Privacy Policy

Ipoh Group Privacy Policy

1. Introduction

About Ipoh Group

Ipoh Property Pty Limited ACN 086 673 627(being the trustee of Strand Property Trust, Galeries Property Trust and QVB Retail Trust) and Ipoh Management Services Pty Limited ACN 060 149 126 (together known as "Ipoh Group") are a specialist retail property, investment and management group. Ipoh Group's major assets and businesses consist of Sydney CBD shopping centres including the Strand Arcade, The Galeries, Queen Victoria Building, and Chifley Plaza (together as "Centres").

For more information about Ipoh Group, please visit our website www.ipoh.com.au.

Protecting your privacy

Ipoh Group is committed to the protection of your personal information. Our Privacy Policy is designed to protect the personal information you provide to us via our services available to our customers, retail tenants, commercial tenants, suppliers, contractors, employees or prospective employees ("Ipoh Services"). This document will outline our practices in connection with this information and disclose how your information is collected, protected, used and shared.

By using Ipoh Services, you agree to the terms and conditions outlined in this Privacy Policy. We also recommend that you visit our website regularly as we update this Privacy Policy from time to time. Additional conditions may be accepted by you upon your further interactions with us - for example when you complete a competition entry form, or receive terms and conditions specific to that promotion.

As of 12 March 2014, we are committed to the Australian Privacy Principles which set out a number of guidelines for the handling of personal information. To find out more about the changes to the Privacy Act 1988 (Cth) visit the Office of the Australian Information Commissioner website www.oaic.gov.au.

2. What information we collect, how and why

Customers

Ipoh Group collects the personal information from customers in order to provide our services, including websites, mobile sites, applications, Wi-Fi, competitions and email newsletter subscriptions (herein known as the "Centre Services").

We will ensure the registration information is collected only by lawful and fair means. The information collected is reasonably necessary for us to facilitate your access to Centre Services and the functionality required. These services and functionalities include:

Information we collect includes:

The information collected is used for the following purposes:

You acknowledge that we may send you emails which constitute Commercial Electronic Messages for the purposes of the Spam Act 2003 (Cth) and you give your consent to the receipt of all such emails. You can withdraw your consent any time by clicking "unsubscribe" in our emails to you.

The information we collect from you is generally on behalf of Ipoh Group. However, in some cases information may be collected through third parties including information service providers or through our Wi-Fi service provider.

In addition to the above-mentioned information, other information we may collect about you from our Wi-Fi service provider include:

By signing up to use the Free Wi-Fi services we provide at our Centres, you consent to us collecting your personal information through our Wi-Fi service provider. The information collected is reasonably necessary for us to facilitate your access to Centre Services and the functionality required.

Retail or Commercial Tenants

Ipoh Group may collect the following information from you as our retail or commercial tenants or the director, secretary or operator of our retail or commercial tenants:

We will ensure the information is collected only by lawful and fair means. The information collected is reasonably necessary for us to facilitate our relationship with you as landlord and tenant.

The information collected is used for the following purposes:

By submitting your Lease Application Form and supporting documents to us, you consent to us storing your personal information in our system for future leasing use.

Suppliers

If you, or a company you work for, supplies goods or services to Ipoh Group, we may collect the following information about you in connection with the provision of those goods or services:

We will ensure the information is collected only by lawful and fair means. The information collected is reasonably necessary for us to facilitate our business relationship with you for the supply of goods or services.

By submitting your information to us, you consent to us storing your personal information in our system for future use.

Contractors

If you, or a company you work for, is contracted to provide services or to carry out works for Ipoh Group, we may collect the following information about you:

We will ensure the information is collected only by lawful and fair means. The information collected is reasonably necessary for us to facilitate our business relationship with you for the contracting services and works carry out by you.

By submitting your information to us, you consent to us storing your personal information in our system for future use.

Employees or potential employees

Ipoh Group may collect the following information from you as our employees or potential employees:

We will ensure the information is collected only by lawful and fair means. The information collected is reasonably necessary for us to facilitate our recruiting process and/or our employment relationship with you.

By submitting your resume or CV to us, you consent to us storing your personal information in our system for future recruitment use.

Ipoh Group discloses that continuous and ongoing camera surveillance ("CCTV") is used in the Centres including the workplace of Ipoh Group's employees. The surveillance is recorded and is carried out for the purposes of ensuring the safety of the users of the Centres. CCTV recordings are provided to investigators, insurers, legal advisors, police or other relevant authorities when incidents occur.

Third Parties

Ipoh Group uses cookies to collect certain information about your visits to our websites. This is in order to facilitate the sampled reporting of demographics and interests of our visitors within Google Analytics, which is used to help us to better understand how you use our websites so that we may improve your experience with us for e.g. by providing you with better services and more relevant content. This feature is based on Display Advertising e.g., Google Analytics Demographics and Interest Reporting, and prohibits the collection of personally identifiable information by Google Analytics and its related services. We will not facilitate the merging of personally-identifiable information with non-personally identifiable information collected through any Google advertising product or feature unless we have your opt-in consent to that merger.

