Haben Property Fund Pty Ltd ACN 139 914 775, and its affiliate shopping centres is committed to being transparent about our privacy practices and protecting your personal information.
We recognise that any personal information we collect about you will only be used for the purposes indicated in our policy, where we have your consent to do so, or as otherwise required or authorised by law. It is important to us that you are confident that any personal information we collect from you or that is received by us will be treated with appropriate respect ensuring protection of your personal information.
Our commitment in respect of personal information is to abide by the Privacy Act 1988 (Cth), the Australian Privacy Principles and any other relevant law.
When we refer to personal information, we mean information from which you are, or may reasonably be, identified. This information may include (but is not limited to) name, date of birth, phone number, email address, address.
It is not common practice for us to collect other sensitive information (such as information about your religion, trade union membership, political opinion, sexual preference or criminal record). We will only collect sensitive information about you with your consent.
How and why we collect your personal information
We collect and receive personal information to conduct business operations, deliver products and services, and notify you of our products and services.
By providing personal information to Haben Property Fund, you consent to the collection, use and disclosure of your personal information in accordance with this Policy and any other arrangements that may apply.
Haben Property Fund collects information from shopping centre customers in several ways, including:
- Customers provide us with their contact details when entering competitions, registering for events, or signing up to email newsletters. Haben Property Fund collects these details to contact competition winners and to inform customers about in-centre events, offers and promotions. Customers have the option to opt out from receiving this information at any time.
- Customers provide us with contact information when hiring equipment such as mobility scooters, kiddy cabs, etc. Haben Property Fund collects this information to ensure that there is a record of the hirer and to enable customers to be informed about in-centre upcoming events, offers and promotions.
- Customers attending Haben Property Fund’s shopping centres and car parks are under video and camera surveillance. When entering the shopping centres and car parks, customer’s personal information, car licence plate details and images may be collected by a third-party contractor who is contracted to Haben Property Fund, and Haben Property Fund may also collect customers personal information and images from third parties (for example, police or retailers). This information may be used by Haben Property Fund in connection with the management and security of its shopping centres. This information may be provided to law enforcement and government bodies, Haben Property fund staff and subcontractors, third parties who provide Haben Property Fund with services from time to time, insurers, and retailers for those purposes.
- Customers parking in Haben Property Fund shopping centre car parks with a ticketless parking system consent to provide us with their car licence plate details and, in some circumstances, other information including name, email address and telephone number. These details are used for providing and managing car parking and related services at our shopping centres and for measuring and analysing car parking dwell times and shopper behaviour.
If you, or a company you work for, supplies goods or services to Haben Property Fund and its affiliates, Haben Property Fund may collect personal information about you in connection with the provision of those goods or services, either directly from you or from that company. This information may include your name, date of birth, contact information, and any other information you provide, or is provided on your behalf, as part of our induction and compliance processes (in-centre and/or online). This information will be used for managing the provision of those good or services.
Employees or potential employees
If you are employed by Haben Property Fund, or are seeking employment with Haben Property Fund, we may collect personal information about you in connection with your employment. This information may include your name, date of birth, contact information, and any other information you provide, or provided on your behalf, as part of our induction and compliance processes (in-centre and/or online). This information will be used for the purposes of our recruitment process and, if successful, managing your employment, in accordance with the requirements of the Privacy Act 1988 (Cth).
Disclosure of personal information
To enable us to maintain a successful business relationship with you, we may disclose your personal information to:
- organisations that provide products or services used or marketed by us, including intermediaries (such custodians and trustee companies, and administrative services providers);
- other individuals or companies authorised by you.
By providing us with your personal information, you consent to us disclosing your information to such entities without obtaining your consent on a case-by-case basis.
Sometimes we are required or authorised by law to disclose your personal information. Circumstances in which we may disclose your personal information would be to a Court, Tribunal or law enforcement agency in response to a request or in response to a subpoena or to the Australian Taxation Office.
We may from time to time transfer personal information outside Australia in accordance with the Privacy Act to countries whose privacy laws do not provide the same level of protection as Australia’s privacy laws. For example, we may use cloud storage and IT servers that are located offshore.
Updating your personal information
It is important to our relationship that the personal information we hold about you is accurate and up to date. During the course of our relationship with you, we will ask you to inform us if any of your personal information has changed.
If you consider that any information we hold about you is incorrect, you should contact us to have it updated. We will generally rely on you to assist us in informing us if the information we hold about you is inaccurate or incomplete.
Access to your personal information
We will provide you with access to the personal information we hold about you, subject to limited exceptions in the Privacy Act as outlined below. You may request access to any of the personal information we hold about you, at any time.
To access personal information that we hold about you, use the contact details specified below. We may charge a fee for our reasonable costs in retrieving and supplying the information to you.
Denied access to your personal information
There may be situations where we are not required to provide you with access to your personal information. For example, such a situation would be information relating to an existing or anticipated legal proceeding with you, or if your request is vexatious.
An explanation will be provided to you if we deny you access to your personal information we hold.
Business without identifying you
In most circumstances it will be necessary for us to identify you in order to successfully do business with you, however, where it is lawful and practicable to do so, we will offer you the opportunity of doing business with us without providing us with personal information. Such a situation would be where you make general inquiries about interest rates or current promotional offers.
Protection of personal information
We will take reasonable steps to protect your personal information, including your credit-related personal information, by storing it in a secure environment, and when the information is no longer needed for any purpose for which the information may be used or disclosed, it will be destroyed or permanently de-identified.
We will also take reasonable steps to protect any personal information from misuse, loss and unauthorised access, modification or disclosure.
Further information and complaints
You may request further information about the way we manage your personal information or lodge a complaint by contacting our Privacy Officer(s) on the contact details below.
We will deal with any complaint by investigating the complaint, and providing a response to the complainant within 15 business days, provided that we have all necessary information and have completed any investigation required. In cases where further information, assessment or investigation is required, we will seek to agree alternative time frames with you.
If you feel your complaint has not been satisfactorily addressed in the first instance, or that it is taking too long to resolve, you may contact the Office of the Australian Information Commissioner (OAIC) to have the complaint heard and determined. To contact the OAIC call 1300 363 992 or find them online at www.oaic.gov.au.
You can contact us by calling us on +61 2 9302 5900 or by writing to: The Privacy Officer Haben Property Fund Pty Ltd Suite 3.05, Level 3 203-233 New South Head Rd Edgecliff NSW 2027
We are constantly reviewing all of our policies and attempt to keep up to date with market expectations. Technology is constantly changing, as is the law and market practices.