The Precision Group (we, us, our) is a group of Australian private property investment companies, and includes the companies listed at http://www.precision.com.au/precision-list-of-companies.
We own and manage a range of commercial property and shopping centres in Australia and New Zealand and are accordingly bound by:
- the Australian Privacy Principles (APPs) in the Privacy Act 1988 (Cth) in Australia; and
- the Information Privacy Principles (IPPs) in the Privacy Act 1993 (NZ) in New Zealand, (Privacy Laws).
We understand the importance of, and are commited to, protecting your personal information.
1. How we collect your personal information
We will collect and hold your personal information in a fair and lawful manner, and not in an intrusive way. Where it is reasonably practical to do so, we will collect your personal information directly from you. We may collect personal information through some of the following means:
- when you access or use one of our centres or car parks (as a result of video surveillance and location sensing devices);
- when you enter competitions or subscribe to our email or mobile services and newsletters, or access and use our Website, social media or mobile applications;
- when you purchase and use a gift card;
- when you communicate with us via telephone, email or facsimile, or otherwise correspond with us (whether in writing or electronically);
- when you submit an application form relating to a proposed tenancy or the provision of services as a supplier or contractor;
- in the course of administering, performing or managing contracts with our service providers or other third parties;
- when you provide us with information in response to direct marketing or customer satisfaction and market research surveys and questionnaires;
- in the course of administering or providing any of our services;
- from credit reporting bodies;
- when you apply for employment with us; and
- as otherwise required to manage our business.
However, in some cases (for instance, in relation to applications for tenancies in our centres or where there is an incident in one of our centres or car parks), we may also collect personal information from publically available sources and third parties, such as law enforcement agencies, emergency services, government bodies, retailers in our centres, insurers, suppliers, recruitment agencies, referees, credit agencies, banks, contractors and our other clients and business partners.
If we collect personal information from a third party we will, where appropriate, request that the third party inform you that we are holding such information, how we will use and disclose it, and that you may contact us to gain access to, correct and update the information.
2. Types of personal information we collect
The types of personal information we may collect and hold about you will depend on a range of circumstances, including who you are and which of our services and products you are looking to access or use. For instance, we generally need to collect more personal information about our tenants than about the customers of our centres.
Generally, the personal information we collect can include (but is not limited to):
In addition, when you access or use:
- your name, date of birth, age, gender, postcode and other demographic information;
- your contact details, such as your email, postal and work addresses and phone numbers;
- information to verify your identify, such as your driver's licence number or passport details;
- billing and financial information (such as your banking or payment information, credit card number, cardholder name and expiration date);
- information relating to your creditworthiness (including the credit information described in section 4 below);
- information about properties you own;
- if applicable, employment information, such as job application information;
- information relating to incidents connected to our business, such as personal injuries, misconduct, breach of conditions or unlawful activity;
- any information which is publicly available, including on a third party social media service; and
- any other information you provide us from time to time, including your preferences or opinions relating to our products, and information relating to surveys, competitions, enquiries or complaints.
- one of our centres or car parks, we may collect details of the vehicle you were driving and its number plate, and any other details captured by our video surveillance, or the video surveillance of retaillers in our centres, including images of you and your vehicle
- our Website, we may collect non-identifiable information about your hardware, software and activities, which can include your IP address, browser type, domain names, pages you accessed and the dates and times you accessed them, how long you spent on those pages and our Website, and referring website addresses (including through the use of 'cookies' as described in section 9 below);
- our Wi-Fi Service, we may collect:
- demographic information, and other information about your preferences as a shopper at one of our centres, including any information you provide us in response to survey questions;
- information about the system or device which connects to the Wi-Fi Service, including the type of system or device, its name, MAC address, location and movement data, and other information relating to operating systems, browser types, IP addresses and data usage; and
- any information transmitted or received by the system or device which connects to the Wi-Fi Service, including when it connected and disconnected, periods of inactivity, which website pages it visited, the date and time it accessed them and the time it spent on each page; and
- our Wi-Fi Service using an account or using an email that is associated with an account, with a third party social media service, we may collect any personal information you have permitted that social media service to share, such as your name, account ID, date of birth, gender, age, location, pictures, email address, followers or friends lists and any other information which is publicly available on that social media service.
