This information explains how we comply with Australian privacy requirements. This information may be updated from time to time.
Our system for complying with Australian privacy requirements includes:
our commitment to compliance with privacy requirements;
our policy and approach to privacy, as explained in this information;
our resources allocated to privacy, including our technology systems and services; and
our people and the training and education we undertake.
Collecting your Personal Information
When you deal with us, we collect personal information about you such as your name, your contact details, and other information about your circumstances and preferences. Where we do not have your personal information, we are not able to contact you, process your requests, or provide our services to you (including our free Guest Wifi Service).
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 about you, 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).
If you access or use our free Guest Wifi Service, you may also provide us with personal information and other information about you which we collect including your name, age, gender, birthday, contact details, information publicly available on your social network such as your Facebook profile (such as your country, employer, age, location). We, and our third party business partners, may also collect other information in respect of your use of the Service including:
the time, date and location of registration;
the duration and frequency of your use of the Service and visits to Harbour Town brand direct outlets;
the approximate location of your device while visiting Harbour Town brand direct outlets;
general information from your browsing device such as the MAC address of your computer or device (which includes device location and movement data).
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 or log on, or access our Guest Wifi service provided in Harbour Town brand direct outlets.
We may also collect your personal information from third parties or from publicly available sources to enable us to contact you and offer our products and services to you, and in doing so we comply with requirements including providing a facility to allow you to indicate your preferences in relation to contact.
Like many companies, we use technology and tools that tell us when a computer or device has visited or accessed our content. Those tools include services from search engines and other companies that help us to tailor our products and services to better suit our customers and potential customers. Search engines provide facilities to allow you to indicate your preferences in relation to the use of those tools in connection with computers and other devices controlled or used by you.
Using your personal information
We use your personal information for our business and activities, and in our efforts to expand and improve our business. Examples include:
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;
to operate forums in different media in which you are able to share information, including your personal information, with us and publicly (on the Terms applicable),
to measure and analyse shopping behaviour, and improve our website and our services to you, including your in-Centre experience;
to respond to and process your requests such as for information or services;
to administer promotional programmes, such as competitions, rewards and rebate programmes;
to provide you with marketing communications and invitations and offers for products and services including new products and services that we, or our third party business partners, have not offered before but we believe may be of interest to you (and we will provide you with an opportunity to opt out) and to assist in developing new products and services;
for a business or professional relationship we may have with you;
if you apply for employment with us, to consider your application;
for our research and development efforts; and
for other everyday business purposes that involve use of personal information.
If we use your personal information to contact you and you would prefer not, please let us know and we will do our best to respect your preference.
When your choice is to continue to deal with us (including when you register, access and use our free Guest Wifi Service), we take it that you agree to and consent to our using your personal information in these ways, providing we follow the system and approach we explain in this information and comply with the law.
Storing and disclosing your personal information
In using your personal information, we may disclose your personal information to:
others, like our agents, contractor or external service providers (such as mailing houses and third party storage providers, or external service providers in relation to our Guest Wifi service) 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);
other companies in the Harbour Town group of companies;
the owners of the Harbour Town brand direct outlets and their related companies; and
regulatory bodies, government agencies and other parties as permitted by law.
Your personal information may be held and processed overseas by our related companies, or service providers. When we pass on or share your personal information in this way, we take steps to ensure it is treated in the same way that we would treat it.
By providing us with your personal information you consent to us (or sometimes our third party business partners) 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 do our best to keep our records of your personal information up to date and accurate and not to keep personal information that is no longer needed.
We also share with others and disclose information from which personal information has been removed so that no privacy is affected.
We sometimes have to pass on personal information for legal or safety reasons or other special circumstances.
Disclosure to third party business partners: we sometimes disclose your personal information to third party business partners who market offers directly to you, giving you a way to opt out of further offers if you prefer.
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.
We use various systems and services to safeguard the personal information we store, as part of our business systems and processes. We take reasonable steps to protect your personal information from misuse, interference or loss and unauthorised access, modification and disclosure with appropriate safeguards and security measures and restrict access to those who have a legitimate business purpose and reason for accessing it.
Personal information is only retained for as long as it is necessary for the identified purposes, to the extent necessary for purposes reasonably related to those identified purposes (for example, resolving disputes) or as required by law.
You should keep in mind that no internet transmission is ever completely secure or error-free. 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 any data transfer over the Internet cannot be guaranteed. When you share information with us, it is at your own risk. If you reasonably believe that there has been unauthorised use or disclosure of your personal information please contact us (see below).
Contact with Harbour Town about your personal information
You may wish to contact us to access your personal information, to seek to correct it or to make a complaint about privacy. Our privacy email contact address is [email protected], and further contact details for Harbour Town are set out below;
The Privacy Officer
Harbour Town Centre Management Pty Ltd
147-189 Brisbane Road
Phone: +61 7 5529 1734
We will respond as soon as we reasonably can including, in the case of access and correction requests, if we are unable to provide you with access (such as when we no longer hold or use the information).
We do not impose any charge for a request for access, but we may charge you a reasonable fee for our costs associated with providing you with access and retrieval costs.
For complaints about privacy, we will establish in consultation with you a reasonable process, including time frames, for seeking to resolve your complaint.
Last updated: October 2017