbselfstorage.com.au/, https://kingsbusinesspark.com.au/, https://www.spacefilmlocations.com.au/, https://www.venue-hire.net.au/, https://www.collinsstreettower.com.au/, https://www.melbcarstorage.com.au/ and https://www.stkildardtowers.com.au/ (collectively, our Websites). Alternatively, if you would like a copy sent to you, please request it by contacting our Privacy Officer (see contact details in section 14 below) and we will provide you a copy free of charge.

We may, in connection with particular services we offer or provide to you, make other privacy disclosures to you or seek your authority to use your personal information in ways which are different from or more specific than those stated in this Privacy Policy. In the event of any inconsistency between the provisions of this Privacy Policy and those other disclosures, the other disclosures will apply.

Where applicable privacy laws provide for exceptions or exemptions, we may rely on those exceptions or exemptions in our information handling practices. This Privacy Policy (other than section 9) explains how we manage personal information about individuals other than employees. Section 9 explains the position of employees.

2. Key Definitions

In this document:

  • “APPs” means the Australian Privacy Principles set out in the Privacy Act;
  • “personal information” has the meaning set out in the Privacy Act, and (in summary) means information or an opinion about an identified individual or an individual who is reasonably identifiable, whether true or otherwise;
  • “Privacy Act” means the Privacy Act 1988 (Cth); and
  • “sensitive information” has the meaning set out in the Privacy Act, and includes certain specific types of personal information such as health information, and information about a person’s racial or ethnic origin, sexual orientation or practices, criminal record, religious beliefs or affiliations, political opinions, membership of a political, professional or trade association, and biometric and genetic information.

3. Open and Transparent Management

DG takes its obligations under the Privacy Act and the APPs very seriously and has implemented practices, procedures and systems to ensure we comply with those laws. DG is committed to maintaining the confidentiality and security of your personal information and managing it in an open and transparent way.

4. Collection of Personal Information

Our preference is to collect personal information from you directly and we will endeavour to do this unless it is unreasonable or impractical to do so. We collect personal information in a variety of ways including via online enquiries you submit on our websites, over the telephone, through correspondence (whether by letter, fax or email), and on our forms when you enter into agreements and contracts with us. We may also collect personal information from third parties including from credit reporting bodies, contractors, business partners and other DG entities.

4.1   Types of Information Collected

The types of personal information we collect about you depends on the circumstances in which the information is collected.

In the process of conducting our businesses, we collect a broad range of personal information about our current and prospective customers and tenants, contractors, suppliers, real estate agents, service providers, investors and other business associates and the people associated with the businesses we deal with. This information can include such things as your name, contact details (such as your phone number(s) and email and mailing addresses), financial information (including bank account details), identification and transaction history information, personal references and supporting documentation.

If we need to confirm your identity (including where required so that we can comply with obligations under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth)), we may collect details of identification documents (including government identifiers such as passport number, driver’s licence number) and such other personal information reasonably required to verify your identity and to comply with such laws.

If you are an individual contractor to us or apply for a role with us, we may also collect information relevant to your engagement with us including qualifications, length of engagement, resume, current and former employment details, pay rate and salary, bank details, feedback from supervisors, training records and logs of your usage of our equipment (e.g. phones, computers and vehicles).

If you access our Websites or if you download and access any of our apps, we may:

  • utilise cookies to collect additional information about your use of our Websites and apps, such as your internet protocol (IP) address, device information, browser information, and details on your usage. Please see the cookies section below for further details; and
  • if you have provided us with permission to access your device location when using our Websites or app, we may collect information about your geographical location.

If you call us via telephone, we may monitor and in some cases record such telephone conversations for staff training, quality assurance and record-keeping purposes.

If you attend a premises we operate or manage, we may:

  • collect certain contact details that you provide to us (which may be via digital check-in apps), including the date and time of attendance, including so that we can comply with applicable laws (such as public health directives). If we collect such information to comply with a particular law, we will only use and disclose it in accordance with applicable laws; and
  • record your image and/or voice through the use of Closed-Circuit Television (CCTV) systems for the purposes of managing security of the premises and health and safety of occupants and the public generally.

We only collect sensitive information about you with your consent, or otherwise in accordance with the Privacy Act. The main types of sensitive information we may collect are criminal record as part of background police checks on prospective tenants and staff.

If you do provide sensitive information to us for any reason (for example, if you provide us with information about a health condition, injury or disability you have), you consent to us collecting that information and to us using and disclosing that information for the purpose for which you disclosed it to us and as permitted by the Privacy Act and other relevant laws.

In addition to the types of personal information identified above, we may collect personal information as otherwise permitted or required by law.

