Haben knows that you care how information about you is used and shared and we appreciate your trust in us to do that carefully and sensibly. This policy describes the types of personal information that we may collect about you, the purposes for which we use the information, the circumstances in which we may share the information and the steps that we take to safeguard the information to protect your privacy.
As used throughout this policy, the term “Haben” (collectively also referred to in this Policy as “us,” “we” and “our”) refers to The Trust Company (Australia), ACN 000 000 993, as the custodian for Haben Retail 5 Trust, and its associated entities and subsidiaries including but not limited to Haben Property Fund Pty Ltd (ACN 139 914 775) and Croydon Central Shopping Centre.
Haben is bound by the Privacy Act 1988 (Cth) (the Privacy Act) and by other applicable laws which govern privacy.
This policy is made freely available via any of our online or mobile services including our main online service www.croydoncentral.com.au.
Compliance with the Privacy Act
Haben is bound by the Australian Privacy Principles in the Privacy Act 1988 (Cth) (the Privacy Act).
To enable Haben to deliver the best possible service to you, its clients, suppliers, service providers, contractors and customers, it is necessary for Haben to collect personal information (i.e. information that can identify a person) about individuals. The type of personal information that is collected will be determined by nature of the relationship between Haben and an individual.
At the time personal information is collected, Haben will take reasonable steps to inform individuals about the purpose for which the information is collected, the customers' right to access the information and other matters contemplated in the Australian Privacy Principles regulating collection of personal information.
What is Personal Information?
Personal information is information about a person whose identity is apparent from the information, and includes identifiers such as the individuals name, email address, postal address, phone number, gender, social media information and profile, (collectively, “Personal Information”).
How do we collect your Personal Information?
Personal information can be collected by Haben in a number of ways, including email, via any of our online services or mobile services, in person, by phone or by fax or via video and camera surveillance systems for security purposes.
(a) Collection of Personal Information from third parties
Haben from time to time collects Personal Information from third parties, such as:
- Public sources of information (such as telephone directories)
- People authorised by you if required (such as lawyers or law enforcement agencies)
- Recruitment Agencies for the purposes of introducing to us future employee prospects
- Real Estate Agents for the purpose of assisting both parties to engage in a potential commercial sale or lease of one or more of our properties or spaces
- Retailers within our retail properties and law enforcement agencies for the purposes of investigating or reporting an incident.
Haben does not collect Personal Information from third parties involuntarily nor is Haben responsible for the protection of your Personal Information held by third parties.
What Personal Information about you does Haben collect and when do we collect it?
The information we gather from you helps us to continually improve your experience with Haben. This personal information may include: your name and contact information; date of birth; preferred communication methods; business name and business address.
In certain circumstances, we may collect additional Personal information such as your home address, age, emergency contact, car registration, health insurance details, education and qualifications, bank details and/or credit details and associated information.
Haben will not collect any Personal Information from you unless you choose to provide it to us.
(a) Sensitive Information
Haben generally does not collect any “Sensitive Information” such as information about your race, political opinion, memberships, or political associations, religious beliefs, philosophical beliefs, memberships of professional or trade associations, trade unions, sexual preferences, criminal records, health records or genetic information. If we do, we will seek consent to collect it if required by law to do so.
Haben may seek your consent to collect Sensitive Information such as health issues in certain circumstances.
(b) Information not Personally Identifiable
Every time you call us, we may be able to identify your phone number but we choose not to record it or use it to identify you. When browsing or using any of our online or mobile services we may collect information about the device you are using, your IP address, and the browser you are using but nothing about you personally until you choose to sign in to the community or member areas of our online or mobile services.
(c) Personal Information from Children
We do not knowingly ask for Personal Information from anyone under the age of 18 (a "Child") without the consent from a Parent or Legal Guardian. Personal Information relating to a child under the age of 18 is collected only when a Parent or Legal Guardian has provided consent for us to enter the person in competitions we hold or conduct, or for incident reporting purposes.
If a Child submits Personal Information to us and we know that the person providing the information is a Child, we will not use it for any purpose. We will take all reasonable steps to destroy that information as soon as we discover it and we will not disclose it to third parties. If you become aware that a Child has provided Personal Information to us via our online or mobile services, please contact our Privacy Officer, (details provided at the end of this policy).
While Haben's policy prohibits children under 18 from registering with our online and mobile services, parents should supervise their children's online activities and consider using parental control tools available from online services and software manufacturers that help provide a kid-friendly online environment.
These tools can also prevent children from disclosing online their name, address and other Personal Information without parental permission.
