Kardinya Park Shopping Centre Privacy Policy
1 INTRODUCTION
This policy details how Dato Holdings Pty Ltd as trustee for the Dato Property Trust, trading as Kardinya Park Shopping Centre, handles personal information in accordance with the Privacy Act and the Privacy Principles. This Policy sets out the kinds of personal information we collect, how that information may be used, and under what circumstances it may be disclosed. In this Policy, 'you' and 'your' refers to any individual about whom we collect personal information.
This Policy does not apply to certain types of information which are not covered by the Privacy Act, including certain employee records in relation to our current or former employees. However, where the personal information we have collected in relation to current or former employees is within the scope of the Privacy Act, this Policy applies to that personal information
2 COLLECTION OF PERSONAL INFORMATION
2.1 The kinds of personal information we collect
Personal information is any information (including an opinion) which can be used to identify you. The types of personal information that Kardinya Park Shopping Centre collects about you will depend upon what dealings you may have with Kardinya Park Shopping Centre.
Examples of where Kardinya Park Shopping Centre may collect and hold your personal information include, but are not limited to, situations where you:
Interact with us in a professional or commercial capacity, including as a customer, a contractor or a business partner;
register or subscribe for electronic newsletters (in person, at our shopping centre or online) customer loyalty programs, competitions or promotions run by Kardinya Park Shopping Centre;
hire mobility equipment in Kardinya Park Shopping Centre;
enter a Kardinya Park Shopping Centre managed shopping centre, building or car park (for example, our camera surveillance systems (commonly referred to as CCTV) may collect footage or still images of individuals and vehicles as well as licence plate details for safety and security purposes);
visit our sites, where you may be required to register before entry for building safety and contact tracing purposes;
use mobile applications developed by Kardinya Park Shopping Centre or logon to wireless facilities provided in Kardinya Park Shopping Centre;
lease, or express an interest to lease, premises, or spaces (including retail pop up spaces), including any related guarantors (for example, when negotiating, entering into or applying to enter into a lease with Kardinya Park Shopping Centre);
seek employment with, or work for, Kardinya Park Shopping Centre including as a contractor (for example, Kardinya Park Shopping Centre may conduct background checks prior to offering you a position of employment);
supply goods and services (for example, when establishing records and systems to enable payment for goods);
use Kardinya Park Shopping Centre's websites, social media and other online services;
otherwise interact with Kardinya Park Shopping Centre.
Kardinya Park Shopping Centre only collects personal information that is reasonably necessary for us to conduct and operate our business. The types of personal information which we may collect include:
personal details (for example, your name, gender, address, email address, contact details, date of birth, photographic or video images);
information needed to verify your identity such as your drivers licence, passport or Medicare details;
your tax file number;
information about your financial position and credit-worthiness;
professional details (such as your occupation and job title);
images from video surveillance and other cameras in our stores (including in car parks, pick up areas and store entrances);
images from facial and biometric data recognition software;
information about you that is required or authorised by law;
your opinions and/or preferences about Kardinya Park Shopping Centre's products, services or staff;
information about how you use our products and services; and
other details regarding our interactions and transactions with you.
2.2 Sensitive Information
Sensitive information is a subset of personal information which includes (for example) information about race or ethnicity, political or religious beliefs, sexual preferences, criminal record and health information (including biometric data).
Kardinya Park Shopping Centre generally does not need to collect sensitive personal information to operate our business. However, in certain circumstances, Kardinya Park Shopping Centre may collect sensitive information about you if it is reasonably necessary to do so.
Where this is required, we will obtain your consent to collect this information. Your consent to our collection and retention of this information can be withdrawn at any time by contacting Kardinya Park Shopping Centre (refer to details at Section 11). To update sensitive information, refer to Section 8 of this Policy.
2.3 Applying for employment with Kardinya Park Shopping Centre
Kardinya Park Shopping Centre collects personal information from you if you submit an application or register interest for employment with Kardinya Park Shopping Centre, such as your name, title, gender, date of birth, contact details, qualifications and work history (including references and other information included in a CV, resume or cover letter as part of the application process). Generally, we will collect this information directly from you.
