Privacy Policy

About this privacy policy

At Top Spring Australia Holdings Pty Ltd ABN 21 609 078 140 (we, our, us), we value and respect your privacy and take the protection of your personal information seriously.

We have prepared this privacy policy to inform you of the personal information we collect and hold about you, and how we use that information. This privacy policy also provides information about your privacy rights as an individual and how to contact us if you have any privacy concerns.

This privacy policy may change from time to time and it is therefore important that you review it regularly.

What personal information do we collect and handle?

Personal information is any information or opinion (whether true or not, and whether recorded in a material form or not) about you as an identified individual, or an individual who is reasonably identifiable.

The types of personal information we collect and handle may include, but are not limited to contact information, such as your name, postal and/or home address, telephone number and email address.

How do we collect your personal information?

We will collect personal information directly from you wherever it is reasonable and practical to do so. We may collect personal information from you:

  • when you communicate or interact with us by telephone, email, online (including through our website), or in person; or
  • when you complete a form or a survey.

We may also collect your personal information from third parties including:

  • real estate agents and other third parties who provide services to us; and
  • other third party selling agents for marketing purposes.

You must only provide us with the personal information of someone else if you have that person’s consent to do so.

Why do we collect your personal information?

We collect, hold, use and disclose personal information for a number of reasons, including:

  • to respond to your comments or questions;
  • to assess and improve the performance of our website;
  • to process and respond to a complaint or request you may make;
  • to contact you if we believe there is any information we believe you might be interested in;
  • for marketing purposes; and
  • to comply with applicable laws and regulations.

Who might we disclose your personal information to?

We may disclose your personal information to various third parties for any of the purposes identified above. The types of third parties with whom we exchange personal information include:

  • our service providers, including providers of promotion, accounting, auditing, legal, data processing, data analysis, document management, information broking, research, and technology services;
  • various third party suppliers and partners, which provide services and support for our operations;
  • law enforcement agencies and other organisations where required or permitted by law; and
  • service providers engaged by us from time to time, to contact you to request your feedback on our website or our projects.

Any personal information that we collect from you is stored in Australia. However, if we need to disclose your personal information to overseas recipients, we will update this Privacy Policy by specifying the countries in which they are located.

What if we can’t collect your personal information?

If you do not provide us with the personal information we need, some or all of the following may occur:

  • we may not be able to offer or provide you with information;
  • and we may not be able to respond to your requests.

Visitors to our website

To help improve the information we provide through our website, certain information is collected from your browser. This information is collected as statistical information and includes the IP address, browser type, language and access times. This website also uses cookies to track pages visited and information accessed within our website. This information is for statistical reference and site analysis only.

In many cases, the tools used on our website record information in a way that does not identify you as an individual. In other cases, information may be personal information in which case this Privacy Policy will apply.

How do we protect your personal information?

We take all reasonable steps to keep personal information protected from loss, interference, misuse or unauthorised access, modification or disclosure. We store personal information in both physical and electronic form, sometimes with the assistance of third parties such as data hosting providers.

Direct marketing communications

From time to time we may send you direct marketing communications. We may contact you by electronic messages (e.g. email), online (e.g. through our website), by mail, and by other means, unless you opt out or we are subject to legal restrictions. You may opt-out of marketing communications, by contacting us using the contact details below, or by using the opt out mechanism included in our electronic marketing messages.

How can you access and correct your personal information?

The accuracy of the personal information we hold and use is important to us. We take reasonable steps to ensure that the personal information we handle is accurate, complete and up-to-date. To help us keep your personal information accurate, please let us know if there are any errors or changes in your personal information.

You can request access to the personal information we hold about you at any time by contacting our Privacy Officer via the contact details at the bottom of this Privacy Policy. You may also request the correction of any of the personal information we hold about you. In most cases, we can help you promptly and informally with these requests. In other cases, we may need to verify your identity and ask you to make your request in writing.

From time to time, we may need to reject your request to access or correct the personal information we hold about you, if we believe it to be necessary and to the extent allowed by law. We will provide our reasons if we deny your request for access to, or correction of, your personal information. Where we decide not to make a requested correction to your personal information and you disagree, you may ask us to make a note of your requested correction with the information we hold about you. We won’t charge you for simply making a request to access or correct personal information. However, we may charge reasonable costs for carrying out your request.

How can you make a privacy complaint?

You can contact our Privacy Officer using the contact details at the bottom of this Privacy Policy if you have any concerns about how we have handled your personal information. We will respond to let you know who will be handling your matter and when you can expect a further response. We may request additional details from you regarding your concern, and we may need to engage or consult with other parties to investigate and deal with your issue. We will keep records of your request and any resolution. If you are not satisfied with the manner in which we have dealt with your complaint, you may contact the Office of the Australian Information Commissioner at

Policy reviews

From time to time, we may review and update this Privacy Policy. All personal information will be collected and handled by us in accordance with the most recently updated Privacy Policy.

How to contact us

If you have any questions or comments about this privacy policy, please don’t hesitate to contact us as follows:

Contact:        Top Spring Australia Administration

Address:        Level 21, 201 Elizabeth St Sydney


Phone:          02 8042 8800


Last updated: 5 February 2019