(d) Photographs for Access/ID Cards
When entering the car park or building of a Haben owned or managed property, Personal Information may be collected in the form of images recorded by video and camera surveillance systems for the management and security of the property. The Personal information and images may be collected by Haben and Haben may collect your Personal Information and images from third parties (for example, the Police, retailers or tenants). This information may be used by Haben for incident reporting purposes and shared with law enforcement, government bodies, Haben staff and subcontractors, insurers and retailers. The license plates of vehicles parked by you in car parks may also be collected and used for the above purposes.
(f) Contacting Us and Becoming a Member via our Online or Mobile Services
When you use our online or mobile services, or contact us by post, telephone, fax, email or SMS, we collect, store and use certain personal information that you disclose to us. This includes details such as your name, address, telephone, fax, email and mobile phone number as well as traffic data, location data, web logs and other communication data, whether this is required for our own purposes or otherwise and the resources that you access. If you contact us, we may keep a record of that correspondence.
When using our online or mobile services you may elect to contact us, become a member or request to join one or our mailing lists or sign up for email offers, in which case we only collect necessary Personal Information that you have volunteered. You may elect not to provide this Personal Information, or to de-identify yourself through the use of a pseudonym, however, we may not be able to provide the information or service, a visitor to our online or mobile services requests if the personal information which is indicated as mandatory is not provided.
(g) Promotions, Events, Competitions
We collect personal information only when you elect to submit such information to us, including when you register for a promotion or event, participate in a contest, fill out a survey, contact us (for example via online Contact Us form or email available on our online or mobile services).
In connection with competitions or signing up to newsletters, you may provide us with your contact details. Haben collects these details to contact competition winners, and to inform you about events, activities and promotions. You have the option to Opt-Out from receiving this information.
We occasionally conduct surveys across different areas of our business. We conduct surveys primarily for feedback and research purposes. You do not have to respond to these surveys.
(i) Other Sources
Haben does from time to time collect Personal Information about individuals who are, or are employed by, our suppliers, service providers, contractors and customers. We usually only collect business or work contact details for these people.
As a general rules personal information is only collected when it is reasonably necessary for, or directly related to, one or more activities or services we provide.
Why do we collect your Personal Information and how do we use it?
The main types of personal information Haben collects and the main purposes for which personal information is collected, used, held and disclosed are set out below:
- We use personal information to provide the services you request from Haben such as to facilitate: our relationship with you, to communicate with you and assist you with queries and to facilitate appointments with our own or third party service providers and other transactions.
- We also use personal information in order to provide and improve our services and operate our facilities (including as described above), or otherwise as required or authorised by law. For example, when an individual sends Haben a query, we will use the individual's personal information for the purposes for which the individual provided it.
- We may also use the information: to advertise products and services, to carry out market data analysis so that we can continue to deliver enhanced services and facilities, to process payments and maintain accounts and records, to prevent crime and aid in the prosecution of offenders, to comply with the law. In addition, we use this information to improve our platform, prevent or detect fraud or abuses of our website and enable third parties to carry out technical, logistical or other functions on our behalf. As part of conducting our business, personal information may also be used to maintain and develop our business systems, including testing and upgrading them.
- If you are personally involved in or are a witness to an incident that occurs on a Haben owned or managed property, construction or worksite, we will ask you to provide us with your personal information to assist with being able to collect information relating to the incident, report on the incident to our insurance underwriters and to assist with notifying emergency services or other appropriate authorities in the event they are required.
- The Personal Information we receive from you will only be used for the particular purpose for which you provided it, and will not be used by Haben for any secondary purpose, unless you consent to that use or the disclosure is required or authorised by Australian Law or a court/tribunal order or if it is reasonably necessary for the enforcement activities of an enforcement body.
- The Personal Information you choose to share with us when using one of our online or mobile services allows us to personalise our product offering and improve your online experience making it more convenient, efficient and enjoyable.
We may use the Personal Information that you submit to us to:
- Customise your communications
- Notify you about our new products and services, special offerings and other promotions
- Co-ordinate contests, promotions, surveys or other website features
- Improve our business and better respond to your needs
- Provide services in the course of investigating a complaint or a security incident
- For any other purpose for which you provided your Personal Information.
Haben will take all reasonable steps to destroy or de-identify Personal Information, if it no longer needs the information, unless the Personal Information is contained in Commonwealth records, or we are required under Australian Law or Court Order to retain the information.
Under what circumstances may we share or disclose your information?
