GENERAL
Clarence Property Corporation Limited (we, us or our) recognise that your privacy is important and we are committed to protecting the personal information we collect from you. The Privacy Act 1988 (Cth) (Privacy Act), Australian Privacy Principles and registered privacy codes govern the way in which we must manage your personal information. This policy sets out how we collect, use, disclose and otherwise manage your personal information.
COLLECTION
Types of information collected
We may collect and hold personal information about you, that is, information that can identify you and is relevant to providing you with the services and products you are seeking. The kinds of information we typically collect include name, gender, address, phone number, email address, facsimile number, bank account details, tax file numbers or other information relevant to providing you with the services and products you are, or someone else you know, is seeking.
Additional information may be collected if you are a tenant or prospective tenant in one of our properties, an investor, job applicant, visitor to one of our properties, or user of our websites or Wi-Fi connections.
Method of collection
Personal information will generally be collected directly from you through the use of any of our standard forms, over the internet, via email, or through a telephone conversation with you. We may also collect personal information about you from third parties acting on your behalf (for instance, financial advisers).
Where you connect to Wi-Fi networks at our properties, in addition to collecting personal information, Clarence Property and/or our third-party service providers may automatically collect data from the devices connected to our network, such as usage, location, centre arrival and departure time.
There may, however, be some instances where personal information about you will be collected indirectly because it is unreasonable or impracticable to collect personal information directly from you. We will usually notify you about these instances in advance, or where that is not possible, as soon as reasonably practicable after the information has been collected.
Purpose of collection
The personal information that we collect and hold about you, depends on your interaction with us. Generally, we collect, use and hold your personal information if it is reasonably necessary for or directly related to the performance of our functions and activities and for the purposes of:
- providing services and products to you or someone else you know;
- providing you with marketing information, including newsletters and emails about other services and products we offer which may be of interest to you, including future investment opportunities;
- responding to your enquiries;
- facilitating our internal business operations, including the fulfilment of any legal requirements; and
- analysing our services and products with a view to improving those services and products.
Except as otherwise permitted by law, we only collect sensitive information about you if you consent to the collection of the information and if the information is reasonably necessary for the performance of our functions, as set out above.
Failure to provide information
If the personal information you provide to us is incomplete or inaccurate, we may be unable to provide you, or someone else you know, with the services and products you, or they, are seeking.
Internet users
If you access our website, we may collect additional personal information about you in the form of your IP address or domain name. Our website may contain links to other websites. We are not responsible for the privacy practices of linked websites and any linked websites are not subject to our privacy policies and procedures.
Our website uses cookies. The main purpose of cookies is to identify users and to prepare customised web pages for them. Cookies do not identify you personally, but they may link back to a database record about you. We use cookies to monitor usage of our website and to create a personal record of when you visit our website and what page you view so that we may serve you more effectively.
Our website uses analytics, provided by Google Inc. (Google) and Zoho Corporation (Zoho). Analytics uses cookies and JavaScript code that enables analysis on your usage of our website and data will be transmitted to and stored on Google or Zoho’s servers. Your data may be used to compile reports on your usage of our website and provide services relating to website activity and internet usage. We will use the analytics data collected to improve the functionality of our website and services.
Visitors to our properties
Our properties and sites may use camera surveillance systems (CCTV) and/or other camera and visitor management systems to maintain the safety and security of the assets and individuals working at or visiting our properties. We will only use CCTV / camera footage or still images to personally identify you for security, risk management, loss prevention and/or incident investigation purposes. Images collected by CCTV and by other means may be provided to law enforcement bodies and insurers. If you are involved in an incident, we may ask for medical information and information from other consultants and third parties.
USE AND DISCLOSURE
Generally, we only use or disclose personal information about you for the purposes for which it was collected (as set out above). We may disclose personal information about you to:
- our related entities to facilitate our and their internal business processes;
- third party service providers who assist us in operating our business, and providing services to you such as:
- third parties who assist with transactions, including financial institutions and payment service providers;
- third parties who assist with the business, including information technology and marketing service providers,
- any purchasers or potential purchasers of building or land owned by us; and
- injury management services, insurers, regulatory authorities or government bodies; and
- our related entities and other organisations with whom we have affiliations, so that those organisations may provide you with information about services, products, future investment offers, upcoming projects and various promotions.
These third party service providers may not be required to comply with our privacy policy.
In some circumstances, the law may permit or require us to use or disclose personal information for other purposes (for instance, where you would reasonably expect us to and the purpose is related to the purpose of collection).
DISCLOSURE OF PERSONAL INFORMATION OVERSEAS
We are likely to disclose your personal information overseas. For instance, our related bodies corporate, third party service providers or other recipients may be based overseas or may use infrastructure outside Australia, including the USA, the EEA, Asia and India. We take reasonable steps to ensure information disclosed overseas is handled with this policy and relevant law.
SECURITY
We store your personal information in different ways, including in paper and electronic form. The security of your personal information is important to us. We take reasonable measures to ensure your personal information is stored safely to protect it from misuse, loss, unauthorised access, interference, modification or disclosure, including electronic and physical security measures.
ACCESS AND CORRECTION
You may request access to personal information we hold about you, by making a written request. We will respond to your request within a reasonable period. We may charge you a reasonable fee for processing your request (but not for making a request for access).
We may decline a request for access to personal information in circumstances prescribed by the Privacy Act and if we do, we will provide you with a written notice that sets out the reasons for the refusal (unless it would be unreasonable to provide those reasons).
If, upon receiving access to your personal information, or at any other time, you believe the personal information we hold about you is inaccurate, incomplete or out of date, please notify us immediately. We will take reasonable steps to correct the information so that it is accurate, complete and up to date.
If we refuse to correct your personal information, we will provide you with a written notice that sets out the reasons for our refusal (unless it would be unreasonable to provide those reasons) and provide you with a statement regarding the mechanisms available to you to make a complaint.
COMPLAINTS AND FEEDBACK
If you wish to make a complaint about a breach of the Privacy Act, Australian Privacy Principles or a privacy code that applies to us, please contact us as set out below and we will take reasonable steps to investigate the complaint and respond to you. If you are not happy with our response, you may complain directly to the Australian Privacy Commissioner. To lodge a complaint, visit the ‘Complaints’ section of the Information Commissioner’s website, located at http://www.oaic.gov.au/privacy/privacy-complaints, to obtain the relevant complaint forms, or contact the Information Commissioner’s office.
If you have any questions or concerns about this privacy policy or the way we handle your personal information, please contact us at:
Street address: Epiq Marketplace, Level 1 Suite 4-5, Corner Hutley & Snapper Drive, Lennox Head NSW 2478
Email: enquiry@clarenceproperty.com.au
Telephone: 1300 382 862
MORE INFORMATION
For more information about privacy in general, you can visit the Australian Privacy Commissioner’s website at www.oaic.gov.au.