Ballina Fair Shopping Centre Privacy Policy

Section 1: Our commitment to protecting your privacy

We know that how we collect, use, exchange and protect your information is important to you, and we value your trust. That’s why protecting your information and being clear about what we do with it is a vital part of our relationship with you. This Privacy Policy helps to ensure that Ballina Fair Shopping Centre meets its legal obligations under the Privacy Act 1988 (Cth) (Privacy Act) which implements the Australian Privacy Principles.

Section 2: Who this privacy policy is for?

This Privacy Policy is for investors, clients, tenants, service providers, current and prospective employees and customers of Ballina Fair Shopping Centre. It explains Ballina Fair Shopping Centre handling practices including in relation to personal information collected by Ballina Fair Shopping Centre.

By using any of Ballina Fair Shopping Centre services or providing any services to Ballina Fair Shopping Centre, you confirm that you have read and agree to the terms of this Privacy Policy. By agreeing to this Privacy Policy, you consent to the collection, use, disclosure and handling of your personal information in accordance with this Privacy Policy. If you are an organisation, by agreeing to this Privacy Policy, you confirm that you have obtained consent from your personnel to the collection, use, disclosure and handling of their personal information in accordance with this Privacy Policy.

Section 3: Further privacy information

During the course of our relationship with you, we may tell you more about how we handle your information. This could be when you complete an application form, or receive terms and conditions or a product disclosure document. When you receive this further information, please consider it carefully. Please also visit our website regularly as we update this Privacy Policy from time to time.

Section 4: What information we collect and why?

We collect information about individuals including in the following ways:

• when you provide the information directly to us. For example:
• when you register or fill in forms on our websites or mobile applications, social media, and other online services;
• when you purchase gift cards or otherwise transact with us, participate in surveys, promotions or competitions and register for or use any of our services;
• when you send emails, letters or other correspondence to us;
• when you report an incident, make a complaint or provide other feedback to us; and
• from publicly available sources of information or from others.

Where we collect information from you, we will generally do so ourselves. However, in some cases we may collect information through your representatives, information service providers and other third parties.

Section 5: Types of information?

The information that we collect about you may include:

• your name, date of birth, address, home phone number, mobile number and other contact details;
• payment information, which may include bank account or credit card details, and other information that we need in order to provide relevant goods and services to you, such as relevant identification;
• details of your interests and shopping preferences and activity;
• user names, passwords and other registration details that you provide when registering to use any of our websites, mobile applications or other services;
• details of your visits to, and use of, our websites, mobile applications, and other online services, including the different parts of those services that you access during your visits, your IP address and the date and time which you access our websites;
• where you use one of our mobile applications, information about your visits to our shopping centres collected through the mobile application, including device details (including device identifiers, usage and location data) This may include information about the different areas of a centre that you have visited and your present location within a centre;
• information submitted in forms, details of incidents involving you at our properties, enquiry/complaint details and records of communications; and other information that you provide to us.

Ballina Fair Shopping Centre Pty Ltd shopping centres, including those managed on behalf of third parties, are under video and camera surveillance. When entering Ballina Fair Shopping Centre Pty Ltd shopping centres, the personal information and images of individuals may be collected by Ballina Fair Shopping Centre Pty Ltd. This information may be used by Ballina Fair Shopping Centre Pty Ltd in connection with the management and security of the property generally, and may be provided to law enforcement and government bodies, insurers, Ballina Fair Shopping Centre Pty Ltd staff and subcontractors, third parties who provide Ballina Fair Shopping Centre Pty Ltd with services from time to time and retailers for these purposes.

Section 6: How we use and disclose the information that we collect?

We may use and disclose personal information that we collect about you for the following purposes:

• to verify your identity;
• to provide goods or services, including gift cards, that you order from us;
• to conduct competitions or promotions for which you have registered and to otherwise perform any obligations and / or exercise any rights we have under any contracts between us;
• to meet our legal and regulatory obligations, including responding to lawful information requests from courts, government agencies and lawyers and to protect our lawful interests;
• to help us improve the structure, layout and usability of our websites and mobile applications and to enable you to participate in any interactive features of those websites and mobile applications;
• to help us plan, operate and manage our shopping centres and other retail assets, including planning, product and service development, security, testing, customer relationship management and record management;
• to answer any questions, you may raise or respond to any comments you may send us;
• to carry out market analysis and research;
• to market and promote the shopping centres and other retail assets that we manage, and any of the tenants of those shopping centres.