Also, when you enter competitions or subscribe to our email or mobile services and newsletters, your name and address are automatically entered into our database and you authorise us to contact you by email including to inform you about products and services, offers, events, activities and promotions relating to our centres
If you do not provide us with the personal information we request from you, we may not be able to supply the products or services you have requested, or we may be restricted in the way we supply those products or services.
3. Our purposes for handling your personal information
We collect and use personal information about you primarily to supply you with the products and services you order from us and our related companies. We do not sell, rent or lease your personal information to third parties.
As a general rule, we only process personal information for purposes that would be considered relevant and reasonable in the circumstances. For instance, if personal information is obtained in connection with an application for a tenancy, we would generally use that personal information to assess your suitability as a tenant, and your ability to perform your obligations.
In particular, we collect, hold, use and disclose personal information:
In addition, where we have collected personal information as a result of you accessing or using the Wi-Fi Service, this personal information is collected, and we may hold, use and disclose this personal information:
- for direct marketing purposes, including to prepare and provide marketing information about our retailers, our products and services and those of our related companies and other organisations, and details of offers, events, activities, promotions and other information relating to our centres in accordance with Privacy Laws and section 7 below;
- to offer and provide you with our products and services, or request feedback about products and services you have received;
- to manage and administer those products and services;
- to conduct business planning and research into our customers and retailing trends, including
- analysing general statistical information regarding the use of our Website or the Wi-Fi Service; and
- measuring and analysing time spent in our centres and car parks and shopper behaviour in order to improve our centres and car parks
- in the case of credit information, to assess your creditworthiness for the purposes of an application by you for commercial credit;
- to communicate with you;
- to comply with our legal and regulatory obligations
- in connection with the management and security of our centres and car parks, including to assess and action security and other incidents relating to our centres, such as circumstances where we suspect fraud or other illegal activity (which may involve disclosure of personal information to law enforcement agencies, emergency services, government bodies, retailers in our centres and insurers);
- for any purpose disclosed to you and to which you have consented;
- for any purpose that you would otherwise reasonably expect; and
- otherwise to appropriately manage and conduct our business, including performing administrative functions such as billing and accounts and records management.
- for direct marketing purposes, including sending notifications to your device (including via push notifications, video interstitials, email or SMS) about our retailers, our products and services and those of our related companies and other organisations, and details of offers, events, activities, promotions and other information relating to our centres in accordance with Privacy Laws and section 7 below;
- for research and marketing purposes, including tracking searches made, or websites accessed, using our Wi-Fi Service in order to facilitate direct marketing, compiling usage statistics and conducting analytics on shopper demographics and preferences;
- for the purposes of providing the Wi-Fi Service;
- to initiate, or assist with, an investigation into any use of the Wi-Fi Service in connection with any unlawful act or purpose; and
We may disclose personal information to our related companies, agents and organisations or to third parties such as our contractors, suppliers, partners, retailers, insurers, service providers (including organisations that provide us with technical and support services), or our professional advisors or consultants, where permitted by Privacy Laws. We may also disclose personal information to entities seeking to acquire all or part of our business, or other entities with your consent. If we disclose information to a third party, we generally require that the third party protect that information to the same extent that we do.
4. Credit reporting
From time to time, where permitted by the Privacy Laws, we may collect, hold, use and disclose certain credit and credit eligibility information about you, including:
- your name, current and previous addresses, driver's licence number, date of birth and employer;
- the fact that you have applied to us for one of our products or services and any credit limit on your account;
- your repayment history, including the amount of any payments due to us which are overdue for at least sixty days, and when steps have been taken by us to recover those overdue payments;
- where an overdue payment has been previously reported, advice that the payment is no longer overdue;
- default information, including cheques or credit card payments which have been dishonoured;
- court judgments or bankruptcy orders made against you;
- if, in our opinion, you have committed a serious credit infringement;
- when we cease to provide products or services to you; and
- other credit information that we are able to derive from the above information.