For the purpose of operating our business, we may transfer or disclose your Personal Information to our third party service providers and contractors who use that information only to conduct Haben business. For example, these third party service providers and contractors may handle archival, auditing, professional advisory, debt collection, banking, marketing, promotions, advertising, mail house, delivery, recruitment, call centre, technology, research, utility and security services.
Personal information we collect may also be used for purposes related to Haben’s research (including market research), planning, product and marketing development, security and testing.
We may disclose Personal Information upon governmental request, in response to a court order, when required by law, to enforce our website policies, or to protect our or others' rights, property, or safety. We may also share Personal Information with companies assisting in fraud protection or investigation. We do not provide Personal Information to these agencies or companies for marketing or commercial purposes.
The content of emails or ‘contact us’ messages which you send Haben, may be monitored by our service providers or our employees for purposes including compliance auditing and maintenance or where email abuse is suspected.
We may share personal information within Haben and with other members of the Haben Group.
(a) Disclosure of Information outside Australia
Haben may disclose your information outside Australia or our service providers located in various other countries from time to time including the United States and Luxembourg.
Haben takes all reasonable steps to ensure that any overseas recipient of any Personal Information will hold and use that information in accordance with the Australian Privacy Principles, or the equivalent provisions in the country in which they are located.
How secure is your information and how do we protect your information?
Whether your personal information is gathered through face-to-face meetings or by interacting with us via phone, mail, email, internet or other methods, we take steps to store your information securely. We hold your personal information in a combination of secure computer storage facility, paper-based files and other formats.
We regard the security of personal information as a priority and use a number of physical and electronic mechanisms to protect it. We have a variety of security measures to protect against the loss, misuse, unauthorised access, modification or alteration and improper disclosure of your Personal Information that we have collected from you. This includes instructing our staff who handle personal information to respect the confidentiality of your information and the privacy of individuals. When using our online or mobile services, to ensure the information you provide online is secure during transmission, we use leading edge encryption technology and Secure Socket Layers (SSL) while processing any Personal Information you supply.
These controls are certified by a leading Internet security company. You can review our security certificate using your browser by clicking on the closed lock or solid key image at the bottom of your browser on any of the secure pages on our online services. This will display security information for our online services.
No data transmission over the Internet can be guaranteed as completely secure. So while we strive to protect such information, we cannot ensure or warrant the security of any information transmitted to us and individuals do so at their own risk.
A username and password may be essential for you to use some sections of our online or mobile services. For your own protection, we require you to keep these details confidential and to change your password regularly (if applicable).
You agree that in order for us to provide our online and mobile services and any services incidental to it (such as online shopping functions), we may need to store or transfer your Personal Information to servers located outside of Australia.
Will my Personal Information be used for Marketing Activities?
It is important for Haben to maintain contact with individuals. That contact may involve the sending of advertising material through the post or by email, notifications via SMS or our mobile services. In these circumstances, it is Haben's policy to comply with the stated purpose for which personal information was collected. Individuals will always have the opportunity to decline to receive further marketing material. If Haben receives such a request Haben will update its records appropriately, within a reasonable time.
(a) Opt-Out and Unsubscribe from email/SMS/Mobile Service Marketing Activities
If for any reason you would like to be taken off the email/SMS list that notifies you of upcoming events, promotions and offers sent by Haben/Croydon Central Shopping Centre or to opt-out of having your Personal Information transmitted via our third party service providers, simply click the unsubscribe link provided at the bottom of an email we send you, or reply unsubscribe to the SMS we send you, or remove our mobile services from your smart phone.
Alternatively please contact us and we will assist you to opt-out.
How do I access and correct Personal Information Haben holds about me?
In most circumstances, you have a right to access any Personal Information which we collect and hold about you and to have it corrected if it is wrong. We may deny your request for access in some circumstances, but if we do this, we will tell you why.
If you have registered your details using our online or mobile services, you may be able to access and update personal information on your profile, subject to any authentication and authorisation considerations, which exist to protect your security.
Please contact our Privacy Officer using the details set out below if you wish to:
- ask any questions or provide feedback about this Privacy Statement or our approach to privacy;
- make a request for access to or correction of any personal information that we may hold about you; or
- make a complaint about the way in which we have handled your personal information.
Any information that we provide in response may be limited to the extent permitted by any applicable law.
Phone: (02) 9302 5900
Fax: (02) 9328 5890
203-233 New South Head Road
Edgecliff NSW 2027
How can I make a complaint, report a breach or misuse of Personal Information?
You may complain about a breach or misuse of your Personal Information, by contacting us in writing to the postal or email address listed above in the section entitled “Access to and correction of, Personal Information”. You should include your name, postal or email address, contact telephone number, details of the nature of the complaint, and any relevant information or documents. We will acknowledge your complaint and advise you of the steps in dealing with your complaint.
