Privacy Policy

Our privacy policy

GJR Holdings Pty Ltd ACN 679 858 489 trading as ONO Rural (we, us, our) respects your privacy and is committed to protecting your personal information. Our privacy policy outlines our approach to privacy and how we collect, use and protect your personal information, and sets out your rights in relation to accessing the personal information we hold about you.

Personal information is defined in the Privacy Act 1988 (Cth) and means information or an opinion about an identified individual, or an individual who is reasonably identifiable.

How we collect personal information

We only collect personal information you give us directly, or which is collected automatically as part of your activities with us (including usage data or cookies on our website (Site)). For example, when you:

• register for an account;
• complete electronic and paper forms;
• call us;
• use our Site;
• send us information via the "Contact Us" page on our Site;
• send us information when using any part of our Site; and/or
• view electronic communication that you receive from us, including where you open emails, the links you view from the email, what webpages you view from the email, and the number of pages viewed.

When we collect information, we will ensure the individual has given verifiable consent or there is some other lawful basis for collection and processing. We will generally explain to the individual why we are collecting it, who we give it to, and how we will use or disclose it.

To ensure that personal information you provide is accurate, up to date and complete, and to prevent fraud, we may contact you using the information you have provided to verify certain information (including account details).

What personal information we collect

The personal information that we collect includes:

• identifying information, including your name and contact details such as your email, home address and billing address;
• transactional information, including information you provide as part of a transaction with us or that is generated as a result of that transaction;
• financial information, including payment details, credit card numbers or bank details;
• information we are required or authorised to collect and process under law to identify you or verify information you have provided;
• depending on the nature of products you list on the Site, information about your business and properties;
• usage information, including data about your interaction with our website through devices you use; and
• computer and connection information such as page views, traffic, uniform resource locators (URLs), internet protocol (IP) address and web log information.

When you visit our Site, we may place cookies on your browser to enhance and manage our website and improve our business and the services we provide to you. We and/or Google may use this information to optimise and place advertisements, including advertisements of third party vendors, on our own and third party websites. Google's ability to use and share information collected by Google Analytics is restricted by the Google Analytics Terms of Use and Privacy Policy. Cookies can be managed by accessing the individual settings in your browser.

Our Site does not support "Do Not Track" requests.

Our services are not intended for children and we do not knowingly collect personal information from individuals who are children.

We may use social media (including Facebook, X or Instagram) to communicate with you or the public. We may collect personal information that you provide us via social media for the purposes of engaging and consulting with you. Any personal information we collect via social media will be handled appropriately in accordance with this privacy policy. Social media platforms may also collect your personal information for their own purposes, and when you agree to their terms of service and privacy policy, you may be agreeing to your personal information being transferred outside Australia. To protect your privacy and the privacy of others, you should refrain from posting any personal information (including phone numbers and email addresses) in your comments, tweets or replies.

We may collect personal information from people who are not customers or suppliers of our business but whose personal information is given to us by those individuals via our Site, or in the course of a transaction or recruitment. If you give us information, you must only do so with that individual's authorisation, and you should inform them of this privacy policy.

Why we collect personal information

The purpose for which we collect personal information is to enable the effective provision of our services to you and our other customers, including to:

• execute your requests for our services;
• issue invoices for, and collect, our fees (for example, an auction success fee) and manage billing for successful auctions. We do not process, hold or escrow the sale price between a buyer and a seller: that is paid directly between them, off the Platform;
• provide you with email confirmation of your account registration;
• verify your identity;
• improve and optimise our services, business and our users' experience;
• send you service, support and administrative messages, reminders, technical notices, updates, security alerts, and information requested by you;
• send you marketing and promotional messages and other information that may be of interest to you, including details of auctions or listings you might be interested in, and information sent by, or on behalf of, our business partners that we think you may find interesting. You may opt out of receiving these direct marketing communications at any time. Our electronic marketing activities will comply with the requirements of the Spam Act 2003 (Cth); and
• comply with our legal obligations, resolve any disputes that we may have with any of our users, and enforce our agreements with third parties.