In particular, this credit information may be collected from, or disclosed to, credit reporting bodies. You authorise us to disclose such information to credit reporting bodies to assist them with assessing your creditworthiness for the purposes of us considering an application by you for commercial credit. You also authorise us to collect and use information from credit reporting bodies for the same purpose. We reserve the right to refuse or cancel the supply of products or services on the basis of a credit assessment of you.
If you believe you have been, or are likely to be, a victim of fraud you have the right to request that a credit reporting body not use or disclose your credit information. You can also request that a credit reporting body not use your credit information for the purposes of pre-screening or direct marketing by a credit provider.
5. Overseas transfers of personal information
We may disclose personal information, including credit information, between our related bodies corporate in Australia and new Zealand, and to Skyfii in accordance with section 1 above, where permitted under Privacy Laws.
By providing your personal information to us, you consent to us disclosing your personal information to any such overseas recipients for purposes necessary or useful in the course of operating our business and agree that APP 8.1 will not apply to such disclosures. For the avoidance of doubt, in the event that an overseas recipient breaches the APPs, that entity will not be bound by, and you will not be able seek redress under, the Privacy Act 1988 (Cth).
If you do not want us to disclose your information to overseas recipients, please let us know.
6. Direct Marketing
Like most businesses, marketing is important to our continued success. We believe we have a unique range of products and services that we provide to customers at a high standard. We therefore like to stay in touch with customers and let them know about new opportunities.
From time to time we may contact you with information about new products, services and promotions either from us, or from third parties which may be of interest to you. In these situations, your personally identifiable information is not transferred to the third party. We will not disclose your personal information to third parties for marketing purposes without your consent.
7. How you can unsubscribe
You may opt out at any time from receiving communications from us that are not account related or legally required by making a request in writing to our Privacy Officer at PrivacyMatters@precision.com.au if you are in Australia or email@example.com if you are in New Zealand, or by using the 'unsubscribe' function contained in every email you receive from us.
9. Protection of personal information
We may hold personal information as either secure physical records, electronically on our intranet system, in cloud storage or on third party servers.
We maintain appropriate physical, procedural and technical security for our offices and information storage facilities so as to prevent any loss, misuse, interference, unauthorised access, disclosure, or modification of personal information, including when we dispose of personal information.
We further protect personal information by restricting access to personal information to only those who need access to the personal information to do their job. Physical, electronic and managerial procedures have been employed to safeguard the security and integrity of your personal information.
We will destroy or de-identify personal information once it is no longer needed for a valid purpose or required to be kept by law.
10. Accessing and correcting your personal information
You may request access to personal information we hold about you (including credit information). On the rare occasions when we refuse access, we will provide you with a written notice stating our reasons for refusing access. We may seek to recover reasonable costs incurred for providing you with access to any of the personal information about you held by us.
You may also request that information about you be corrected if you do not think that it is accurate (including credit information). We are not obliged to correct any of your personal information if we do not agree that it requires correction and we may refuse to do so. If we refuse a correction request, we will provide you with a written notice stating our reasons for refusing.
Requests to access or correct personal information should be made in writing to our Privacy Officer at PrivacyMatters@precision.com.au. We will respond to all requests to access or correct personal information within a reasonable time.
11. Resolving personal information concerns
If you are dissatisfied with the handling of your complaint, you may contact:
Office of the Australian Information CommissionerGPO Box 5218, Sydney NSW 20011300 363 992 or via email at firstname.lastname@example.org
In New Zealand:
Office of the Privacy CommissionerPO Box 10094, Wellington 61430800 803 909 or via email at email@example.com
12. Further information regarding Privacy Laws
If you would like further information relating to the application of the APPs and the Privacy Act 1988(Cth) in Australia, please visit http://privacy.org.au
If you would like further information relating to the application of the IPPs and the Privact Act 1993(NZ) in New Zealand, please visit http://privacy.org.nz