JEN RETAIL PROPERTIES LIMITED
Privacy Policy
JEN RETAIL PROPERTIES LIMITED ("JRPL") is committed to the protection of your personal privacy. We value and appreciate the trust and confidence you place in us and our services. Accordingly, we adhere to the National Privacy Principles as set out in the Privacy Act 1988 when gathering, using amd storing information about you. As evidence of this commitment, we undertake to adhere to the following 13 principles in relation to the information you give us about yourself.
1. Collection
We agree that we will only collect information necessary in relation to the conduct of our business as shopping centre owner managers and providers of commercial space, including (but not limited to) the following:
- Tenant's contact details - including private telephone number and mobile numbers for after hours communications (this includes casual leasing tenants);
- Tenant company director details - including private address, telephon number and details of guarantees;
- Customer databse - including name, address, phone number and age
- Competition entries - supplied by our tenants and customers, including name, address, phone number and age;
- Resumes of potential employees - including personal and professional information;
- Camera surveillance in our shopping centres, including carparks;
- Customer contact details - collected in relation to Insurance matter for slips and falls - including name, address, telephone number and age;
- details of customer complaints - including name, address, telephone number and the nature of the complaint; and
- Carpark information in relation to permanent and reserved parking - including name, address, telephone number and vehicvle registration number.
Our purpose in collecting the above information form you is to enable is to properly manage our business, service our tenants and our customers and meet their expectaions.
This information will be collected by lawful and fair means and will not be collected in an unreasonably intrusive way.
We only collect customer information that is needed to administer our business, ensure the safety of our tenants and our customers, provide superior service and to communicate offers, merchandise or services that we believe would be of interest to you.
When we collect personal information from you, we will make sure that you know;
- how to contact us if you would like to access your personal information;
- the purpose for which the information was collected;
- who we would usually disclose your personal information to;
- any legislative requirements for collecting your personal information to;
- any consequences for you if you do not provide us with this information.
Where possible, we will only collect personal information about you from you. If we collect personal information about you from somebody else, we will still try to make you aware of all matters discussed above.
2. Use and Disclosure
We will not use or disclose or permit the use or disclosure of any personal information unless one or more of the following apply:
- you have provided your consent;
- you would expect the information to be disclosed;
- it is in accordance with this Privacy Policy;
- we believe that use or disclosure is necessary where we suspect fraud or unlawful activity has been, is being or may engage in;
- the use or disclosure is required or authorised by law;
- the use or disclosure is required as a result of an insurance claim;
- we believe the use or disclosure is necessary for the operation, development or administration of JRPL or services provided by JRPL;
- we believe that the use or disclosure is necessary to assist a law enforcement body or national security body in the performance of its functions, or the use or disclosure rates to the preparation for, conduct or orders arising out of legal proceedings of a court or tribunal; or
- we reasonably believe it is necessary to prevent any serious and imminent threat to any person's life, health or safety or the public's health or safety.
Where personal information is provided to third parties in accordance with this Privacy Policy the following statement must be attached to or accompany the personal information being disclosed:
"This personal information is provided to you in accordance with the terms and conditions of our Privacy Policy and must only be used in accordance with the National Privacy Principles as set out in the Privacy Act 1988. We accept no responsibility or liability for any third parties use of the personal information which is not in accordance with our Privacy Policy or the National Privacy principles as set out in the Privacy Act 1988."
3. Data Quality
We will make reasonable efforts to ensure that information we have about you is accurate when it is collected and that it this information is kept complete and up to date.
4. Data Security
We agree to make reasonable efforts to ensure that information we collect and keep about you is kept secure at all times (including noth electronic and paper-based storage systems).
We will monitor and adopt ,as appropriate, new technological developments that are designed to aid in ensuring the security of customer information.
We limit access to customer information to those of our employees who need it to carry out their business functions. We educate our employees about our policies and practices in regard to:
- safeguarding customer information
- preventing its unauthorised access, use or disclosures; and
- ensuring its proper handling
Unfortunately, no data transmission over the internet can be guaranteed as totally secure. Although we strive to protect such information, we cannot ensure or warrant the security of any information you transmit to us and you do so at your own risk. Once we receive your transmission, we take reasonable steps to preserve the security of the information in our own system.
We will use all reasonable endeavours to ensure that you only provide personal information in a secure environment, and when the information is no longer needed it will be destroyed or permanently de-identified. We will also take care to ensure that any personal information provided by you will be reasonably protected from misuse, loss, unauthorised access, modification or disclosure and will be maintained by us in an accurate, complete and up to date manner.
5. Openness
We promise to be honest and open with you about the actual use of information that is collected about you and the type of personal information about you that we keep. You may inquire about the use or type of information held by contacting us on:
-
Brisbane (07) 3229 4188
-
Sydney (02) 9288 8900
and asking to speak to our Privact Policy Manager. This policy on our management of personal information is publicly available to anyone who asks for it.