2.4 Information collected online
Kardinya Park Shopping Centre may collect the following information from you if you interact with us online, including when you use an application developed by us:
(a) Cookies
A cookie is a small data file that may be placed on your computer (usually in the browser software folder) during a visit to Kardinya Park Shopping Centre's website. Cookies are necessary to allow Kardinya Park Shopping Centre's website and your computer to interact effectively and enhance security. Cookies can record information about your visit to assist Kardinya Park Shopping Centre in better understanding your needs. For example, this data may be collected and used to infer demographic information about you using various web analytic technologies. Kardinya Park Shopping Centre sometimes also uses performance tracking technology (such as conversion tags) to help Kardinya Park Shopping Centre to track your behaviour on our websites. General user traffic and performance tracking data is collected on an aggregate level to report statistics to assist Kardinya Park Shopping Centre to improve the quality and relevancy of its services. If you have completed the online registration form on Kardinya Park Shopping Centre’s websites, cookie data may be linked to the personal information Kardinya Park Shopping Centre holds about you. In these circumstances, this cookie data will be treated the same manner as the personal information to which it has been linked.
Kardinya Park Shopping Centre may also use cookies from third party ad servers for the purpose of targeting our online advertisements on other sites. The cookies provided by the third-party ad servers will collect information about the device you use to access our website (such as the type of device, the browser type or the operating system), your browsing behaviour (such as what you searched for, the pages you viewed, the date and time of the visit and how long you stayed) and the performance of our marketing campaigns (such as which ads or online content the user viewed or accessed). The information collected through this technology is not personally identifiable but such information will be shared with the third-party ad servers for the purposes of showing you more relevant advertising on Kardinya Park Shopping Centre’s websites or partner sites.
If you access a Kardinya Park Shopping Centre group website and do not wish to receive any cookies, you should set your browser to refuse cookies. If you do so you may not be able to use certain parts of the Kardinya Park Shopping Centre website. If you do not want third party ad servers to use cookies for targeted advertising purposes, you can use an opt out mechanism provided by various advertising industry bodies such as Network Advertising Initiative opt-out (http://www.networkadvertising.org/choices/DAA).
(b) Wi-Fi networks, Bluetooth (or similar)
Where electronic devices such as mobile phones and tablets are enabled to allow connectivity to and are detected by Wi-Fi networks, Bluetooth (or similar) in Kardinya Park Shopping Centre managed buildings or shopping centres, Kardinya Park Shopping Centre may automatically collect data relating to the device identification code and its location. Kardinya Park Shopping Centre may use the anonymised data to create aggregate information to, among other things, analyse shopping behaviour to improve its shopping centres, but the aggregate information will not identify you. If you do not wish to have your device identification code detected, you should disable the Wi-Fi network, Bluetooth (or similar) connectivity of your device.
When you register to use Wi-Fi services provided by Kardinya Park Shopping Centre, Kardinya Park Shopping Centre collects your personal information in relation to your use of the Wi-Fi services, and for any other purposes you consent to at the time of registration.
(c) Applications
When you download and use applications developed by Kardinya Park Shopping Centre, Kardinya Park Shopping Centre may collect and use your personal information in relation to your use of those applications, and for any other purposes which you consent to at the time. Where it does so, Kardinya Park Shopping Centre will handle your personal information in accordance with any applicable terms of use of the application, and this Policy.
(d) Website Analytics
Kardinya Park Shopping Centre’s websites use, among other technologies, Google’s suite of analytics programs to track website traffic. Where you have chosen to enable Google to associate your web and app browsing history with your Google account, and to use information from your Google account to personalise ads, Google will use data from its signed-in users together with Kardinya Park Shopping Centre ’s Google Analytics data to build audience lists for cross-device remarketing. For users of Kardinya Park Shopping Centre’s websites, Google Analytics will collect Google-authenticated identifiers associated with your Google Accounts (and therefore, personal information). Google Analytics will also temporarily join these identifiers to Kardinya Park Shopping Centre’s Google Analytics data. If you do not wish to have your Google-authenticated identifiers joined with Kardinya Park Shopping Centre’s Google Analytics data, you should opt out of the ‘personalised ads’ option via your Google account.
