This Privacy Policy explains how personal information is collected, used, disclosed, and protected when you visit www.tolgaroad.com.au (the Website). The Website is owned by Douglas Development Corporation and GDM Property (together referred to as the Site Owners) and was designed and is maintained by Martins Design Pty Ltd (the Developer) on behalf of the Site Owners. We are committed to handling personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).
1. Who we are & roles
- Site Owners (Data Controllers): Douglas Development Corporation and GDM Property — determine the purposes and means of processing personal information collected via this Website, including information received by email.
- Developer (Processor/Service Provider): Martins Design Pty Ltd — provides and operates the Website and related technical services for the Site Owners.
- Email Delivery Sub-processor:Postmark (email delivery service) — transmits Website form submissions by email to the Site Owners’ nominated town planner and may temporarily log email content for debugging and delivery assurance.
- Analytics Provider: Google Analytics — measures Website usage and performance on behalf of the Site Owners.
2. Information we collect
2.1 Information you provide (Support Form)
If you choose to submit the optional “Show Your Support” form for the Bonogin development, we will collect the following:
- Name
- Email
- Postcode
- Phone
- Comment (your message of support or feedback)
When you submit the form, these details are sent via Postmark to the town planner’s email address nominated by the Site Owners.
2.2 Information collected automatically (Cookies & Analytics)
When you visit the Website, we (and our analytics providers) may automatically collect certain information through cookies and similar technologies, such as:
- Device and browser information (e.g., type, version, settings)
- IP address and approximate location (at a city/region level)
- Pages viewed, time on site, and interactions
- Referring URLs and campaign/traffic source details
This information is generally aggregated and de-identified, but may, in limited circumstances, be considered personal information.
3. How we use your information
- To receive, record, and consider expressions of support or feedback for a proposed development in Bonogin, including for use in the development approval process with the relevant council.
- To communicate with you about your submission if follow-up is required.
- To provide, operate, secure, and improve the Website and user experience.
- To analyse Website performance and understand aggregate visitor behaviour (via Google Analytics).
- To comply with legal or regulatory obligations and to establish, exercise, or defend legal claims.
4. Disclosure of your information
We may disclose personal information as follows:
- Town Planner: Form submissions are delivered by email to the Site Owners’ nominated town planner and may be used and retained for the duration of the council development approval process.
- Service Providers: To trusted providers that help us deliver the Website and related services (e.g., website hosting, email delivery via Postmark, analytics via Google), subject to contractual confidentiality and privacy obligations.
- Regulators and Councils: Where reasonably necessary to support the development approval process, or if required by law.
- Business Transfers: In connection with a merger, acquisition, or asset transfer involving either of the Site Owners, subject to customary safeguards.
- Legal Requirements: To comply with lawful requests, court orders, or to protect rights, safety, and property.
5. International data transfers
Some service providers (including Postmark and Google) may process information on servers located outside Australia (for example, in the United States or other jurisdictions). Where this occurs, we take reasonable steps to ensure that your personal information is handled in a manner consistent with the APPs and protected by appropriate safeguards.
6. Retention
- Support Form submissions: The town planner may retain your submission and related correspondence for as long as required for the development approval process with the council and for any associated legal or record-keeping requirements.
- Email delivery logs: Postmark may temporarily log email content and metadata for debugging and delivery assurance, after which such logs are purged in accordance with Postmark’s policies.
- Analytics data: Retained by Google Analytics in accordance with settings chosen by the Site Owners and Google’s policies.
7. Cookies & analytics
What are cookies? Cookies are small data files placed on your device to help operate and improve the Website and to understand usage.
How we use them: We use strictly necessary cookies for basic site functions and analytics cookies (Google Analytics) to measure and improve performance.
Your choices:
8. Security
We take reasonable steps to protect personal information from misuse, interference, loss, and unauthorised access, modification, or disclosure, including through access controls, encryption in transit where appropriate, and service-provider due diligence. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security.
9. Your rights
Subject to applicable law, you may request to:
- access the personal information we hold about you;
- correct or update inaccurate, incomplete, or out-of-date information; and
- withdraw your consent (where processing is based on consent).
We will respond within a reasonable period. We may need to verify your identity and, where permitted by law, may charge a reasonable fee to cover administrative costs.
10. Children
The Website is not intended for children under 16. We do not knowingly collect personal information from children. If you believe a child has provided personal information, please contact us so we can take appropriate steps.
11. Third-party links
The Website may contain links to third-party sites and services. We are not responsible for the privacy practices of those third parties. We encourage you to review their privacy policies.
12. How to contact us
For privacy enquiries, access or correction requests, or to make a complaint, please contact:
Developer (Martins Design Pty Ltd)
Email: privacy@martins.com.au
Postal: 46 Magill Road, Norwood 5067, Australia
Phone: +61 08 8130 2777
If you are not satisfied with our response, you may contact the Office of the Australian Information Commissioner (OAIC): www.oaic.gov.au/privacy/privacy-complaints.
13. Changes to this policy
We may update this Privacy Policy from time to time to reflect operational, legal, or regulatory changes. The updated version will be posted on this page with a revised “Effective date”.