We may contract third party service providers to assist us with understanding our site visitors through conducting data analysis; these service providers are not permitted to use this information on our behalf except to help us conduct and improve our business. In the unlikely event that third parties will support our websites by serving advertisements, these third parties may also use these technologies to collect similar information. You can opt out of this feature by downloading the Google Analytics Opt Out browser add-on. Further information regarding Google Analytics and its Data Privacy and Security are available on their website www.google.com/analytics/learn/privacy.html?l=DE

Information collected by these third parties includes:

Information is also collected through third party Social Media for the purpose of providing you with the ability to use our services, for example, to post a comment, share an article, enter a competition or share a competition on your social media networks. When you access Centre Services through third party Social Media services, you will receive a request to authorise or not authorise Ipoh to collect, store, use and disclose any personal information collected.

Information collected by these third parties includes:

Ipoh Group may also receive your information from our promotional partners, generally through co-branded activities including competitions. When this information is collected through our third party partners an opt-in will be made available for this data to be provided to us for the purposes of communicating with you, and will be communicated in any applicable Terms and Conditions.

If Ipoh Group receives any unsolicited personal information, we will, after a reasonable period, determine whether the information is within our collection criteria. If not, we will destroy the information or ensure that the information is de-identified as soon as practicable provided that it is lawful and reasonable to do so.

Subject to the relevant privacy regulations, we will not collect your sensitive information (for example, information relating to your health, racial or ethnic background or criminal records), unless we have obtained your consent and such sensitive information is reasonably necessary for one or more of Ipoh Group's functions and activities.

We respect your right to exercise the option of not identifying yourself or to use a pseudonym when dealing with us. However, where applicable laws or practical considerations require you to identify yourselves through the provision of personal information, we will not be able to accommodate anonymity or the use of pseudonyms.

Who collects the information

The information collected about you which is held or used in relation to the Ipoh Services and Centre Services may be collected by Ipoh Group and its related entities, comprising of:

Each entity listed above is referred to as 'we', 'our', 'us' or 'Ipoh Group' in this Privacy Policy.

If we collect your personal information through a third party or someone other than yourself, we will take reasonable steps to notify you that we have collected your information and the circumstances of that collection.

3. The use and disclosure of your personal information

How we use your information

Ipoh Group may use your personal information in a number of ways including:

Cookies

The information collected through cookies, such as demographic and interest information will be used to help us compile aggregate data about site traffic and site interaction, so we can aim to help offer you better online experiences, content and tools in the future.

Disclosure of your information to third parties

We may disclose the information you provide to third parties where this is permitted by law including for any of the purposes mentioned in Section 3. Generally, these third parties are co-branded service partners either appointed external companies and consultants.

At times, we may offer co-branded services such as competitions or promotions in partnership with a third party. These co-branded services may be hosted on Ipoh Group's or a third-party's service and we may share the information you have submitted in connection with the co-branded service with the third party. However, this information is only obtained and shared with an elected third party with your express consent.

On occasion we may also hire companies or consultants to help us in promoting the retailers in our shopping centres including the distribution of catalogues. In these instances, we need to share your information with them, but only to the extent of the delivery of the promotional information or catalogues.

Third parties include:

Sending information overseas

At times it may be necessary for you to send your information overseas including to our service providers or other third parties who operate or hold data outside of Australia that are relevant to our business and activities. When we do this, we take reasonable steps to ensure that data is handled securely and appropriately with strict procedures in place.

In the unlikely event that we ever need to disclose your personal information to overseas recipients, we will notify you. We will take reasonable steps to ensure that the overseas recipients do not breach the relevant Australian Privacy Principles in relation to your personal information so disclosed.

Generally, information sent and held overseas pertains to back up servers and data centres, which are protected by strict security safeguards. Our additional back up servers and data centres may be located outside of Australia including Singapore, United States of America or other countries through Cloud technologies.

The only other time we will disclose your information is:

You have the right to contact us and request not to receive any direct marketing communications or request us not to disclose your personal information to other organisations for the purposes of direct marketing. We will provide you with the source of your information upon your request. If you wish to make any of the above-mentioned requests relating to direct marketing, please contact our Privacy Officer:

Email: This email address is being protected from spambots. You need JavaScript enabled to view it.
Mail: c/- Privacy Officer, Ipoh Group,
Level 4, Queen Victoria Building,
455 George St, Sydney NSW 2000
Phone: (02) 9265 6800
Fax: (02) 9264 8862

Advertisers and partners

Our websites contain links to other websites of advertisers and/or partners. Once you click on the links and leave our websites, we are not responsible for the privacy policies on other websites and their use of your information. For your protection, we recommend that you read the privacy statements on each website visited that collects personal information.

4. Keeping your information secure

How your information is stored

We take the protection of your information seriously and take every reasonable step to ensure that any personal details submitted to us are protected both online and offline. Your personal information, such as your registration details for email newsletters, are held in secure databases. Ipoh Group and our appointed third party services use commercially reasonable means to safeguard your information against misuse, interference, loss, theft or unauthorised use. We review our security safeguards on a regular basis and implement improvements where necessary to protect from misuse, interference and loss, and from unauthorised access modification or disclosure.