2.5 How Kardinya Park Shopping Centre collects your personal information
As long as it is reasonable and practicable for us to do so, Kardinya Park Shopping Centre will usually only collect personal information about you directly from you. However, in some circumstances, it may be necessary for us to access or collect personal information about you from a third party, including an agent, employee or Kardinya Park Shopping Centre’s authorised agents, service providers and subcontractors.
3 NOTIFICATION OF COLLECTION OF PERSONAL INFORMATION
Kardinya Park Shopping Centre takes reasonable steps to provide a privacy collection statement at the time we collect personal information from you. This privacy collection statement will generally include details about the purpose of the collection, the entities that your personal information will be disclosed to, overseas recipients of your personal information (where applicable), and that this Policy contains information about how you may access your personal information held by Kardinya Park Shopping Centre and how you may make a complaint.
4 USE AND DISCLOSURE OF PERSONAL INFORMATION
Kardinya Park Shopping Centre handles personal information in a number of ways. The personal information we collect will generally be used or disclosed for the purposes for which it is collected, and for any other purpose related to that primary purpose and for which you might reasonably expect us to use it (including as described in this Policy).
In general, Kardinya Park Shopping Centre uses personal information for the following purposes:
to manage our relationship with you;
to provide products or services that have been requested by you;
to communicate with you;
to manage and enhance our products and services, including analysing customer feedback and future customer needs;
to provide ongoing information and marketing about products and services that Kardinya Park Shopping Centre believes you may be interested in, where you have requested or agreed to receive this information or have not opted out;
to manage security and safety requirements in Kardinya Park Shopping Centre managed buildings and sites;
in the case of images from facial recognition software, for loss prevention or shopping centre safety purposes;
to assess your suitability as a prospective tenant, employee or business partner;
to engage contractors; and
to comply with our regulatory and legal obligations
Your personal information may be disclosed to other entities associated with the Kardinya Park Shopping Centre and used by those entities for the same purposes for which we are entitled to use it.
4.1 Disclosures of personal information to external third parties
We may also disclose your personal information to external third parties in certain circumstances where authorised or permitted by law. Those third parties may include:
Kardinya Park Shopping Centre 's contractors, consultants, advisers and service providers who assist Kardinya Park Shopping Centre in the operation of its business or provide services to us or our customers (for example, a company which helps maintain Kardinya Park Shopping Centre's computer systems or sends out Kardinya Park Shopping Centre's mail);
joint venture partners for the purposes of seeking relevant regulatory approvals;
third party lenders and insurers;
the Australian Securities Exchange, the Australian Securities and Investments Commission and other regulatory authorities or government agencies as agreed to or required by law;
anyone authorised by you; and
relevant external third parties in situations when Kardinya Park Shopping Centre is required by law to provide the information.
Kardinya Park Shopping Centre does not sell personal information. Some of our service providers may be located overseas or may store information (including your personal information) that we provide to them overseas. Personal information you disclose to us will only be held or processed overseas in accordance with all applicable law.
5 DIRECT MARKETING
Kardinya Park Shopping Centre may use or disclose your personal information for the purpose of sending you marketing materials to inform you about our products and services, upcoming promotions and events, or other opportunities that may interest you or as otherwise permitted under applicable laws.
The individual’s prior consent will be obtained before personal information is used for marketing purposes in situations where the personal information has been collected from the individual and the individual would not reasonably expect Kardinya Park Shopping Centre to use the information for that purpose, the personal information has not been collected directly from the individual or where sensitive information is involved. If you no longer wish to receive marketing materials from us, you can opt-out via the relevant method provided for in an electronic marketing message you receive (e.g. via an ‘unsubscribe’ link) or write to Kardinya Park Shopping Centre at any time.
If you opt-out of receiving marketing material from us, Kardinya Park Shopping Centre may still contact you in relation to our ongoing relationship with you.
6 SECURITY OF PERSONAL INFORMATION
Kardinya Park Shopping Centre stores information in paper-based files or electronic record keeping methods in secure databases (including trusted third-party storage providers based in Australia and overseas). Personal information may be collected in paper-based documents and converted to electronic form for use or storage (with the original paper-based documents either archived or securely destroyed).