Where you do not wish to provide us with your personal information, we may not be able to provide you with requested services and/or certain functionality of our Websites and apps.

4.2    How we collect personal information

Our preference is to collect personal information from you directly and we will endeavour to do this unless it is unreasonable or impractical to do so. We collect personal information in a variety of ways including via online enquiries you submit on our Websites, over the telephone, through correspondence (whether by letter, fax or email), when you apply for a role with us, through any mobile applications provided by our organisation, while conducting customer satisfaction and market research surveys, and on our forms when you apply for or enter into agreements and contracts with us.

In certain cases, we may collect personal information from publicly available sources and third parties, including from credit reporting bodies, referrers, suppliers, contractors, booking platforms, your employers, referees, lawyers/conveyances, our business partners, other DG entities, recruitment agencies, government bodies (e.g. police checks, if required), academic and professional bodies (e.g. to validate details and currency of qualifications).

If we collect personal information about you from a third party we will, where appropriate, request that the third party inform you that we are holding such information, how we will use and disclose it, and that you may contact us to gain access to and correct and update the information.

4.3     Cookies

“Cookies” are small files that are transferred to your computer’s hard drive through your web browser and enable our sites to recognise your browser and remember certain information to assist in improving your online experience. Cookies may collect and store personal information about you. This information will help to better adapt our Websites to suit personal requirements. While cookies allow a computer to be identified, they do not permit any reference to a specific individual. For information on cookie settings of your internet browser, please refer to your browser’s manual.

We may use third party vendors to show our ads on sites on the Internet and serve these ads based on a user’s prior visits to our Websites and other internet activity. We may also use analytics data supplied by these vendors to inform and optimise our ad campaigns based on your prior visits to our Websites.

From time to time we may disclose your personal information, including your credit information to third party entities, which may include credit reporting bodies or collection agencies for credit management purposes or other purposes as required by law.

 

5. Use or disclosure of personal information

5.1   Why do we collect, hold, use or disclose personal information?

As a general rule, we only process personal information for purposes that would be considered relevant and reasonable in the circumstances. The purposes for which we use and disclose your personal information will depend on the circumstances in which we collect it. Whenever practical we endeavour to inform you why we are collecting your personal information, how we intend to use that information and to whom we intend to disclose it at the time we collect your personal information.

We may use or disclose your personal information:

  • for the purposes for which we collected it (and related purposes which would be reasonably expected by you);
  • for other purposes to which you have consented; and
  • as otherwise authorised or required by law.

We collect, hold, use and disclose your information for the primary purpose of enabling us to carry out our business functions and activities which includes but is not limited to:

  • the provision of products or services to you (including the improvement of those products or services);
  • verifying your identity;
  • conducting checks and searches of your credit information to assess your credit rating from time to time;
  • communicating with you, including via email, mail or telephone;
  • personalising and customising your experience;
  • managing and enhancing our products and services;
  • promoting and marketing our products and services including updating you with news and information about our existing and new products and services;
  • providing you with information about events, products or services that may interest you;
  • managing our relationship with you;
  • facilitating our internal business operations;
  • considering you for a job (where as an employee or contractor) or other relationships with us;
  • receiving goods or services from you;
  • providing you with tax invoices for our services;
  • operating, monitoring, developing and improving our Websites, apps and services;
  • optimising and customising the user experience on our Websites, apps and services;
  • protecting the security, health and safety of our premises, facilities, personnel and visitors;
  • where a business seeks to purchase our products or services on credit, we may seek commercial credit reports that may include limited personal information about officeholders;
  • investigating any complaints made by you; or
  • as required or permitted by law.

5.2   Sharing your information within Deague Group (DG)

Sometimes you may provide your information directly to one DG entity and that information is shared with other DG entities. This typically occurs when you acquire services from more than one DG entity. If we share your personal information with another DG entity, that entity will treat your information in the same way that we are required to treat it under the Privacy Act and this policy.

5.3   Disclosure to third parties

From time to time we may disclose your personal information to third parties in connection with the purposes described in section 5.1 of this Privacy Policy, including the following types of third parties:

  • our suppliers, contractors and organisations that provide us with technical and support services or who manage some of our business functions (including providers of IT, virtual office and marketing services);
  • our related entities (who may use and disclose the information in the same manner we can);
  • where the relevant DG entity is part of or conducts business via a joint venture, to the relevant joint venture entities;
  • our accountants, insurers, real estate agents, financiers, lawyers, auditors and other professional advisers;
  • credit reporting bodies or collection agencies for credit management purposes or other purposes as required by law;
  • debt collection agencies;
  • any third parties to whom you have directed or permitted us to disclose your personal information (e.g. referees, owners’ corporations, government authorities); and
  • in the unlikely event that we or our assets may be acquired or considered for acquisition by a third party, that third party and its advisors.

