Privacy Policy



This is our Privacy Policy (Policy) and it applies to any person for whom we currently hold, or may in the future collect, Personal Information. This Policy tells you how we collect and manage your Personal Information.

For the purposes of this Policy references to “AGEM” includes AGEM Developments Pty Ltd (ACN 161 087 743), AGEM Constructions Pty Ltd (ACN 009 075 905) and those entities related bodies corporate, officers, employees, agents and contractors.

AGEM is committed to providing you with the highest possible protection for your Personal Information.  We may modify this Policy from time to time.

What is personal information?

When used in this Policy, the term “Personal Information” has the meaning given to it in the Privacy Act. In general terms, it is any information that can be used to personally identify you.  This may include your name, address, telephone number, email address and profession or occupation. If the information we collect personally identifies you, or you are reasonably identifiable from it, the information will be considered Personal Information.

Collection of personal information

The type of Personal Information we collect and hold about you will depend on the circumstances and the nature of the relationship between AGEM and its potential or actual customers and clients.  Generally, it will include information which is relevant to providing our services to you.

We may collect your name, mailing or street address, email address, telephone number, facsimile number, age or birth date, profession, occupation or job title, financial information, banking details, governmental identification details and any additional information relating to you.

We may also collect some information that is not Personal Information because it does not identify you or anyone else. For example, we may collect anonymous answers to surveys or aggregated information about how users use our website.

We do not collect or hold Sensitive Information (which is a subset of Personal Information), such as health information, racial or ethnic origins, religious affiliation or political opinions.

We collect your Personal Information directly from you unless it is unreasonable or impracticable to do so. We may collect Personal Information about you in a number of ways, including:

  • through your access and use of our website;
  • by telephone, letter, fax or email;
  • during conversations between you and our representatives;
  • through exhibitions;
  • by contracting with us;
  • by entering promotions or ; and
  • completing surveys or questionnaires, providing feedback or complaining to us.

We may also collect Personal Information from third parties including:

  • from third party companies such as credit reporting agencies, law enforcement agencies and government entities;
  • your representatives (e.g., lawyers, accountants and financial advisers);
  • your spouse, relatives or employer; and
  • publicly available sources of information or any other organisations where you have given your consent.

WHY WE COLLECT YOUR personal information

We collect Personal Information about you so that we can perform our business activities and functions and to provide best possible quality of customer service.

We collect, hold, use and disclose your Personal Information for the following purposes:

  • to provide products and services to you and to send communications requested by you;
  • to answer enquiries and provide information or advice about existing and new products or services;
  • to assess the performance of the website and to improve the operation of the website;
  • to conduct business processing functions including providing Personal Information to our related bodies corporate, contractors, service providers or other third parties;
  • for the administrative, marketing (including direct marketing), planning, product or service development, quality control, survey and research purposes of Warrington, its related bodies corporate, contractors, real estate agents and employees or service providers;
  • to provide your updated Personal Information to our related bodies corporate, contractors, real estate agents and employees or service providers;
  • to update our records and keep your contact details up to date;
  • to process and respond to any complaint made by you; and
  • to comply with any law, rule, regulation, lawful and binding determination, decision or direction of a regulator, or in co-operation with any governmental authority of any country (or political sub-division of a country).

Your Personal Information will not be shared, sold, rented or disclosed other than as described in this Policy.

Disclosure of personal information

We may disclose your Personal Information to:

  • our employees; contractors, real estate agents and employees or service providers for the purposes of operation of our website or our business, fulfilling requests by you, and to otherwise provide products and services to you;
  • our related bodies corporate or any other company within the AGEM group;
  • any third party service provider with whom we have a commercial relationship for business, marketing, and related purposes;
  • professional advisers, such as accountants, solicitors, business advisors, financial advisers and consultants; and
  • government authorities such as the Australian Taxation Office or the Australian Securities and Investments Commission where required to by law or where reasonably requested.

