Moving Leads supports privacy protection as a fundamental part of its business and is committed to maintaining the highest standards of data integrity and security for the Moving Leads database.

Moving Leads is bound by the Privacy Act 1988 (Cth) (the Privacy Act), the Australian Privacy Principles (APPs) as well as other applicable laws protecting privacy. This policy describes how Moving Leads collects, uses, holds and discloses personal information.

In this Privacy Policy:

Moving Leads means Intelligent Business Communications Pty Ltd trading as Moving Leads

Personal Information means information or an opinion about an identified individual, or about an individual who is reasonably identifiable.

You consent to us collecting, holding, using and disclosing your personal information in accordance with this policy.

WHY WE COLLECT, HOLD AND USE PERSONAL INFORMATION

The purpose of the Moving Leads database (‘Intelligent Moves’ database) is to facilitate effective contact between buyers and sellers in the Australian business-to-business or B2B marketplace. The Moving Leads database covers companies and organisations in Australia who may soon be relocating business premises or expanding to a new business premises, as identified by researching expiring commercial leases and/or public real estate lease listings. It contains firmographic data and potential moving date data on the companies and organisations, and business contact information.

In most cases, the information we collect as part of the ‘Intelligent Moves’ database and share as part of our service does not include personal information.

Where personal information is collected as part of the ‘Intelligent Moves’ database, Moving Leads collects, holds and uses personal information only for the purposes for which it was collected which are directly related to Moving Leads’ functions and activities, namely:

maintenance of the quality of the ‘Intelligent Moves’ database;
provision of business information to clients for marketing purposes;
to provide you with products and services, or manage our relationship with you;
contacting or responding to you, or if we need to tell you something important; or
complying with our legal obligations.

If you do not provide us with your personal information we may not be able to provide our services to you, or communicate with you, or respond to your enquiries.

WHAT PERSONAL INFORMATION DO WE COLLECT

Moving Leads does not collect sensitive information about an individual. Moving Leads predominantly collects business data that does not include personal information, however the data Moving Leads collects may include personal information as required. The business data does not include individual consumer contact information (no B2C data).

Most of the information in Moving Leads’ database, such as names of individuals or company information is sourced from publicly available and third-party sources, or from the organisation directly.

The business and personal information Moving Leads may capture on Australian organisations and individuals can include:

Decision Maker Job Titles
Decision Maker Names
Company Names
Company Postal & Office Addresses
General Switchboard Telephone Numbers
Email Addresses
URL’s
Number of Employees
Sales /Operating Revenues
Business Activities (Industry Codes and Keywords)

Moving Leads collects information on Australian businesses, and decision makers within those businesses, in a lawful manner in order to maintain the ‘Intelligent Moves’ database. Moving Leads takes reasonable steps to ensure individuals listed in the database are aware of its identity, the purpose of collection and possible use of their personal information and, to the extent practicable, obtains consent to such use.

For clients and website visitors Moving Leads may also collect information about you and your interactions with us when you purchase or use any of Moving Leads’ products or services, call us or visit Moving Leads’ website.

HOW WE COLLECT YOUR PERSONAL INFORMATION

We will collect your personal information directly from you when you interact with us.

Moving Leads also collects personal information when it collects company information which is used by Moving Leads to maintain its ‘Intelligent Moves; database and by Moving Leads’ clients for marketing purposes. An individual may opt out of receiving further contact or request access to their information (see below).

Most of the information in Moving Leads’ ‘Intelligent Moves’ database, such as names of individuals or company information is sourced from publicly available third-party sources. For example:

Business Directories
Business Media
Press Clippings
Websites and Online Sources
Telephone research

HOW WE STORE AND HOLD PERSONAL INFORMATION

Moving Leads employs security procedures to protect information from misuse, interference or loss, unauthorised access, modification or disclosure. For any essential suppliers and contractors that require access to the ‘Intelligent Moves’ database, Moving Leads supplies data only to authorised users who have contracted to provide an appropriate level of data security.

Moving Leads maintains stringent updating procedures to ensure that data is accurate, complete and up-to-date. To maintain data accuracy, information is verified on a regular basis.

Moving Leads does not use government identifiers on an individual.

Moving Leads will also take reasonable steps to destroy or de-identify personal information once we no longer require it for the purposes for which it was collected or for any secondary purpose permitted under the Privacy Act.

WHO WE DISCLOSE YOUR PERSONAL INFORMATION TO AND WHY

Moving Leads collects, holds and uses personal information only for the purposes for which it was collected which are directly related to Moving Leads’ functions and activities, namely:

maintenance of the quality of the ‘Intelligent Moves’ database;
provision of business information to clients for marketing purposes;
to provide you with products and services, or manage our relationship with you;
contacting or responding to you, or if we need to tell you something important; or

We may transfer or disclose your personal information to our related companies or to external service providers so that they may perform services for us or on our behalf.

We may also disclose your personal information to others where:

we are required or authorised to do so by law;
you expressly consented to the disclosure or the consent may be reasonably inferred from the circumstances; or
we are otherwise permitted to disclose the information under the Privacy Act.

DISCLOSURE TO OVERSEAS RECIPIENTS

Data from the Moving Leads ‘Intelligent Moves’ database is predominantly supplied to clients within Australia. In the event of an overseas recipient who receives Moving Leads data is contracted to provide an appropriate level of data security and use the data in accordance with the Australian Privacy Principles.

Moving Leads has a separate GDPR Statement below in relation to the GDPR.

USE OF YOUR PERSONAL INFORMATION FOR MARKETING

We, or related companies, business partners, clients or service providers (offeror) may use your business contact information which may contain personal information to offer you products and/or services we or they (as applicable) believe may interest you, but not where you tell the offeror not to contact you.