When we use, process or disclose personal information

We will only use, process or disclose your personal information for the primary purpose for which it was collected, or otherwise as relevant national laws allow. We may otherwise use and disclose your personal information to detect, prevent and investigate fraudulent behaviour, if you have given us consent for the use or disclosure, or if it is required or authorised by law.

If those purposes for which we have collected the information involve providing personal information about an individual to any third party, we will take appropriate and reasonable steps to ensure any personal information is protected.

We may disclose personal information for the purposes described above to:

• our employees and related bodies corporate;
• data processors, including third party suppliers and service providers (including providers for the operation of our websites and/or our business, or in connection with providing our products and services to you);
• GoHighLevel (LeadConnector), a customer communications, invoicing and marketing platform located in the United States, which we use to send you communications, issue our fee invoices and manage billing;
• professional advisers, dealers and agents;
• payment systems operators (for example, merchants receiving card payments);
• our existing or potential agents, business partners or partners;
• anyone to whom our assets or businesses (or any part of them) are transferred;
• specific third parties authorised by you to receive information held by us; and/or
• other persons, including government agencies, regulatory bodies and law enforcement agencies, or as required, authorised or permitted by law.

Where your personal information is held and processed

We process your personal information on our servers and through service providers, some of which are located in Australia and some overseas.

We provide your information to third parties that provide services to us solely for the purpose of providing those services, including technology, invoicing, billing and marketing providers. In particular, we use GoHighLevel (LeadConnector), located in the United States, for customer communications, fee invoicing and billing. This means some of your personal information, including your name, contact details and billing information for our fees, is disclosed to and processed by a recipient in the United States.

Where your personal information is transferred outside Australia, we will take reasonable steps to ensure that overseas recipients deal with that information in a way that is consistent with the Australian Privacy Principles and the Privacy Act 1988 (Cth).

Security and retention of personal information

We take reasonable steps to protect the personal information we hold against loss, unauthorised access, use, modification or disclosure, and against other misuse. However, we cannot guarantee the security of your personal information.

We will only use, process or store personal information for as long as required by the purpose it has been collected for, including where such purpose relates to our legitimate interest, and for a longer period where you have given consent to such processing, as long as such consent is not withdrawn. We may be obliged to retain personal information for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

Third parties and information you receive through us

Our Site may contain links to third party websites. We are not responsible for the privacy policies of any third party websites. We recommend that you review the privacy policy of each website you visit.

Where you transact with another person or entity through us, we may enable you to obtain the personal information of that person or entity. You acknowledge that in these circumstances you are the data controller of that data, and you should, where required, inform that other person about your privacy practices and otherwise comply with relevant national laws.

Using the personal information of any person you receive through us for any purpose other than to perform the transaction we enable is prohibited by this policy.

Your rights and our complaints procedure

We have appointed a privacy officer who can be contacted:

by post:
Privacy Officer
PO Box 42
Warrnambool VIC 3280

by email: info@onorural.com.au

You have certain rights in relation to the personal information we collect and hold about you. We will allow an individual to:

• know what personal information we maintain about you, and request a copy of your personal information, which we will provide; and
• request us to correct information we hold about you.

In addition to the information contained in this privacy policy, we may provide you with additional information concerning particular Services, or the collection and processing of personal information, upon request.

To make a complaint about how we handle your personal information, you may contact our Privacy Officer. We will respond to your complaint within a reasonable time after it is received. If you are not satisfied by our response, you may acquire further information regarding privacy from the Office of the Australian Information Commissioner.

We may make changes to this privacy policy at any time by giving notice on this page and, as far as technically and legally feasible, sending a notice to you. We recommend you check this page often, referring to the effective date of the last modification listed at the bottom.

Review

This privacy policy will be reviewed as follows:

• annually at a minimum;
• following an information security incident;
• following significant changes to our systems; and/or
• following relevant changes to the relevant privacy legislation, including the Privacy Act.