We may also disclose your personal information in accordance with any consent you give or where disclosure is authorised, compelled or permitted by law.

If we disclose information to a third party who is handling it on our behalf, we generally require that the third party protect your information to the same extent that we do.

If you post information to certain public parts of our Websites or to our social media pages, you acknowledge that such information may be available to be viewed by the public. You should use discretion in deciding what information you upload to such sites.

 

6. Use of automated decision making tools, AI and other technologies

6.1  Automated decision making

We utilise online recruitment tools to assist us in screening applications for employment including deciding whether or not we may offer applicants an interview or employment. See the Schedule to this Privacy Policy for details of the providers / tools we utilise for employment screening.

The tools we use assess a candidate’s application for employment against certain questions and assessment criteria we have set. The tools may automatically reject applications that do not meet certain criteria. As part of this process, the automated tools analyse various kinds of personal information provided during the application process, such as details of the applicant’s qualifications and experience and responses to questions relating to the specific role.

6.2  AI and other technologies

Like most organisations, we use a variety of technology services to operate our business, provide our products and services and perform our other functions and activities. Many of these technology services are provided and operated by third party service providers.

In some cases, we use these technology services to collect information from or about you. For example:

  • we may use social media platforms such as to keep in contact with the community (see section 16 of this Privacy Policy);
  • we may use third party services to conduct our surveys; and
  • when you visit our websites, we may use cookies, web analytics and other similar technologies to collect information about how you interact with our website (see section 4.3 of this Privacy Policy).

The information that we collect via these third party technology services is used for the purposes explained in this Privacy Policy.

We also use third party technology services to provide functionality that we make available to you as part of our products or services or to assist us in operating our business. These include service providers who provide us with technical services, such as cloud hosting and storage, analytics and monitoring, payment processing and billing and customer support and communications.

Our third party technology service providers have their own privacy policies, which explain how they handle and process personal information or other data that is collected by their services.

The Schedule to this Privacy Policy lists some of the key third party technology services that we use in our business, and which may be involved in processing your personal information (depending on the nature of your dealings with us).

 

7. Our marketing and advertising activities

7.1  Overview

Like most businesses, marketing and advertising are important to our continued success. We therefore like to stay in touch with customers and let them know about new offers and opportunities.

We may provide you with information and advertisements about products, services and promotions either from us, or from third parties which may be of interest to you, where:

  • you have asked us to (or have otherwise consented to us doing so); or
  • it is otherwise permitted by law.

7.2  Direct marketing and opting out

For the purposes of this policy, “direct marketing” is the provision of information or the promotion and sale of products and services directly to you including through emails, SMS, MMS, phone calls and the post.

DG may send you direct marketing, such as promotional material about DG or any DG entity from time to time in relation to any product or service they offer.

We will not use or disclose your personal information for the purposes of direct marketing material if you have previously told us not to. If at any time you do not want us (or one of our service providers) to send you direct marketing material or you wish to cancel a previous consent, then you can simply inform our Privacy Officer by contacting them (see contact details in section 14 below). We will implement the request in a reasonable time and without charge.

Please note that there are certain types of communications that you may not be able to opt-out from, such as communications that we are required or permitted by law to send you.

7.3  E-mail analytics

Like many organisations, we use e-mail analytics to track and measure the success of our e-mail newsletters and other e-mail campaigns.

We use various technologies to collect information such as: which of our emails you have opened, which links you have clicked, which email client you are using, whether you opened our e-mail on a computer or mobile device, and the geolocation of your IP address. We use this data to analyse and improve the performance of our e-mail campaigns.

 

8. Cross-border disclosure of personal information

Some of the third parties to whom we disclose personal information may be located outside Australia. Where we engage overseas service providers, we take steps to ensure that personal information is handled in accordance with applicable privacy obligations. In the ordinary course of business, we work with service providers located in the Philippines to assist with certain operational and administrative functions. These service providers are provided only with the limited personal information necessary to perform their specific functions, as determined by us. They are not provided with complete customer records and are contractually required to handle all personal information securely and in accordance with our privacy standards.

From time to time, we may also engage an overseas recipient to provide services to us, such as cloud-based storage solutions. Please note that the use of overseas service providers to store personal information will not always involve a disclosure of personal information to that overseas provider.

Whenever we transfer your personal information outside of Australia, we will do so in accordance with the requirements of applicable privacy and data protection laws. We may disclose your personal information to an overseas recipient without your consent where permitted by the Privacy Act (and, in such circumstances, we will comply with the applicable requirements of the Privacy Act in doing so).