Where you receive electronic marketing communications from us, related companies, business partners, clients or service providers, you may opt out of receiving further marketing communications by following the opt out instructions below.

COOKIES AND IP ADDRESS TRACKING

Our website may use cookies for site administration purposes. If for any reason an individual wishes not to take advantage of cookies, the individual may have his or her browser not accept them (although this may disable or render unusable some of the features of our website). Our website may also detect and use an individual’s IP address or domain name for internal traffic monitoring and capacity purposes or to otherwise administer the website. No personal information is obtained, rather the patterns of usage of visitors to the website may be tracked for the purposes of providing improved service and content based on the aggregate or statistical review of user site traffic patterns.

ACCESS TO AND CORRECTION OF YOUR PERSONAL INFORMATION

You may access or request correction of the personal information that we hold about you by contacting us by email at contact@movingleads.com.au. No charge is made for access. There are some circumstances in which it may not be possible for us to provide you access to your personal information or an exemption under the Privacy Act may apply. For instance, we may not provide access to information if disclosing that information would impact on the privacy of another individual. Where we will not provide access to personal information held about an individual, we will tell the individual why.

OPT OUT

You can opt out of receiving further marketing communications at any time by contacting us by email at contact@movingleads.com.au. You agree that even if you opt out of receiving marketing communications we may still be required to send you essential information that we are legally required to provide relating to the services we provide. You acknowledge and agree that removal from our distribution lists may take several business days after we receive your request for removal.

COMPLAINTS

Please direct all complaints to the contact details below. If you have a complaint about the way in which we have handled any privacy issue, we will consider your complaint and determine whether it requires further investigation. We will endeavour to notify you of the outcome of this investigation within a reasonable period of time. If you are unsatisfied with the way we have handled a privacy issue, you may contact the Office of the Australian Information Commissioner (www.oaic.gov.au).

CONTACT DETAILS

For any questions relating to Moving Leads Privacy Policy, please contact:

Suite 5, 35 Toorak Road
South Yarra VIC 3141
P: +61 (03) 7068 6615
E:contact@movingleads.com.au

CHANGES TO THIS POLICY

This Privacy Policy is effective as at 22 September 2023.

Moving Leads may change its policy on how it handles personal data from time to time. Any changes to our policy will be published on our website.

GDPR

MOVING LEADS GDPR STATEMENT

WHAT IS THE EU GDPR

The General Data Protection Regulation (GDPR) came into effect on 25 May 2018 with the intent of unifying data protection laws across the European Union (EU).

The GDPR applies to “personal data” including any information relating to an identified or identifiable natural person.

TO WHOM DOES GDPR APPLY

The GDPR applies directly in all EU member states. However, in certain circumstances the GDPR can also apply to the processing activities of data controllers situated outside the EU.

GDPR applies to:

The processing of personal data in the context of the activities of an establishment of a controller or processor in the EU regardless of whether the processing takes place in the EU or not;
The processing of personal data of data subjects in the EU by a controller or processor not established in the EU where the activities relate to either of the following: a) The offering of goods or services to data subjects in the EU; b) The monitoring of the behaviour of data subjects as far as their behaviour takes place in the EU;
The processing of personal data by a controller not established in the EU, but in a place where Member State law applies by virtue of public international law.

DOES GDPR GENERALLY APPLY TO MOVING LEADS

Moving Leads is an Australian business that is not established in the EU or the European Economic Area (EEA).

GDPR generally does not apply to Moving Leads’ activities for the following reasons:

Moving Leads as a data controller does not have an establishment in the EU;
Moving Leads’ business information data was collected in Australia with respect to individuals in Australia.
Moving Leads does not offer goods or services to data subjects in the EU;
Moving Leads does not monitor the behaviour of data subjects as far as their behaviour takes place in the EU;
EU Member State law does not apply to Moving Leads’ processing by virtue of public international law.

WHAT BUSINESS DATA DOES MOVING LEADS PROVIDE

Moving Leads provides its customers with business contact information to help its customers locate and engage with other businesses (B2B data) in Australia who may soon be relocating business premises or expanding to a new business premises, as identified by researching expiring commercial leases and/or public real estate lease listings. It contains firmographic data and potential moving date data on the companies and organisations, and business contact information.

This B2B data relates to businesses in Australia only. The B2B data may include “personal information” which is defined under The Australian Privacy Act 1988 (Privacy Act), as ‘information or an opinion about an identified individual, or an individual who is reasonably identifiable’ (i.e. contact names of individuals employed by such businesses in Australia), however:

the business data does not include individual consumer contact information (no B2C data);
Moving Leads does not process sensitive personal data;
Moving Leads does not process “special categories” of personal data; and
the business data is subject to usage restrictions and may only be used internally by the client.

DOES MOVING LEADS COMPLY WITH GDPR

The GDPR does not generally apply to Moving Leads and its business activities.

The GDPR may still apply where Moving Leads engages a data processor established in the EU to perform services for Moving Leads. In this event, Moving Leads will require that such party complies with the GDPR.

Regardless of whether GDPR may apply indirectly to Moving Leads, Moving Leads must comply with the laws of Australia in relation to the transfer of personal data to and the processing by any data processor for which it is a controller.

MOVING LEADS COMPLIES WITH AUSTRALIAN PRIVACY LAW

Moving Leads takes all reasonable steps to ensure that any disclosure of its business data to an overseas recipient does not breach the Australian Privacy Principles (APPs) in relation to that information. Moving Leads will also take into account whether it reasonably believes the overseas recipient is subject to laws that are substantially similar to the APPs (eg GDPR or the UK Data Protection Act 2018).

DISCLAIMER

This statement is intended to apply to Moving Leads Australian business contact information. This document is provided for information purposes only and does not constitute legal advice.