Privacy Policy

Harbour Town Privacy Policy

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

2.1 Collection

We will only collect personal   information that we require for the purposes 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).

 

2.2 Storage

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 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

This section of our Privacy Policy   deals specifically with our "online services" including any   services which are provided by us via the Internet. This may include email,  our website at www.harbourtown.com.au and any other promotional websites that may operate from time to   time.

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.

 6.2 Cookies

Our websites may use cookies to make   it easier for you to load the pages on future occasions. Information stored   in cookies is not used by us for the purpose of tracking your use of these   web sites.

6.4 Security

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.

 6.5 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.

 7. Alterations

We reserve the right to amend this   Privacy Policy at any time.

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 appropriate we 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 such 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
147-189 Brisbane Road
BIGGERA WATERS QLD 4216

Phone: 07 5529 1734

Email: privacy@harbourtown.com.au

 

This policy is with effect from 10th February 2104.