Retail Property Partners Privacy Policy

Introduction & Purpose of this Policy

Retail Property Partners (‘the Agency’) provides real estate and property services including retail leasing and advisory, retail investment sales and property management services.

We are bound by the Privacy Act and the Australian Privacy Principles (APP) which regulate the collection, use and disclosure of personal information. This Privacy Policy explains;

  • The scope of our Privacy Policy;
  • Why we collect personal information;
  • What personal information we collect;
  • How we collect and use your personal information;
  • How we disclose your personal information;
  • Your right to access your personal information;
  • Your right to correct your personal information;
  • How we protect the integrity of your personal information;
  • Your right to make a privacy complaint
  • How you can contact us regarding privacy concerns

Scope

This Privacy Policy governs all personal information collected by and provided to us and must be adhered to by all persons who access, use, process, control or otherwise deal with personal information on our behalf. This policy applies to independent contractors and job applicants, as well as individuals who provide us with personal information.

Interpretation

Personal pronouns: except where the context otherwise provides or requires:

  • The terms We, Us or Our refers to Retail Property Partners; and
  • The terms You or Your refers to any person who provides us with personal information in any form or by any means.

What is personal information?

Personal information is any information that can be used to identify you. This includes any information or an opinion about you (including information or an opinion forming part of a database), whether true or not, and no matter how the information or opinions are recorded. The information may be collected from you directly or provided to us by another party.

Why do we collect personal information?

We collect personal information from you for the following purposes:

  • To allow us to lawfully carry out our real estate and property services;
  • To enable us to provide information and deliver the services that you request from us;
  • To personalise and customise your experiences with us;
  • To help us review, manage and improve the quality of our services;
  • To communicate more effectively with you;
  • For internal administration purpose;
  • To promote and market our services which may be of interest to you;
  • When considering making offers to job applicants or for employment purposes;
  • To receive services from you or the organisation which employs you.

We may also collect, hold, use and/or disclose personal information if you consent or if required or authorised under law.

What personal information do we collect?

We collect personal information that is reasonably necessary for one or more of its functions or activities.

The type of information that we collect, and hold may depend on your relationship with us. For example:

Customer: if you are a customer of the Company, the Company may collect and hold information including your name, address, email address, contact telephone number, gender, age, profession or job title and any additional information relating to you that you provide to us directly or indirectly through our website, online presence or representatives.

Supplier: if you are a supplier of the Company, the Company may collect and hold information including your name, address, email address, contact telephone number, business records, billing information and information about goods and services supplied by you.

Candidate: if you are a candidate seeking employment with us, we may collect and hold information including your name, address, email address, contact telephone number, gender, age, employment history, references, resume, medical history, emergency contact, taxation details, qualifications and payment details.

Sensitive information: we will only collect sensitive information where you consent to the collection of the information and the information is reasonably necessary for one or more of the Company’s functions or activities.

If you feel that the personal information that we are requesting at any point is not information that you wish to provide, please feel free to raise this with us.

How do we collect and hold personal information?

We must collect personal information only by lawful and fair means. We will collect personal information directly from you if it is reasonable or practicable to do so.

We may collect personal information in a number of ways, including without limitation, by:

  • Interaction over the phone;
  • Interaction in person;
  • Interaction online;
  • Participation in surveys or questionnaires;
  • Attendance at a Retail Property Partners event;
  • Subscription to our mailing list;
  • You apply for a position with us as an employee, contractor or volunteer;
  • Application Forms;
  • Business Cards;
  • Contracts;
  • Technology that is used to support communications between us;
  • Third parties, including through publicly available information sources (which may include telephone directories, the internet and social media sites).

When we collect personal information about you through publicly available information sources, such information will be managed in accordance with the APPs.

Unsolicited personal information is personal information that we receive which we did not solicit. Unless we determine that we could have collected the personal information in line with the APPs or the information is contained within a Commonwealth record, we must destroy the information to ensure it is de-identified.

How do we use your personal information?

We will only use and disclose your personal information for purposes which are related to those identified under paragraph 4 of this policy or if we get your consent to do so and it is in accordance with this Privacy Policy and the Privacy Act.