We may send marketing or promotional materials to you where you subscribe to one of our newsletters or any other communication service, you request information about our services, you use our mobile applications or you provide your contact details to us and request that we contact you. If you do not want to receive this type of information, please let us know by contacting us in accordance with section 10 – how to contact us; and

• where you use one of our mobile applications, to provide certain services and other functionality within the application. For example, we may assign you a unique customer identification number in order to collect information about your location within the shopping centre to provide a mapping service within the application.
• In relation to mobile applications and other online services, we may also share personal information with other users of one of our online services where you have chosen, through your own use of that service, to share your information with those users. You can control the information that you share through the online service by changing the information sharing settings within the service.
• Your personal information will not necessarily be made available to all of our staff. Access to your information will generally be restricted to those staff who require the information for the purposes set out above.
• Generally, if you choose not to provide certain information to us, then we may not be able to provide you with certain services and you may not be able to use certain parts of our websites or online services or participate in competitions or promotions that we run.

In relation to mobile applications and other online services, we may also share personal information with other users of one of our online services where you have chosen, through your own use of that service, to share your information with those users. You can control the information that you share through the online service by changing the information sharing settings within the service.

Your personal information will not necessarily be made available to all of our staff. Access to your information will generally be restricted to those staff who require the information for the purposes set out above.

Generally, if you choose not to provide certain information to us, then we may not be able to provide you with certain services and you may not be able to use certain parts of our websites or online services or participate in competitions or promotions that we run.

Section 7: Cookies and other unique identifiers

Apart from the information mentioned above, we may also collect information about your usage of our websites by using cookie files which are stored on the hard drive of your computer. Cookies, which are small text files that a website may write to your hard drive when you visit the website, may be used for a variety of purposes, for example to manage security and store information about the type of browser being used. We use this information in order to help us recognise you as a unique visitor to the websites and to store your individual preferences, so that we can customise the websites to reflect your particular interests, and also for system administration purposes. You can accept or reject cookies by changing the relevant settings in your browser. However, if you decline cookies, you may be unable to access certain parts of our websites.

We may also collect information relating to other unique identifiers such as Flash cookies (also known as local stored objects), IP addresses and device identifiers that help us to understand device and browser interactions and activity on our websites and in our centres. In many cases, we will not be able to reasonably identify a particular individual from this information. Where we can do so, this Privacy Policy applies, as well as our obligations under the Privacy Act.

Section 8: Who do we exchange your information with?

Third parties

We may disclose information about you to third parties where this is permitted by law including for any of the purposes mentioned in section 3. These third parties include:

• our related bodies corporate;
• service providers, for example custodians, brokers, unit registry services or correspondent banks;
• other organisations who provide archival, auditing, professional advisory (including legal, accounting and business consulting), debt collection, banking, marketing, advertising, communication, mail house, delivery, recruitment, call centre, contract management, technology, research, analytics, utility, cleaning and security services and other persons/entities necessary for us to comply with a legal obligation or to perform any obligations under any contracts between us;
• those to whom we outsource certain functions on a confidential basis, for example, direct marketing, statement production, information technology support;
• owners of shopping centres for whom we provide property management or development services;
• a buyer or prospective buyer of us or our business, shopping centres or other retail assets;
• brokers, agents and advisers and persons acting on your behalf, for example a custodian, asset consultant or a person who holds a power of attorney; and
• government and law enforcement agencies or regulators where required or authorised by law or to assist in the prevention, detection and management of unlawful conduct such as fraud.

Section 9: Safeguarding your personal information

Ballina Fair Shopping Centre has technological and operational processes and procedures in place to protect personal information from misuse, interference and loss, unauthorised access, modification and disclosure.

Section 10: How to request access or correct personal information

Under the Privacy Act, you have the right to seek access to personal information we hold about you, subject to some exceptions.

To request access or correct personal information, or to obtain more information about Ballina Fair Shopping Centre’s privacy policy, you can contact Ballina Fair Shopping Centre:

By telephone: 02 66 86 8555 By letter to: The Privacy Officer, Ballina Fair Shopping Centre Management, 84 Kerr Street, Ballina NSW 2478 By email: info@ballinafairshoppingcentre.com.au

Ballina Fair Shopping Centre will respond to a request for access within a reasonable period of time.

Where we refuse access, we will where possible provide you with a written notice setting out our reasons for the refusal and the avenues for complaint about the refusal.

We may charge a fee for providing access to personal information. No fee is charged for the making of a request for access.

Section 11: How to opt out

If you do not wish to receive any further printed information from Ballina Fair Shopping Centre, you can contact the person named on the last printed information you received from Ballina Fair Shopping Centre. Alternatively, if receiving emails from Ballina Fair Shopping Centre, you will have the option to unsubscribe from our mailing list by following the directions on our emails.

Section 12: How to get more information or make a complaint

Please direct any questions about this policy or complaints about a breach of privacy by Ballina Fair Shopping Centre to Ballina Fair Shopping Centre’s Privacy Officer who can be contacted: By telephone: 02 66 86 8555 By letter to: The Privacy Officer, Ballina Fair Shopping Centre Management 84 Kerr Street, Ballina NSW 2478 By email: info@ballinafairshoppingcentre.com.au

Last updated January 2018