Independent of any complaint made to us, you may also be entitled to make a complaint to the Office of the Australian Information Commissioner.
General information about privacy and the operation of the Privacy Act 1988 (Cth) can be found at the Office of the Australian Information Commissioner's website at www.oaic.gov.au.
This statement outlines some privacy issues specific to the haben.com.au website and mobile services accessible via a mobile device.
Some aspects and areas of Haben’s online and mobile services provide interactive tools designed to help you to learn more about us or provide us with your feedback, join our communities or mailing lists.
Haben may collect personal information you enter when using the interactive tools available via our online or mobile services.
Cookies, Web Beacons and Pixel Tags
(a) Collection through cookies, web beacons and pixel tags
A cookie is a small removable data file stored by your Web browser on your computer or mobile device. We place a unique identifier in the cookie and use the cookie to connect your computer with the information we store for you in our database.
- Recognize you when you came back to our site(s)
- Alert you to new areas that may be of interest to you
- Customize Web page content that may be helpful to you
- Cookies do not contain any Personal Information and they do not give us access to your computer.
Pixel Tags and Web Beacons are tiny graphic images that allow us or preferred service providers to track non-personally identifiable analytic information about your visit to our online service or use of our mobile services (such as pages viewed or links clicked). Pixel tags and Web beacons also let us know when you have opened an HTML E-mail from us. Using this information we are able to understand how Visitors and Members use our service. This allows us to learn what pages are most attractive to our Visitors, which parts of our online services are the most interesting and what kind of offers our Members like to see.
(b) Turning off some of these tools
You may turn off tracking of cookies, web beacons and pixel tags, through configuring your computer, mobile device or web browser, however you may not have access to some functions of our online services, and other functions may not function properly.
You can choose to have your computer warn you each time a cookie is being sent or you can choose to turn off all cookies. You do this through your Internet browser (such as Internet Explorer, Firefox, Safari) settings. Most browsers are initially set to accept cookies. Each browser is a little different, so check your browser Help menu to learn the correct way to modify your cookie settings. However, if you choose to turn cookies off, you may not have access to all of the features of our site that make your navigation experience more efficient and convenient.
At times, we may provide links from our online and mobile services to other websites or mobile apps operated by third parties. These links are provided only for your convenience and intended to add value to your visit. However, by including these links, even if affiliated with Haben, we do not have control over these sites and services, which are independent from Haben and have separate privacy policies and terms and conditions.
When leaving our online or mobile services, you need to be aware that our policies no longer apply. Therefore, we will not be responsible for the accuracy, relevancy, availability, reliability, copyright compliance, legality or decency of material contained in third party sites linked to our services.
We strongly encourage you to review the terms and privacy policies of any third-party sites before using their sites.
Information posted on public areas of our online or mobile services
If we determine that it is not reasonably necessary for, or directly related to, one or more of our activities then we will either destroy, remove or de-identify the information as soon as practicable.
If the Unsolicited Personal Information is supplied by a third party, then we will notify you of the collection of that information and the steps that have been taken in relation to that information.
Any Unsolicited Personal Information you post and/or disclose in a public forum in the public areas of our online or mobile services shall be deemed to be non-confidential, as it may be publicly viewable.
You should use your discretion to exercise caution before you post Personal Information in public forums, such as any Haben blog site, social media site, online or mobile service. Once you release your Personal Information for posting on public forums, Haben is not responsible for the privacy and/or security of such information, other than that required under the Australian Privacy Principles or at Law.
Website analytics measurement software is used to assist in tracking traffic patterns to and from the online and mobile services, anonymously surveying users of the sites.
Every time you visit one of our online or mobile services, we automatically collect information from you that is not Personal Information. Examples of this type of information include:
- The type of Internet browser you are using.
- The type of computer or mobile device operating system you are using.
- Your computer or mobile device IP address.
- The domain name of your Internet service provider.
- The Web page from which you came.
- The pages you visit on our website.
This non-personal information is collected and aggregated by third party software and provided to us to assist in our analysis of our online and mobile services. You cannot be identified personally from this information and no personal information is stored about you.
You can visit many of the pages on our online or mobile services without providing us with any Personal Information. When you visit these services, we may track your visit and, as described above in the section concerning “Cookies, Pixel Tags and Web Beacons”, collect certain data regarding your use of the Service and your activity on the Service. You may elect to limit this process of collection of this type of information, as described in the “Cookies, Pixel Tags and Web Beacons” section above.