Cerno Hurstville Investors No3 Pty Ltd ATF Apollo Cerno Hurstville Property Trust (“we”, “our”) ABN 49 683 032 858 as the owner and manager of Hurstville Central Shopping Centre (“the Centre”), is committed to safeguarding personal privacy. We are committed to complying with the Australian Privacy Principals (APP) which guides organisations on how to deal with personal information. The APPs are found in amendments to the Privacy Act 1988, effective 12 March 2014.
We value your trust, so it is important to us that we are transparent about how we use information from and about you. It is our aim to create a shopping experience which makes your experiences with us better, easier and more enjoyable. The information we obtain from your interactions with us helps us to better understand and influence how we:
- Improve the Centre to meet the community’s shopping needs, and
- Support our tenants to help them deliver an improved service to you
This policy explains how we use the personal information of our customers. Personal information generally refers to information about you which can be used to reasonably identify you, such as:
- Your name
- Phone number
- Email address
- Date of birth
- Photos and videos of you
We generally collect personal information from you so that we can:
- Provide you with our services
- Register you for our events, newsletters and promotions
- Operate the Centre and digital services including through the use of CCTV, device and website tracking and logging of security, health and safety incidents
- Respond to complaints, queries and disputes
- Tailor our Centre and digital offerings to your activities and preferences
If you contact us in person, via our website or by phone, email or other correspondence, we collect your information so that we can provide you with an appropriate response, address any complaints, queries or feedback which you raise and maintain records of our communications. We also monitor your communications with us for security and dispute resolution purposes.
We collect sensitive information, such as:
- Health information, where required for managing compliance with our health and safety obligations and responding to health and safety incidents at the Centre, and
- Criminal offence details where individuals have committed, or are suspected of, criminal offences at our Centre.
When you visit our Centre, we collect information about you either directly from you or through our service providers. The kinds of personal information we collect includes:
The carpark We collect CCTV footage from within our car park in order to:
- Monitor car park usage and maintain Centre security
- Allow you to pay for parking using on-premise options
- Help you to locate your car
The Centre During your visit inside the Centre, we and our service providers:
- Collect CCTV and video camera footage for safety and security purposes
- Offer public Wi-Fi should you choose to register and provide us with your contact details or social media ID. We also collect from your use of our Wi-Fi:
– MAC address, devise ID, IP address assigned to the device, type of device and type of web browser you are using – The dates and times you access our Wi-Fi – The website which you access using our Wi-Fi – If you sign onto our Wi-Fi using a social media ID, publicly available social media posts, personal information and demographic data which we obtain from those social media platforms We use this information in combination with other information which we collect to improve our services and send you promotions, surveys, other marketing materials and manage the security of the Centre.
- Conduct consumer profiling and traffic monitoring, which does not identify you, through:
– Camera technology, digital screens and wayfinding kiosks that help us identify the demographics, age groups and genders of customers visiting our Centre – People counters and traffic flow tools which help us better understand and track how busy our Centre is
- Run promotions for which we ask you to provide your name and contact details
- Log health and safety incidents as well as actual or suspected criminal or other illegal activity which takes place at the Centre and collect the name, contact details and incident details (including injury information and criminal offence details) from those involved including witnesses
- Offer you the chance to subscribe to Centre news and promotions by providing your name and contact details
- Conduct market research surveys and interviews as part of collecting your feedback on how we can improve the experience at our locations
Other reasons why we collect your details when you visit the Centre include when you report an incident, lose a family member or friend or property within our Centre, make a complaint, make and inquiry or request assistance from our Centre Management office, or provide other feedback to us.
When you use our digital services When you access or subscribe to our website, online services, social media channels, public Wi-Fi or electronic communications, the kinds of personal information which we may collect both directly and through our service providers include:
- Your name, date of birth, gender, postcode, email and mobile number
- Your preferences, interests and demographic data which allows us to tailor our communications to you regarding Centre news, events and promotions
- Data about your use of our services including information about what parts of these services you access, your IP address, the dates and times at which you use these services and usage data collected through certain website and application monitoring tools
FOR RETAILERS and LICENSEES
In addition to the above information collected from individuals visiting the Centre, the kinds of personal information which we collect from retailers and licensees both directly and through our service providers include: If you lease, license or apply to lease or license space from us
- From retailers and licensees: name, address, date of birth, contact and insurance details, job position as well as information on your business experience, trading history, financial capacity and personal and business assets and liabilities.
