Privacy Policy

The kinds of personal information that we collect and hold about you may include:

• identifying information, such as your name, gender and date of birth
• contact information, such as your home and / or postal address, email address, telephone number and fax number
• social media handles and other social media profile information that you make available to us or to the public
• usernames and passwords that you create when registering for an account with us
• details of any products or services that we provide to you
• records of our communications with you and other information that you send to us, such as information in correspondence between us, information you provide for a competition or promotion that we run, or information you provide when applying for a job with us
• information about your interests and preferences relating to the use of our websites, products and services or participation in any programs that we run
• technical information we collect when you access one of our websites, such as the date and time you accessed the site, the IP address you were using at the time, your path through the site (which pages you accessed), how long you spent on each page you visited, whether you were referred (via a hyperlink) to our website, where you went to from our website, the type of web browser and operating system you use or any errors encountered or problems that have occurred
• other information relevant to the particular relationship you have with us, for example:
• for visitors who are involved in an incident at one of our sites, information about the incident and your involvement
• for individual tenants and occupiers (and their guarantors), insurance details, business details, payment information (including bank account and credit card details), and other relevant financial and credit-related information
• for individual investors and shareholders, details of your shareholding, tax file numbers, and other relevant financial information
• for individual service providers, business history and references, insurance details, and other relevant financial and credit-related information

The information we collect will vary depending on the type of relationship we have with you. For example, we collect different types of information about customers, investors, tenants, and job applicants. Without this information we may not be able to properly manage your relationship with us. For example for customers we may not be able to provide you with our products or services (or with all of the features and functionality offered by our products or services) or to respond to queries or requests that you submit to us. And for job applicants, we may not be able to properly consider your job application.

We collect personal information about you in the following ways:

• when you sign up to one of our databases or register for an account with us
• when you order products or services from us
• when you submit a query or request to us
• when you enter a competition or respond to a survey or fill in a website form
• by monitoring your use of our websites and mobile applications
• using CCTV systems at our premises
• from third parties who are entitled to disclose that information to us
• when you apply for a job with us
• public sources (e.g. social media sites, Google and other websites)
• government authorities and agencies

Where we collect personal information from you, we will generally do so directly ourselves. However, in some cases we may collect personal information from a third party, such as through your representatives, contractors who provide services to us, or third parties who refer you to us because they think you may be interested in our products or services.

We use personal information that we collect about you for the following purposes:

• to verify your identity when you are dealing with us
• to enable us to provide our products and services
• to answer your queries and requests
• to comply with our legal and regulatory obligations
• to carry out market analysis and research
• to monitor use of our products and services
• to assess, maintain, upgrade and improve our products and services
• to carry out education and training programs for our staff
• to manage and resolve any legal or commercial complaints or issues
• to carry out planning and forecasting activities and other internal business processes, including assessing job applications and managing relationships with investors
• to keep you informed about our activities, including by sending out newsletters
• in order to promote public heath, including to manage the risks of disease outbreaks and pandemics
• to identify your behaviours, habits and preferences
• to notify you if you have won a competition, promotion or prize

We may from time to time use your personal information in order to send you marketing materials about products or services that we think you may be interested in (including in some cases products and services that are provided by a third party). You can opt-out of receiving marketing communications from us by contacting us at [email protected] or following the “unsubscribe” link in the communication.

We may also use and disclose your information for other purposes as authorised by you, or in accordance with your requests or instructions.

We may share personal information about you with:

• our staff (including employees and contractors) who need the information to discharge their duties
• related entities within our corporate group
• our business partners, agents and service providers (including technology survey providers and companies that operate marketing and other databases on our behalf)
• prospective purchasers of all or part of our business or shares in our company or a related entity
• professional advisers who we engage to provide advice on our business
• your duly appointed agents, representatives, brokers, builders or contractors
• other parties who are engaged to carry out works which may affect land purchased by you, any adjoining property owner or their duly appointed agents, representatives, builders or contractors
• government authorities who ask us to disclose that information, or to other people as required by law
• credit-reporting and fraud checking agencies for credit-related purposes such as assessing creditworthiness
• our tenants and occupiers, but only to the extent that it is necessary to provide you with and/or process payments for goods, services or information

In some cases the people to whom we disclose your personal information may be located overseas and may be subject to different privacy regimes. This includes international consultants and technology providers that provide services for our business. These service providers have operations in the US, the Netherlands and other countries outside Australia. We will never sell your personal information to any third party.

We use cookies to monitor and observe your use of our websites, compile aggregate data about that use, and provide you with a more effective service (which may include customising parts of our websites based on your preferences and past activities on those websites). “Cookies” are small text files created and stored on your hard drive by your internet browser software, in order to hold relevant information about the web page you are currently viewing. Most internet browsers have a facility that will allow you to disable cookies altogether – please refer to your browser’s help menu to find out how to do this. While you will still be able to browse our websites with cookies disabled on your internet browser, some website functionality may not be available or may not function correctly.

We take reasonable steps to ensure that any of your personal information which we hold is accurate, complete and up-to-date. These steps include promptly updating personal information when we are advised that the information has changed, checking our contact lists for accuracy, and providing individuals with a simple means to update their personal information.

We store personal information for as long as it is needed for the purpose for which it was collected or as required by law. We generally store the personal information that we collect in electronic databases, some of which may be held on our behalf by third party data storage providers. Sometimes we also keep hard copy records of this personal information in physical storage facilities. We use a range of physical and technical security processes and procedures to protect the confidentiality and security of the information that we hold, and we update these from time to time to address new and emerging security threats. Please note that we cannot guarantee the security of communications over the internet or over third party networks that we do not control.

If you want to access any of the personal information that we hold about you or to correct some aspect of it (e.g. because you think it is incomplete or incorrect), please contact us using the contact details set out below. To protect the integrity and security of the information we hold, we may ask that you follow a defined access procedure, which may include steps to verify your identity. In certain cases we may charge you an administration fee for providing you with access to the information you have asked for, but we will inform you of this before proceeding. There may be cases where we are unable to provide the information you request, such as where it would interfere with the privacy of others or result in a breach of confidentiality. In these cases we will let you know why we cannot comply with your request.

We try to meet the highest standards in order to protect your privacy. However, if you are concerned about the way in which we are managing your personal information and think we may have breached the Australian Privacy Principles, or any other relevant privacy obligations, please contact us using the contact details set out below. Complaints must be lodged in writing. We will deal with the matter within a reasonable time, and will keep you informed of the progress of our investigation.

If we have not responded to you within a reasonable time or if you feel that your complaint has not been resolved satisfactorily, you can contact us to discuss your concerns. You are also entitled to make a complaint to the Office of the Australian Information Commissioner (OAIC). Contact details can be found at the OAIC’s website: www.oaic.gov.au

We may make changes to this policy from time to time, to take into account changes to our standard practices and procedures or where necessary to comply with new laws and regulations. The latest version of this policy will always be available on our website.

If you need to contact us or want any further information from us on privacy matters, please contact our privacy manager at Level 2, 100 Dorcas Street, South Melbourne VIC 3205 or [email protected]