1. Privacy Act
Harbour Town Centre Management Pty Ltd (HTCM) is required to comply with the Privacy Act 1988 (Cth) (Act) including the National Privacy Principles (and, from 12 March 2014, the Australian Privacy Principles).
This Policy is intended to provide a general overview of the policies for the handling of your personal information by HTCM and other entities in the Harbour Town group, including Airport West Pty Ltd.
2. How we Collect, Hold, Use and Disclose Personal Information
We will only collect personal information that we require for the purpose of our business functions and activities. Our functions and activities include (amongst others): operating our brand direct shopping centres, holding special in-centre and online shopping events, conducting promotions and competitions, operating the Harbour Town VIP membership scheme and providing centre management services to customers and retailers.
We generally collect personal information directly from you, including for example, when you complete applications for Harbour Town VIP membership, purchase products online through our websites, complete email or feedback forms on any of our websites, enter into promotions and competitions, complete surveys, or sign up to mailing lists. In limited circumstances, we may also collect personal information about you from a third party.
The types of personal information that we require will depend on the purposes for collection, but will generally include your name, address, telephone number and email address. We may also collect other information, such as your birthday if you are becoming a Harbour Town VIP member, and your bank account details and details of products you purchase if you are using one of our online platforms for the purchase of products. We may also collect other personal and sensitive information from you if necessary (for example, health information if you borrow a wheelchair from us when visiting our shopping centre).
In some cases, if you do not provide all of the personal information that we require we will be unable to provide you with the products and services you are seeking (for example, access to our online platforms, or entry into a promotion or competition).
We handle all personal information carefully. Storage of your information may be undertaken by a third party at an off-site location specifically authorised by us for that purpose, or it may be stored by us in a secure location. We ensure that your personal information is stored securely, and have implemented policies and procedures designed to ensure that your personal information is not misplaced or misused, and that unauthorised access to, modification of, or disclosure of your personal information does not occur.
Security measures we may employ from time to time include:
password protection of information stored in computer records;
restricted access to certain information, to ensure that only authorised individuals are able to view this information, and only for authorised purposes;
network and computer security;
physical document security, including locked offices, filing cabinets and archives; and
secure destruction of the information on the database every 3-5 years to ensure that your personal information will not be stored indefinitely.
We may refuse to provide you with further information about our security procedures if doing so may compromise those procedures.
2.3 Use and Disclosure
We will use and disclose your personal information for the purposes for which we collected it, for other related purposes that you would reasonably expect, and as otherwise permitted or required by law.
We may disclose your personal information to suppliers who provide services to us (such as mailing houses and third party storage providers) and in some cases to our retailers (for example, we will disclose personal information about you to a retailer whose products you purchase using one of our online platforms).
By providing us with your personal information you consent to us sending you marketing and promotional material about the Harbour Town business and the products, services, special offers and promotions that we and the retailers in our brand direct shopping centres offer. You agree that we may send you such information by post or by electronic means (including email and SMS). You can opt-out of marketing and promotional communications at any time by contacting our privacy officer, or using the opt-out mechanism provided in each communication.
We will not otherwise disclose your information to third parties without your consent.
3. Access to Personal Information
You may seek access of any of the personal information we hold about you by contacting our privacy officer on the details set out at the end of this Policy. We may require that you provide us with sufficient identification before allowing you to access the personal information we hold about you. If we are required or authorised by law to do so, we may refuse to provide you with access to this information.
We may charge a reasonable fee for you to access your personal information we hold. If so, we will advise the amount of that fee once we have assessed your request for access, and may require payment prior to allowing you to access your personal information. We will not charge a fee for you to lodge a request for access.
We may provide you with access to your personal information in any of a number of ways, including by providing you with a hard copy of the information, or by allowing you to view our records. If you satisfy us that any personal information we hold about you is not accurate, complete and up-to-date, we will amend our records accordingly. Please let us know if any of your personal details change.
4. Credit checks
If you are seeking to become a tenant of a HTCM managed centre, we may need to collect, use and disclose particular consumer and commercial credit information (for example, collecting and disclosing particular information to credit reporting agencies or other credit providers about you). Where we intend to collect consumer credit information about you we will provide you with further information about how we will handle that information and obtain specific consents from you.
5. Information Transferred Overseas
Generally, we do not transfer personal information outside of Australia. We may do so, however, if you have given your permission for this to occur or if we are otherwise legally entitled or required to do so.
6. Online Privacy
6.1 Automatic Server Logs
Our web server automatically collects various items of information when you use our web site, including:
your IP (Internet Protocol) address;
information about the operating system and Internet browser software you are currently using; and
the data that you download from our websites(s) and when you download it.
Although, in some circumstances, it may be possible to identify you from this information, we do not attempt to do so, and only use this information for statistical analysis, system administration, and similar purposes. This information is not disclosed to any other party.
If you provide any personal information to us via our online services (including email) or if we provide information to you by these means, the privacy, security and integrity of this information cannot be guaranteed during its transmission unless we have indicated otherwise.
Once we receive personal information, we will take reasonable steps to store it so that unauthorised access, modification, disclosure, misuse and loss are prevented.
6.4 Other Online Services
If any of our online services (including any email messages we send to you) provide links to other online services that are not operated by us, we are not responsible for the content of those other services and do not (unless we specify otherwise) endorse the privacy practices of the organisations that operate those other services.
8. Complaints, Concerns or Further Information
If you believe we have breached our obligations under the Privacy Act (including the National Privacy Principles, or from 12 March 2014, the Australian Privacy Principles) or if you have any other queries or concerns regarding your privacy and the way we handle your personal information, we encourage you to contact our privacy officer using the contact details below. As appropriatewe will endeavor to provide you with further information, or in the case of a complaint we will investigate your complaint and provide you with a response within 14 days (or shorter period as agreed).
9. Contact Information
If you have any questions about our management of your personal information, please contact our privacy officer for further information on the details set out below:
The Privacy Officer
Harbour Town Centre Management Pty Ltd
727 Tapleys Hill Road
WEST BEACH SA 5024
Phone: 08 8355 1144;
This policy is with effect from 7th February 2014.