Kardinya Park Shopping Centre takes reasonable steps to protect personal information that it holds from misuse, interference and loss and from unauthorised access, modification or disclosure. Kardinya Park Shopping Centre maintains physical security measures over its physical premises and paper data stores (including through locks and security systems at our premises), and a range of computer and network security measures over its electronic systems (such as systems access, user identifiers and passwords, multi-factor authentication, firewalls and data encryption while data is in transit and at rest). Our websites use encryption and other technologies to ensure the secure transmission of information via the internet. Notwithstanding our use of encryption or other technologies to ensure secure transmission of information, users of our websites are encouraged to exercise care in sending personal information via the internet.
7 ACCESS TO YOUR PERSONAL INFORMATION
You are entitled to access your personal information, including any sensitive information in relation to you, held by Kardinya Park Shopping Centre on request. To request access to this information, please contact the Kardinya Park Shopping Centre (refer to contact details in Section 11). Kardinya Park Shopping Centre will require evidence to verify your identity prior to determining if your request can be fulfilled.
This service is free of charge unless the personal information requested requires additional preparation time. In this situation, Kardinya Park Shopping Centre will provide a reasonable estimate of how much this service will cost and request agreement from you before proceeding.
In normal circumstances, Kardinya Park Shopping Centre will provide you with access to your personal information. However, in some circumstances, there may be legal, regulatory or administrative reasons to deny your requested access. If access is denied, Kardinya Park Shopping Centre will provide you with the reasons for doing so.
8 CHANGING YOUR PERSONAL INFORMATION
We will take reasonable steps to ensure that the personal information we collect, use or disclose is accurate, complete and up-to-date. You can help us to do this by letting us know if you notice errors or discrepancies in information we hold about you and letting us know if your personal details change.
If you consider any personal information we hold about you is inaccurate, out-of-date, incomplete, irrelevant or misleading you are entitled to request the correction of your personal information by contacting Kardinya Park Shopping Centre (refer to contact details in section 11). After receiving a request from you, we will take reasonable steps to correct your information.
We may decline your request to correct your personal information in certain circumstances in accordance with the Privacy Principles. If we do refuse your request, we will provide you with the reasons for doing so and will include a statement with your personal information about the requested correction.
9 RETENTION OF PERSONAL INFORMATION
Where we no longer need to use or disclose your personal information for any purpose required under the Privacy Act, this Policy, or where we are not otherwise legally required to retain that information, we will take reasonable steps to either destroy or de-identify personal information.
10 COMPLAINTS
You can make a complaint by contacting Kardinya Park Shopping Centre if you believe that we have breached our obligations under the Privacy Act or failed to comply with this Policy. Any complaint should be made in writing and sent to us using the contact details in Section 11.
Kardinya Park Shopping Centre takes privacy-related complaints very seriously. We will acknowledge receipt of your complaint within a week and endeavour to complete our investigation into your complaint promptly. First, we will consider your complaint to determine whether there are simple or immediate steps which can be taken to resolve the complaint.
If your complaint requires more detailed consideration or investigation, we may ask you to provide further information about your complaint and the outcome you are seeking. We will then typically gather relevant facts, locate and review relevant documents and speak with individuals involved.
In most cases, we will investigate and respond to a complaint within 30 days of receipt of the complaint. If the matter is more complex or our investigation may take longer, we will let you know.
If you are not satisfied with our response, or we have not responded to your complaint within 30 days, you can refer your complaint to the Office of the Australian Information Commissioner (OAIC).as follows:
Phone: 1300 363 992
Web: www.oaic.gov.au
Address: GPO Box 5218 Sydney, NSW 2001
11 CONTACTING KARDINYA PARK SHOPPING CENTRE
The Kardinya Park Shopping Centre Privacy Officer can be contacted as follows:
Phone : (08) 9337 5522
Email: kardinya@metwaywa.com
Address Kardinya Park Shopping Centre
Corner of South Street and North Lake Road
Kardinya WA, 6160
12 CHANGES TO THIS POLICY
We may update this Policy from time to time to reflect our current information handling practices, to take account of new laws and technologies or the changing business environment, and to reflect changes to our operations and practices.
When we do so, the updated Policy will be available on the Kardinya Park Shopping Centre website at https://www.kardinyapark.com/ We recommend that you regularly visit our website and review this Policy.
13 APPROVED AND ADOPTED
This Policy was last approved and adopted by Kardinya Park Shopping Centre on 5 April 2023.