However, no data transmission over the internet can be guaranteed as completely secure. So while we strive to protect such information, we cannot guarantee or warrant the security of any information transmitted to us and individuals do so at their own risk.

For financial information, additional security measures will be implemented such as a secure payment gateway to help safeguard your financial information.

Security safeguards we employ include:

When electronic data is transferred or sent outside of Ipoh Group, we generally use dedicated secure networks or encryption.
We limit access by requiring use of individual identifiers and passwords.

Security Safeguard Details
Staff education Staff are trained in relation to their obligations with regard to your information. Access to our databases and your information is limited to a select number of staff requiring use of individual identifiers and passwords that adheres to strict data handling guidelines.
Security precautions with information transfers

When information is transferred or sent to third parties that handle or store data, we take reasonable steps to ensure that appropriate and secure data handling arrangements are in place.

We have firewalls, intrusion detection systems, virus scanning tools, and internal network security to protect against unauthorised persons and viruses accessing our systems.

System security

When electronic data is transferred or sent outside of Ipoh Group, we generally use dedicated secure networks or encryption.

We limit access by requiring use of individual identifiers and passwords.

Destroying data when no longer required Where practical, we keep information only for the period required.
Outsourced arrangements We require all of our Australian service providers to have in place a privacy policy that complies with applicable Australian law.

 

Once the information you provided to us is no longer required for us to provide any of the Ipoh Services, we will take reasonable steps to destroy the information or to ensure that the information is de-identified provided that it is lawful for us to do so.

5. How to access, correct, update or remove the information you have given us

Can I access my information?

The information you provide to us is kept secure and only accessed by persons authorised by us. You can ask for access to your information by contacting us and we will endeavour to give you access to the information that you have provided to us.

Is there a fee?

There is no fee charged by Ipoh Group for accessing your information.

How long does it take to receive access to my information?

We endeavour to respond to your request within a reasonable time frame. Before we can provide you with your information we will need to confirm you are appropriately authorised to access the information, which may include an identity verification process. If we are unable to provide access as requested, we will provide a written notice setting out the reason for the refusal.

Can I change/update my information?

It is important that we have your correct details, such as your current address and contact number, to provide you with the Ipoh Services you have requested. You can check or update your information by contacting our Privacy Officer.

We endeavour to take reasonable steps to comply with your request to correct any personal information if we are satisfied that the information is inaccurate, out of date, incomplete or misleading. We will ensure that we notify any third parties if any incorrect information has previously been disclosed to them.

If we are unable to correct any personal information as requested by you, we will provide a written notice setting out the reason for the refusal.

If you wish to update your details or stop receiving promotional or marketing offers from Ipoh Group, please contact our Privacy Officer:

Email: This email address is being protected from spambots. You need JavaScript enabled to view it.
Mail: c/- Privacy Officer, Ipoh Property Pty Limited,
Level 4, Queen Victoria Building,
455 George Street, Sydney, NSW 2000
Phone: (02) 9265 6800
Fax: (02) 9264 8862.

How you can opt out

If you wish to stop receiving promotion materials or email newsletters, you can edit your details or unsubscribe at any time by following the opt-out instructions at the bottom of each email newsletter. There is no fee to opt out from email newsletters.

If you would like to lodge a complaint

If you believe we have breached our privacy policies in any way, or if you would like to discuss any issues regarding this Privacy Policy, please contact us and we will try to satisfy any privacy concerns you have as soon as reasonably practicable.

Please contact our Privacy Officer at:

Email: This email address is being protected from spambots. You need JavaScript enabled to view it.
Mail: c/- Privacy Officer, Ipoh Property Pty Limited,
Level 4, Queen Victoria Building,
455 George Street, Sydney NSW 2000
Phone: (02) 9265 6800
Fax: (02) 9264 8862

6. Further information about privacy

For more information about privacy, the Australian Privacy Principles and the Privacy Act can be found directly from the Office of the Australian Information Commissioner at the website www.oaic.gov.au or through the contacts below.

Phone: 1300 363 992
Email: This email address is being protected from spambots. You need JavaScript enabled to view it.
Post: GPO Box 5218,
Sydney NSW 2001

7. Updates to Privacy Policy

Ipoh Group reserves the right to make updates to this Privacy Policy at any time. Any changes made to this Privacy Policy will become effective immediately and we will notify you of these changes through publishing the most updated policy on our websites. The Privacy Policy can be viewed on our websites free of charge.

If you would like to view or obtain a copy of the Privacy Policy in a different format, please contact our Privacy Officer at:

Email: This email address is being protected from spambots. You need JavaScript enabled to view it.
Mail: c/- Privacy Officer, Ipoh Property Pty Limited,
Level 4, Queen Victoria Building,
455 George Street, Sydney NSW 2000
Phone: (02) 9265 6800
Fax: (02) 9264 8862

Last updated: May 2016

 

 

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