Privacy Policy

Privacy Policy

Effective Date: 07/03/2025

Lumo Property Investing Pty Ltd ACN 667 805 941 (Lumo, us, we, our) takes your privacy seriously and is committed to responsible privacy practices. 

Please read the following privacy policy (Privacy Policy) to understand how we collect, use, disclose, store, handle and protect your personal information.  We hope that this will help you make an informed decision about sharing personal information with us.  As well as applying to our interactions with you, this Privacy Policy also applies to all information collected through this website https://lumopropertyinvesting.com.au/ and any other websites or platforms we operate.

This Privacy Policy sits alongside our Website Terms of Use, and any other terms and conditions that apply to the products and services we provide to you.

What is personal information?

In this Privacy Policy, ‘personal information’ has the meaning set out in the Privacy Act 1988 (Cth) (Privacy Act).  In general terms, personal information is information (whether fact or opinion) about an individual who is identified or reasonably identifiable from that information, or from other information combined with the information.

Some types of personal information are classified as ‘sensitive information’, which is subject to additional protection under the Privacy Act. Examples of sensitive information includes information about your racial origin, criminal record, membership of a professional association or trade union and your health information.

What types of personal information do we collect?

The types of personal information we collect about you will depend on the purpose for which the personal information is collected.  This can include:

·                in the case of customers of our property investment and financial advisory services – your name, gender, billing or home address, telephone number, email address, age or date of birth, banking and financial information (including income, investments, credit history, financial position and financial institution details), payment information (including credit card or bank account details), government issued identity documents (such as your drivers licence,  tax file number or passport details) and details about your employment (including your employer, occupation or job title).

We may also collect details of your interests, opinions and preferences to assist us to provide our products and services to you (for example, your financial and investment goals). Where we attend a zoom, teams or other video call with you we may also collect recordings of this meeting but will ask you for your consent first;

·                technical information and general analytics, such as web browser type and browsing preferences, Internet service provider, referring/exit pages, date/time stamps, IP address, time zone and geolocation data (if applicable), some of which is collected automatically,  arising from your use of our website and/or platforms, as well as information about your usage of our website and/or platforms when browsing;

·                if you have requested to receive news about offers, promotions, or events from, us – your name, mailing or street address, email address, social media information and telephone number(s);

·                if you have contacted us to make a complaint, provide feedback, submit an enquiry or request information or a call-back – your name, mailing or street address, email address, social media information and telephone number(s);

·                in the case of our premises or sites where we have CCTV technology installed, CCTV footage and recordings;

·                in the case of prospective employees or contractors – information contained in your application or résumé, recorded during any interview, or obtained through any pre-employment checks, and government-issued identifiers such as tax file numbers;

·                in the case of our suppliers, distributors, referrers or business associates – your name, mailing or home address, occupation or job title, email address, and telephone number(s).

Generally, we will not collect sensitive information about you.  However, in certain circumstances, we may need to collect limited sensitive information about you.  For instance, if you apply for a job with us and we undertake pre-employment checks or you disclose details of disabilities, medical conditions, or other specific dietary or allergy requirements to us.

How do we collect personal information?

We collect your personal information directly from you, including when you:

·                access or use our website;

·                obtain our property investment and financial advisory products and services;

·                attend an in-person, telephone or online session, consultation or workshop with us. This includes discovery and strategy sessions;

·                sign up to receive news and offers, promotions, or attend our events;

·                download ebooks, information or guides from our website;

·                enter surveys, competitions, promotions or request information or material from us;

·                make inquiries about us or our services or otherwise communicate with us by email, by telephone, in person, via social media or another website or otherwise; and

·                apply to work with us or are engaged by us as a contractor.

Where it is reasonable and practicable to do so, we will only collect personal information about you from you directly and not from third parties. 

In limited circumstances, we may collect personal information about you from other sources, including publicly available sources (such as the Internet) and from third parties (such as mutual contacts, business associates who refer our services or from your referees during the recruitment process if you apply for a job with us).  We may also collect personal information through third parties such as our service providers or through promotional and marketing activities.

