Who are we?
‘We’, ‘us’ and ‘our’ refer to NPSC Pty Ltd ACN 635 273 835 and our related businesses.
Our commitment to protect your privacy
We understand how important it is to protect your personal information. This document sets out our commitment in respect of the personal information we hold about you and what we do with that information.
We recognise that any personal information we collect about you will only be used for the purposes we have collected it for or as allowed under the law. It is important to us that you are confident that any personal information we hold about you will be treated in a way which ensures protection of your personal information.
Our commitment in respect of personal information is to abide by the Australian Privacy Principles (APPs), the Privacy Act and any other relevant law.
When we refer to personal information we mean information from which your identity is reasonably apparent. This information may include information or an opinion about you. The type of personal information that we collect will depend upon what dealings you may have with us.
The kinds of personal information we may collect about you will depend on the nature of your interactions with us, but will include your name, date of birth, address, account details, occupation, photographic or video images and any other information we made need to identify you. When you use our website or mobile applications we may collect information about your location or activity including IP address, telephone number and whether you have accessed third party sites, the date and time of visits, the pages that are viewed, information about the device used and other user location information.
How we collect your personal information
Where reasonable and practical we will collect your personal information directly from you. We may also collect information from you indirectly, anytime you:
- communicate or interact with us, whether this is by phone, email, face to face meeting, online or social media interaction;
- use our websites or our Wi-Fi services;
- participate in our surveys, competitions, loyalty programs or promotions;
- you apply for a position with us through our recruitment process.
We may collect information about you that is publicly available, for example from public registers or social media, or made available by third parties.
Why we collect your personal information
We collect personal information for a number of different purposes including:
- to provide you with our goods and services, to do business with you and to communicate with you;
- when you attend our shopping centres, buildings and car parks under video and camera surveillance. When entering our shopping centres and car parks, customers’ personal information, car licence plate details and images may be collected by us, and we may also collect your personal information and images from third parties (for example, the police or retailers) in connection with the management and security of our shopping centres. This information may be used by us in connection with the management and security of our shopping centres, loss prevention, incident investigations and other purposes set out in this policy or as permitted by the law. This information may be provided to law enforcement and government bodies, our staff and subcontractors, third parties who provide us with services from time to time, insurers and retailers for those purposes;
- when you park in our car parks with a ticketless parking system or car locator functionality, you consent to provide us with your car licence plate details and, in some circumstances, other information including name, email address and telephone number. These details are used for measuring and analysing car parking dwell times and shopper behaviour in order to improve our shopping centres, for the purposes of managing car parking at the centre, marketing purposes and also to assist customers to locate your cars including via online and mobile applications;
- to assess the suitability of prospective employees;
- with respect to tenants or retailers of our shopping centre premises:
- to assess the suitability of prospective tenants/licensees (including any related guarantors);
- to manage our relationship with you;
- to manage the security of our shopping centre premises;
- to monitor the performance of the shopping centre generally; and
- to process rental or other payments; and
- in connection with competitions or signing up to emails, mobile newsletters (either in one of our shopping centres or online), customer loyalty programs, competitions, promotions or events that we run;
- when you use mobile applications developed by us, or logon to Wi-Fi provided in our shopping centres or third party applications utilising our infrastructure, you provide us with certain information including your contact details, your device ID, IP address and MAC address, geo-location information and any movement throughout our premises and any other information you voluntarily provide us while accessing our Wi-Fi networks. We collect this information to enable you to be informed about upcoming events, activities and promotions, both in the shopping centre and as part of our other activities, sponsor and retailer promotions, and other activities, which will be notified as you sign in to use those facilities;
- for the purposes of direct marketing and managing our relationship with you. Improvements in technology also enable organisations like ours to collect and use information to get a more integrated view of our customers. From time to time we may offer you other products and services;
- in connection with the management and security of your shopping centres generally, to obtain feedback about your experiences at a centre (including with our retailers), and may be provided to law enforcement and government bodies, insurers, our staff and subcontractors, third parties who provide us with services from time to time and retailers for these purposes;
- help us manage and enhance our products and services, including analysing customer feedback and future customer needs; and
- to comply with regulatory and legal obligations.
Do we disclose your personal information?
We may disclose your personal information:
- to other organisations that are involved in managing or administering our services such as third party suppliers, printing and postal services, call centres, security providers, facilities management providers, integrated services providers and insurers;
- to associated businesses that may want to market products to you;
- to companies that provide information and infrastructure systems to us to include website providers;
- to our agents, contractors, advisers, external service providers to outsource certain functions, for example, information technology support and adjunct marketing services;
- to anybody who represents you, such as finance brokers, lawyers, mortgage brokers, guardians, persons holding power of attorney and accountants;
- to anyone, where you have provided us consent;
- to other lessees and guarantors in relation to a lease, licence or other agreement with you;
- to our auditors, insurers, re-insurers and health care providers;
- to claims related providers, such as assessors and investigators who help us with claims;
- where we are authorised to do so by law;
- to investors, agents or advisers, trustees, rating agencies or any entity that has an interest in our business;
- organisations that provide products or services used or marketed by us; or
- to your employer, former employer, referees or identity verification services.
Prior to disclosing any of your personal information to another person or organisation, we will take all reasonable steps to satisfy ourselves that:
(a) the person or organisation has a commitment to protecting your personal information at least equal to our commitment, or
(b) you have consented to us making the disclosure.