We will not use your personal information for any purpose for which you would not reasonably expect us to use it for. Additionally, we will not disclose your sensitive information without your consent, unless there is a need to disclose such information in accordance with the Privacy Act or to comply with any other regulatory requirement.

Is personal information used for direct marketing?

We may use or disclose personal information (other than sensitive information) about you for the purpose of direct marketing (for example, advising you of new opportunities and/or services being offered by us).

We may use or disclose sensitive information about you for the purpose of direct marketing if you have consented to the use or disclosure of the information for that purpose.

You can opt out of receiving direct marketing communications from the Company by contacting us (see contact details below) or, where available, using opt-out facilities provided in communications.

What happens if you do not provide your personal information?

You are not obliged to give us your personal information. If you would like to access any of our services on an anonymous basis or using a pseudonym, we will take reasonable steps to comply with your request. However, we will require you to identify yourself if:

  • We are required by law to deal with individuals who have identified themselves; or
  • It is impracticable for us to deal with you if you do not identify yourself or elect to use a pseudonym. This might include ensuring the safety of others for whom we have responsibility.

Please be aware that your request to be anonymous or to use a pseudonym may affect our ability to provide you with the requested products or services to the same standards or at all.

When do we disclose your personal information?

We may disclose your personal information for any of the purposes for which it was collected, as indicated under paragraph 5 of this policy, or where it is under a legal duty to do so.

Disclosure will usually be internally and to related entities or to third parties such as contracted service suppliers.

Before we disclose personal information about you to a third party, we will take steps as are reasonable in the circumstances to ensure that the third party does not breach the APPs in relation to the information.

Access, correction and deletion of your personal information

If you wish to seek access to, correct or delete your personal information that we hold about you, please contact our Privacy Officer using the contact details set out below. Depending on the nature of your request, we may ask you to provide us further information in order to verify your identity and ask you to put in writing the information you require.

There may be instances where we cannot grant you access to, or are not able to delete, the personal information we hold, for example, if a legal exception applies or where granting access would interfere with the privacy of others or result in a breach of confidentiality, or where we are required to retain or cannot delete the information for legal or regulatory compliance reasons.

If that happens, we will give you written reasons for refusal (if permitted by law to do so). If you wish to update or delete the personal information that we may hold, please contact our Privacy Officer info@retailpropertypartners.com.au. If we disagree that there are grounds for amending your personal information, we will inform you of the reasons and add a note to the personal information stating that you disagree with it.

We will not charge you for requesting access to, corrections or deletion of your personal information, however we may recover reasonable expenses associated with providing you with access to your personal information.

Security of your personal information

We may hold your personal information in either electronic or hard copy form. The confidentiality and security of your information is very important to us, and we take reasonable steps to protect your personal information from misuse, interference and loss, as well as unauthorised access, modification or disclosure.

We use a number of administrative, personnel and technical measures to protect your personal information, and regularly test our security controls, however the open nature of the internet means there is always some risk that an unauthorised party might find ways to overcome our security measures, and it is not possible to guarantee the security of your personal information. You should also be aware that e-mail communications are not usually encrypted and should not be considered secure.

Where we no longer require your personal information for business or legal reasons, we will take reasonable steps to destroy or de-identify it.

Where required by applicable law, we will notify you, and the Office of the Australian Information Commissioner and/or other relevant regulatory authorities, of data breaches affecting your personal information.

Complaints

You have a right to complain about our handling of your personal information if you believe we have breached the APPs.

If you wish to make such a complaint to us, you should first contact us using the contact information below, and provide details of the incident so that we can investigate it. Your complaint will be dealt with in accordance with our complaints procedure and we will provide a response within a reasonable period.

If you are unhappy with our response to your complaint, you may refer your complaint to the Office of the Australian Information Commissioner.

Privacy Officer contact details:

The Office of the Australian Information Commissioner contact details:

How does this policy change over time?

We reserve the right to review and if necessary, change this Privacy Policy. We will post changes to this Privacy Policy on our website. This Privacy Policy was last updated on 07 September 2022.