Information storage and security

We will take reasonable steps to ensure that the Personal Information we hold is protected from misuse, loss and unauthorised access, modification or disclosure.

We store Personal Information in our computer databases and we may also utilise the services of third party storage providers, which may store data in an overseas country.  In the event that your Personal Information is held in an overseas country the information will not be protected by the Australian Privacy Principles.  By providing your details, you consent to your Personal Information being disclosed and held in this manner.

Various security measures are in place to safeguard Personal Information, including restricted staff access, password restricted access and internet based security tools (e.g., firewalls, virus protection programs). Despite this, as our website is linked to the internet, and the internet is inherently insecure, we cannot provide any assurance regarding the security of transmission of information you communicate to us online. We also cannot guarantee that the Personal Information you supply will not be intercepted while being transmitted over the internet. Accordingly, any Personal Information or other information which you transmit to us online is transmitted at your own risk.

Accessing your personal information

You may request access to your Personal Information at any time. Upon confirmation of your identity, we will provide you with access to information by either providing you with copies of the information requested or allowing you to inspect the information.

We will not provide you with access to Personal Information which would reveal any confidential formulae or the detail of any in-house evaluative decision making process, but may instead provide you with the result of the formulae or process or an explanation of that result.

The Australian Privacy Principles place other restrictions on accessing your Personal Information. Restrictions include the following:

  • giving access would have an unreasonable impact on the privacy; or would pose a serious and imminent threat to the health or safety of any individual or to the public;
  • the request for access is frivolous or vexatious;
  • the information relates to existing or anticipated legal proceedings and would not be accessible by the process of discovery in those proceedings;
  • giving access would reveal commercially sensitive information or our intentions which may prejudice any negotiations with you;
  • giving access would be unlawful or would be likely to prejudice a criminal investigation;
  • denying access is required or authorised by or under law or a court/tribunal order; and
  • giving access would be likely to prejudice enforcement related activities by or on behalf of an enforcement body.

If we decline your request for access, we will provide a written explanation to you for the refusal.

Correcting your personal information

We will take reasonable steps to ensure that the Personal Information we collect is accurate, up to date and complete. If you provide evidence to us that the Personal Information we hold about you is inaccurate, incomplete or out of date, then we will take all reasonable steps to correct it.


When you access our website, we may send a “cookie” which is a small data file that is transferred to your computer when you allow your web browser to accept a cookie. This enables us to recognise your web browser. It also enables us to keep track of your activity on our website for a period of time. Cookies also make it easier for you by saving your passwords and preferences.

We also use cookies to measure traffic patterns on our website, to determine which areas of our website have been visited and to measure transaction patterns in the aggregate.

We use this to research our users’ habits so that we can improve our online products and services. We may log IP addresses (that is, the electronic addresses of computers connected to the internet) to analyse trends, administer the website and track users movements.

Our cookies do not collect Personal Information. If you do not wish to receive cookies, you can set your browser so that your computer does not accept them.


Our website may contain links to other websites operated by third parties. We make no representations or warranties in relation to the 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.

Privacy complaints or questions

If you have a privacy complaint or question, would like to know what Personal Information we hold about you, or would like to update your Personal Information please contact our Privacy Officer in any of the following ways:

Our Privacy Officer will investigate any privacy concerns you have, and will endeavour to respond to your privacy questions, or resolve any privacy concerns you have in a timely manner.  Our Privacy Officer will respond in writing to you regarding the outcome of any investigation.

If your privacy concerns are not resolved to your satisfaction or you wish to obtain more information on privacy legislation, you can contact the Office of the Australian Information Commissioner on 1300 363 992, or visit their website at 

More information

We are required to comply with the Privacy Act 1998 (Cth) and the Australian Privacy Principles. A summary of the Australian Privacy Principles, a copy of the Privacy Act and additional information about privacy is available on the website of the Office of the Australian Information Commissioner at