 

9. Employees

We collect information in relation to employees as part of their job application and during the course of their employment, either from the employee directly or, in some cases, from third parties such as recruitment agencies, referees, government bodies (e.g. police checks, if required) and academic and professional bodies (e.g. to validate details and currency of qualifications).

The information we collect may include contact details, documents evidencing eligibility to work in Australia, qualifications, resume, current and former employment details, pay rate and salary, bank details, feedback from supervisors and training records.

We may also collect details of disabilities, allergies and health issues that may impact the employee’s role, or which arise while on our premises or in the performance of the employee’s duties, so we can accommodate and otherwise assist the employee with any such health requirements or incidents.

We collect camera/video footage of employees while on our premises (via CCTV) and logs of the usage of our computer systems and networks on a continuous and ongoing basis using various technologies, including monitoring email, internet and network use.

Under the Privacy Act, personal information about a current or former employee may be held, used or disclosed in any way that is directly connected to the employment relationship. We handle employee information in accordance with legal requirements and our applicable policies in force from time to time.

 

10. Security of personal information

10.1  Protection

We will hold personal information as either secure physical records, electronically on our intranet system, in cloud storage, and in some cases, records on third party servers, which may be located overseas. We use a range of security measures to protect the personal information we hold, including by implementing IT security tools to protect our electronic databases.

10.2  Destruction

When we no longer need your personal information for a permitted purpose and we are not required to keep it to comply with any laws, we will take such steps as are reasonable in the circumstances to destroy your personal information or to ensure that the information is de-identified.

 

11.  Complaints

If you have a query or concern in relation to this privacy policy or wish to make a complaint regarding a breach of privacy (including if you believe we have breached the APPs), you may do so by contacting our Privacy Officer (see contact details in section 14 below). All complaints will be investigated and dealt with in accordance with any applicable timeframes imposed by law and otherwise within a reasonable period, and confidentially.

When contacting us please provide as much detail as possible in relation to your question, concern or complaint. We request that you cooperate with us during this process and provide us with any relevant information that we may need.

If you are dissatisfied with the handling of your complaint, you may contact the Office of the Australian Information Commissioner:

Office of the Australian Information Commissioner

GPO Box 5288, Sydney NSW 2001

Telephone: 1300 363 992

Email: enquiries@oaic.gov.au

 

12. Access to personal information

If you wish to access your personal information that we hold, you may submit a written request to our Privacy Officer (see contact details in section 14 below). You will be required to provide adequate proof of identity before information will be disclosed to you. We may refuse a request in situations permitted by law. We aim to provide you access to such information within 30 days of receipt of a valid request. We may seek to recover from you reasonable costs incurred for providing you with access to the personal information we hold about you, and will provide you with details of those costs before actioning any access request.

 

13. Correction of personal information

13.1   Correction of personal information

You may request that we correct personal information we hold about you by contacting our Privacy Officer (see contact details in section 14 below). We will take reasonable steps to correct your personal information (at no charge) if we are satisfied that it is inaccurate, out-of-date, incomplete, irrelevant or misleading.

13.2   Circumstances when we decline to make corrections

In certain circumstances we may decline to correct your personal information. When this occurs we will provide you with a written notice that sets out:

  • the reasons for the refusal; and
  • the mechanisms available to complain about the refusal.

 

14. Privacy Officer Contact

The contact details for our Privacy Officer are as follows:

Attention: Privacy Officer

Postal address: Level 3, 505 Toorak Road, Toorak VIC 3142

Telephone: 03 9863 9999 Email: ops@deaguegroup.com.au

 

15. Links

Our Websites may contain links to other websites operated by third parties. We make no representations or warranties in relation to privacy practices of any third party website and we are not responsible for the privacy policies or the content of any third party website. Third party websites are responsible for informing you about their own privacy practices and procedures.

 

16. Social media platforms

We use social media platforms such as Facebook, Instagram, X, LinkedIn and TikTok to communicate with the public about our services and businesses. We may collect the information that you choose to share with us through these platforms, including photos, videos and comments and posts.

These social media platforms have their own privacy policies, and may handle your information for their own purposes. You can access the privacy policies for Facebook, Instagram, X, LinkedIn and TikTok on their websites.

If you choose to use these social media platforms to communicate with us, please be mindful that certain pages within these platforms may be publicly available. We encourage you to use the privacy settings available on each platform. If you would like to contact us directly, you can do so using the contact details in section 14.

 

17. Changes

We reserve the right to change the terms of this Privacy Policy from time to time, without notice to you. An up-to-date copy of our Privacy Policy is available on our Websites.

 

Updated: May 2026