- From guarantors: name address, date of birth, contact details, information on your business experience, trading history, financial capacity as well as personal and business assets and liabilities.
- From retailer or licensee personnel: name, job position, contact details and any other information required for registering retailer personnel for Centre services such as retailer car parking programs for which we collect number plate details.
We use this information to:
- Assess whether to grant a lease, license or other rights to use our facilities or services
- Manage our relationship, agreements, payment processing and communications with you
- Manage and operate the Centre in which you lease or license space from us
- Monitor the performance of our Centre
- Contact you in the event of an emergency
- Conduct market research surveys and interviews to gather feedback and better understand how to improve the retailer experience at the Centre
FOR SERVICE PROVIDERS
If you or a company which you work for provides goods and services to us, we collect the personal information which we require in order to manage our relationship with you, including for the purposes of registering your visits to our locations as well as managing onboarding and compliance processes which apply to our service providers.
The kinds of personal information which we collect from you includes:
- Name, address, date of birth, contact details and employment screening results
- Insurance details as well as information on licences, permits and qualifications which you possess
- Information about your financial standing and business experience
- Registers which record the start and end time of your visits or work at the Centre
We collect this information directly from you and from others such as your representative, referees, current and previous employers, professional and trade associations as well as law enforcement agencies and publicly available sources such as LinkedIn.
FURTHER INFORMATION AND YOUR RIGHTS
We collect your personal information directly from you or from third parties such as
- Our service providers
- Our retailers
- Our property owner, joint venture partners and property managers
- From public registers We also collect information, which does not identify you from third parties, such as data businesses and public sources such as Census data.
We may share your personal information with third parties, including:
- Our service providers who assist us with
– Developments, technology services, marketing, communications, research – Business advisory services including legal, accounting and audit – Carpark operations, utilities, cleaning and security services – Contract management and administrative services including mailing, delivery and archiving services – Insurance, banking, payment processing and debt collection services
- With other users of our websites or social media channels where you have chosen to share your personal information with those users through your use of that service
- With agents and advisers and persons acting on your behalf, for example, custodian, asset consultant or person who holds a power of attorney
- With our Centre owner and joint venture partners for whom we provide property management services
- For regulatory and enforcement purposes where necessary in order to report actual or suspected criminal offences, illegal or fraudulent activity to police or other enforcement agencies and to meet our legal and regulatory obligations
How do we store and protect your personal information?
- Electronically obtained personal information are saved directly to our encrypted online server. This information is backed up.
- Personal information obtained in hard copy format is scanned and saved to our server with the hard copy filed in secure onsite storage cabinets.
- Electronic server access and physical access is restricted to employees who need to access personal information, for example when administering a new lease
How we secure your personal information We are committed to protecting your personal information from misuse, unauthorised access or unauthorised disclosure.
- Employees are bound by confidentiality obligations
- Our information technology systems are password, firewall and virus protected to ensure the integrity of our systems that hold your information
- All areas that hold physical copies of your information are protected by electronic access cards or lock-and-key, have key locked cabinets and are limited to specific staff
- Service providers who hold your personal information are contractually required to hold information in accordance with the Privacy Act and we obtain periodic confirmation of adequate information security management.
Disclosure to entities in other countries We use third party companies when performing bulk mail marketing activities. As a result, personal information collected by us is provided to them. These companies use services in the United States and other parts of the world. The personal information we provide is owned by the Centre and will not be used for any other purpose except
Data breach notification Guided by the Notifiable Data Breaches Scheme, we will promptly notify you if we become aware of or have reasonable grounds to believe that your personal information held by us has been lost or subjected to unauthorised access or disclosure which is likely to result in serious harm. We will notify you within 30 days from when the determination has been made that the breach may cause serious harm. We will also notify the Australian Information Commissioner of the data breach. Our assessment and escalation of data breaches will follow our Data Breach Response Plan.
Your rights of access and updating You have the right to access your personal information and may request this information to be corrected or updated. If you wish to make a request to review your personal information, please contact Centre Management using the contact details provided.
Complaints and queries Should you have a need to complain about a possible breach of privacy, or how we have administered your personal information, please contact us on +61 2 9580 0277. Alternatively, you could address your complaint to The Compliance Officer, PO Box 653, Hurstville NSW 1481. Should you wish to contact us to assist you with any enquiries, please use any of the following options:
Phone: +61 2 9580 0277, Monday to Friday between 8.30am to 5.30pm and Saturday and Sunday between 8.30am to 4.00pm. Mail: PO Box 653, Hurstville NSW 1481