Disclosure to overseas entities
We may disclose your personal information to overseas entities that provide support functions to us. This will include disclosure to the USA and Germany.
From time to time we may use your personal information to provide you with current information about offers you may find of interest, changes to our organisation, or new products or services being offered by us or any company with whom we are associated.
These communications may be sent in various forms, including by telephone, post, fax, email, SMS or any other form of electronic communication, in accordance with the Privacy Act and the Spam Act 2003 (Cth).
If you do not wish to receive marketing information, you may at any time decline to receive such information by telephoning us on (02) 9518 0660 or by writing to us at firstname.lastname@example.org. If the direct marketing is by email you may also use the unsubscribe function. We will not charge you for giving effect to your request and will take all reasonable steps to meet your request at the earliest possible opportunity.
Updating your personal information
It is important to us that the personal information we hold about you is accurate and up to date. During the course of our relationship with you we may ask you to inform us if any of your personal information has changed.
If you wish to make any changes to your personal information, you may contact us. We will generally rely on you to ensure the information we hold about you is accurate or complete.
Access and correction to your personal information
We will provide you with access to the personal information we hold about you. You may request access to any of the personal information we hold about you at any time. We may charge a fee for our costs of retrieving and supplying the information to you.
Depending on the type of request that you make we may respond to your request immediately, otherwise we usually respond to you within seven days of receiving your request. We may need to contact other entities to properly investigate your request.
There may be situations where we are not required to provide you with access to your personal information, for example, if the information relates to existing or anticipated legal proceedings, if your request is vexatious or if the information is commercially sensitive.
An explanation will be provided to you, if we deny you access to the personal information we hold about you.
If any of the personal information we hold about you is incorrect, inaccurate or out of date you may request that we correct the information by telephoning us on (02) 9518 0660 or by writing to us at email@example.com.
If appropriate we will correct the personal information at the time of the request, otherwise, we will provide an initial response to you within seven days of receiving your request. Where reasonable, and after our investigation, we will provide you with details about whether we have corrected the personal information within 30 days.
We may need to consult with other entities as part of our investigation.
If we refuse to correct personal information we will provide you with our reasons for not correcting the information.
What happens if we cannot identify you?
In most circumstances it will be necessary for us to identify you in order to successfully do business with you, however, where it is lawful and practicable to do so, we will offer you the opportunity of doing business with us without providing us with personal information, for example, if you make general inquiries about current promotional offers.
Sensitive information is personal information that includes information relating to your racial or ethnic origin, political persuasion, memberships in trade or professional associations or trade unions, sexual preferences, criminal record, or health.
We will only collect sensitive information about you with your consent, for example if you are involved in an accident we may collect medical information and incident reports. CCTV footage may contain sensitive information, and as such its use and release is governed by additional policies, this is covered in more detail in the section dealing with access to personal information.
How safe and secure is your personal information that we hold?
We will take a range of measures and reasonable steps to protect your personal information. Your personal information will always be stored in a secure environment. We may store your personal information in paper and electronic form. We will also take reasonable steps to protect any personal information from misuse, loss and unauthorised access, modification or disclosure.
Information from third parties
Our website may contain links to the websites of third party providers of goods and services (Third Party websites). If you have accessed Third Party websites through our website, and if those third parties collect information about you, we may also collect or have access to that information as part of our arrangements with those third parties
Where you access a Third Party website from our website, cookie information, information about your preferences or other information you have provided about yourself may be shared between us and the third party.
Advertising and tracking
When you view our advertisements on a Third Party website, the advertising company may use ‘cookies’ and in some cases ‘web beacons’ to collect information such as:
- the server your computer is logged onto;
- your browser type;
- the date and time of your visit; and
- the performance of our marketing efforts.
When you access our website after viewing one of our advertisements on a Third Party website, the advertising company collects information on how you utilise our website (eg which pages you view).
We use ‘cookies’ to provide you with better and more customised service and with a more effective website.
A ‘cookie’ is a small text file placed on your computer by our web page server. A cookie can later be retrieved by our webpage servers. Cookies are frequently used on websites and you can choose if and how a cookie will be accepted by configuring your preferences and options in your internet browser.
- to allocate a unique number to your internet browsers;
- to customise our website for you;
- for statistical purposes;
- to identify if you have accessed a Third Party website; and
- for security purposes.
Your IP address is the identifier for your computer when you are using the internet.
It may be necessary for us to collect your IP address for your interaction with various parts of our website.
If you are dissatisfied with how we have dealt with your personal information, or you have a complaint about our compliance with the Privacy Act, you may contact us on (02) 9518 0660 or by writing to us at firstname.lastname@example.org.
We will acknowledge your complaint within seven days and aim to resolve the complaint as quickly as possible. We will provide you with a decision on your complaint within 30 days.
If you are dissatisfied with the response of our complaints officer you may make a complaint to the Office of the Australian Information Commissioner which can be contacted on either www.oaic.gov.au or 1300 363 992.
You may request further information about the way we manage your personal information by contacting us.
We are constantly reviewing all of our policies and attempt to keep up to date with market expectations. Technology is constantly changing, as is the law and marketplace practices.
As a consequence we may change this policy from time to time or as the need arises. We will post any changes to this policy on our website.
You may request this policy in an alternative form by telephoning us on (02) 9518 0660 or by writing to us at email@example.com.