Whilst we will always maintain robust privacy practices, we are not responsible for the privacy practices of any third parties, so you should review their relevant privacy policy to satisfy yourself as to how they protect and handle your personal information.

We also use the following technologies to collect technical information and general analytics:

·                cookies, which are data files that are placed on your device and often include an anonymous unique identifier.  For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org;

·                log files, which track actions occurring on our website; and

·                web beacons, tags, and pixels, which are electronic files used to record information about how you browse our website.

You may disable your web browser from accepting cookies and other tracking technologies used to collect technical information and general analytics when browsing our website.  If you do so, you can still access our website, but it may impact your user experience.

Some organisations that deliver targeted advertising allow you to opt-out of receiving targeted ads. You may find out more information about this using the links below or by looking at your account settings: 

·                Facebook;

·                LinkedIn;

·                Instagram;

·                X (formerly Twitter);

·                TikTok;

·                Google; and

·                Bing.

Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal. 

Can you choose not to disclose your personal information?

You do not have to identify yourself or provide any personal information if you contact us. You can also notify us that you wish to deal with us using a pseudonym. 

However, if we cannot collect personal information about you or if you use a pseudonym, we may not be able to provide you with our services, or the information or assistance you require.  For example, we will not be able to send you information you have requested if you have not provided us with a valid email address or telephone number.

How do we use your personal information?

We use your personal information for the purposes it was collected including managing our business and providing our tailored property investment and financial advisory products and services to you, including to:

·                provide our products and services to our customers or to receive goods or services from third parties;

·                verify your identity (for example, as part of our ‘know your customer’ checks, or if you request access to the personal information we hold about you);

·                consider you for a job at Lumo (whether as an employee or contractor) or other relationships with us;

·                communicate with you, and to address any issues or complaints that we or you may have regarding our relationship or our property investment and financial advisory products and services;

·                prevent, detect and investigate suspicious, fraudulent, criminal or other activity that may cause you, us or others harm, including in relation to our products and services;

·                comply with our legal obligations such as notifying you of matters that we may be required by law to do so;

·                identify opportunities to improve our products and services and to improve our service to you;

·                gain insights about you so that we can serve you better, understand your preferences and interests, personalise your experience and/or enhance products and services you are offered and receive;

·                for direct marketing purposes (see “Direct Marketing Communications” below); and

·                contact you regarding any of the above, including via electronic messaging such as SMS and email, by mail, by phone or in any other lawful manner.

We may also use or disclose your personal information for our administrative, marketing (including direct marketing), planning, product or service development, quality control, survey and research purposes and for other purposes to which you have consented, or as otherwise permitted or required by law.

Technical information and general analytics is used for the purpose of gauging visitor traffic, trends and delivering personalised content to you while you are using our website, and to improve our website and our products and services.

To whom do we disclose personal information?

We may disclose your personal information to third parties in connection with the purposes described above (see the “How do we use your personal information?” section).

This may include disclosing your personal information to the following types of third parties:

·                our related companies;

·                any potential third party acquirer of our business or assets, and advisors to that third party;

·                our professional advisers (such as lawyers, accountants or auditors) and insurers;

·                our employees, contractors and third party service providers who assist us in performing our functions and activities for example payment systems operators and financial institutions, cloud service providers, data storage providers, shipping companies, telecommunications providers and IT support services providers). This includes Acronis and Synology (who provide us with data storage and back-up services);

·                organisations authorised by us to conduct promotional, research or marketing activities;

·                third parties to whom you have authorised us to disclose your information (e.g. referees or account nominees, your bank, financial institution or broker, builders or land developers, real estate agents, insurers and your professional advisers such as lawyers, financial consultants and accountants); and

·                any other person as required or permitted by law.

We use third party service providers to provide us with web analytics services, such as Google Analytics and social media platforms. More information about how these third party service providers use your personal information is available online. For example, you can read more about how Google uses your personal information at https://support.google.com/analytics.

If we disclose your personal information to third parties we will use reasonable commercial efforts to ensure that such third parties only use your personal information as reasonably required for the purpose of disclosure and in a manner consistent with applicable laws. For example, where it is commercially practical to do so, by including suitable privacy and confidentiality clauses in our agreement with a third party service provider to whom we disclose your personal information.