6. Access and Collection
Upon presentation of appropriate identification, we will allow you to access the information we keep about you to determine what the information is and to correct that information if it is found to be incorrect. We will endeavour to provide you with access to your personal information within 28 days of receiving your request, or sooner if reasonably practical.
If at any time you wish to change personal information that is incorrect or wish to have your personal information deleted, please contact us on:
- Brisbane (07) 3229 4188
- Sydney (02) 9288 8900
or email us at info@jen.com.au. Unless personal information is required for administrative or legal reasons, we will take all reasonable steps to meet such requests at the earliest possible opportunity. We reserve the right to charge a reasonable fee for providing access to your personal information.
7. Identifiers
We will not use government document identifiers (for example a number or combination of letters and numbers ascribed to an individual) for the purpose of identifying you. We may use your name or ABN (as defined in the A New Tax System (Australian Business Number) Act 1999) to identify you.
8. Anonymity
Wherever it is unlawful and practicable, we will endeavour to provide you with the option of not identifying yourself or not providing personal information when entering transactions with us. However, failure to provide full and complete information we request may result in a limited ability on our part, to offer or deliver complete services to you.
Our website may collect information from visitors that is not personally identifiable. This information may include details about your operating system, browser, domain name, and specific web pages you access on our site. We only collect information in the aggregate and only use it to improve our website.
We may use cookies to personalise and simplify your access to and use of our website. A cookie is a piece of data stored in your hard drive, which allows us to recognise your computer. This information is used to authenticate or identify whether you are registered on our website, without requiring you to re-enter details each time you log on to our website. Cookies are not linked to any personally identifiable information whilst on our site, but can allow us to attract the interest of customers and enhance your online experience. Cookies can assist by allowing you to navigate freely on our website without the need to re-register, therefore saving you time.
If at any time you do not wish to accept cookies or wish to delete existing cookies, you may manually configure your browser or refuse cookies or may manually delete existing cookies form your hard drive. However, by deleting or refusing to accept cookies, you may frustrate or encumber your access to or use of areas of our website.
9. Transborder Data Flows
We agree to ensure that personal infomration you give to us that is transferred outside Australia will remain subject to the protection given by our Privacy Policy.
We will not, without your consent, transfer personal information to foreign country unless:
(a) we reasonably believe the recepient is subject to a law, binding scheme or contract or we have taken reasonable steps to ensure that the recipient is subject to a contract which effectively upholds principles for the fair handling of personal information that are substantially similar to the National Privacy Principles; or
(b) you consent to the transfer; or
(c) the transfer is necessary:
- for the performance of services requested by you; or
- for the purpose of fulfilling our business commitments to you; or
- to implement pre-contractual measures taken in response to our request by you; or
(d) the transfer is necessary for the conclusion or performance of a contract concluded in your interest, between JRPL and a third party; or
(e) all of the following apply:
- the transfer is for your benefit; and
- it is impracticable to obtain your consent to the transfer; and
- if it were practicable you would be likely to consent to the transfer;
(f) we have taken reasonable steps to ensure that the information we have transferred will not be held, used or disclosed by the recipient of the informarion inconsistently with the National Provacy Principles.
10. Sensitive Information
We promise that information that is likely to be considerde too personal for public disclosure will not be collected. For example, information relating to your sexual orientation, religious or philosophical beliefs, political opinions or the state of your health will not be intentionally collected by us.
We may collect this type of sensitive information if:
(a) you sonsent; or
(b) the collection is required or specifically authorised by law; or
(c) the collection is necessary to prevent or lessen a serious and imminent threat to the life or health of any individual, where the subject of the information is physically or legally incapable of giving consent; or
(d) the collection is necessary for the establishment, exercise or defence of a legal claim.
11. Complaints Resolution
We are committed to providing you with a fair and responsive system for handling and resolving complaints. You have a right to complain and to have your complaint handles efficiently. We believe that in receiving your complaint we are provided with a valuable opportunity to improve the services we deliver to you and maintain your confidence in us and our services.
If any time you wish to lodge a complaint in respect of the handling, use or disclosure of your personal information by us, you may notify us of your complaint by phoning us on:
- Brisbane (07) 3229 4188
- Sydney (02) 9288 8900
writing to us at GPO Box 2891, Brisbane, Queensland, 4001 or emailing us at info@jen.com.au marked to the attention of the Privacy Policy Manager.
12. Compliance Audit
We will ensure an internal audit to verify that management arrangements are adequate to ensure compliance with this Privacy Policy. An annual audit will be conducted and a report will be provided to senior management.
13. Updates
We reserve the right to update this Privact Policy if we consider it necessary. Your personal information will be handled in accordance with the most current version of this Privacy Policy which you can access by contacting us on:
- Brisbane (07) 3229 4188
- Sydney (02) 9212 1300
or by writing us at GPO Box 2891, Brisbane, Queensland, 4001 or emailing us ar info@jen.com.au marked to the attention of the Privacy Policy Manager.