Direct marketing communications

We will only send you direct marketing communications (either through mail, SMS or email), including any news and exclusive offers, promotions, or events, where you have consented for us to do so.

You may opt-out of receiving direct marketing communications at any time by contacting us or by using opt-out facilities provided in the direct marketing communications.

How to we store personal information?

We store your personal information in paper-based files and electronically in secure databases on cloud based servers.  

Does personal information leave Australia?

We store personal information in servers located in Australia. However, some of the third-party service providers we disclose personal information to may be based in or have servers located outside of Australia. For example, we use the Synology NAS storage application to host Lumo data which is backed up to a datacentre located in Seattle, USA.

Except where an exception applies under the Privacy Act or other relevant legislation, we will take commercially reasonable steps to ensure that overseas recipients to whom we disclose personal information do not breach the Privacy Act and the Australian Privacy Principles in relation to such personal information.

How do we protect your personal information?

We implement reasonable measures to protect and safeguard your personal information from misuse, loss, theft and unauthorised access, modification or disclosure. This includes computer and network security, for example, we use firewalls (security measures for the internet) and other security systems such as user identifiers and passwords to control access to our computer systems.

However, particularly for electronic data stores and due to the fact that the Internet is inherently insecure, we cannot guarantee the security of transmission of personal information disclosed to us online.  Accordingly, you transmit your personal information to us online at your own risk and are encouraged to exercise care in sending personal information via the internet.

How long do we keep your personal information?

Generally, we will retain your personal information for the amount of time necessary for the purposes for which your personal information was collected (as outlined in this Privacy Policy), unless a longer retention period is required by law or is reasonably necessary for us to comply with our legal obligations, resolve a dispute or maintain security.

How can you access and correct your personal information?

You may request access to any personal information we hold about you at any time by contacting us at operations@lumoperopertyinvesting.com.au. We will provide access to that information in accordance with the Privacy Act, subject to any exemptions that may apply.  We may charge an administration fee in limited circumstances, but we will let you know in advance if that is the case.

If you believe that personal information we hold about you is incorrect, incomplete or inaccurate, then you may request us to amend it by contacting us at operations@lumoperopertyinvesting.com.au. Where we agree that the information needs to be corrected, we will update it. If we do not agree, you can request that we make a record of your correction request with the relevant information.

You can also ask us to notify any third parties that we provided incorrect information to about the correction. We’ll try and help where we can – if we can’t, then we’ll let you know.

Questions or complaints?

If you have any questions, concerns or complaints about our collection, use, disclosure or management of your personal information, please contact us at operations@lumoperopertyinvesting.com.au.

We are committed to resolving any complaints reasonably and to ensuring that we are doing the right thing by our customers. We will make all reasonable inquiries and your complaint will be assessed with the aim of resolving any issue in a timely and efficient manner.

If you have raised a complaint with us and you are unsatisfied with the outcome or have further concerns about the way we handle your personal information, under the Privacy Act, you may complain to the Information Commissioner at the Office of the Australian Information Commissioner, whose contact details are set out below:

Office of the Australian Information Commissioner
GPO Box 5218
Sydney NSW 2001
Phone: 1300 363 992
Online: www.oaic.gov.au
Email:   enquiries@oaic.gov.au

How to contact us

If you have a query, concern or complaint about how we have collected or handled your personal information or you would like to request access to or correction of the personal information we hold about you, please contact us using the details provided below:

Privacy Officer

Lumo Property Investing Pty Ltd

2/9 Windmill Street, Southport QLD 4215

Phone: 1300 217 670
Email:   operations@lumoperopertyinvesting.com.au

Changes to this Policy

We may change or update this Privacy Policy from time to time to keep up-to-date with legal requirements and the way we operate our business.  An up-to-date version of this Privacy Policy is available at any time on this page. You are responsible for reviewing this Privacy Policy periodically and informing yourself of any changes. We suggest that you check back regularly. If we make significant changes to our Privacy Policy, we will seek to inform you by notice on our website or by email.

Last updated: 7 March 2025