1. WHO is collecting your private information

Market Square Shopping Centre (Market Square), owned by Davinski Nominees and managed by Knight Frank Pty Ltd, is committed to securely managing and using your private information provided to Market Square in accordance with its obligations under the Privacy Act 1988 (Cth) (the Privacy Act) and, in particular, the Australian Privacy Principles (APPs).

This information may be collected directly by Market Square or through a third party, such as our website hosts, our security contractors, etc. Information you provide to a tenant (i.e. retailer, service provider or casual lease) within Market Square is governed by their privacy policy which you can request directly from them.

2. WHY & HOW is Market Square collecting your private information

Under the Privacy Act, personal information is broadly defined. In simple terms it means any information about an individual (i.e. a natural person) who can be identified from the information, whether the information is true or not and whether recorded in a material form or not.

Market Square collects personal information as reasonably necessary to provide its services and to manage its relationships with clients and other parties. Information will be collected in a variety of different methods (i.e. in person, through digital and social media/ technology, over the phone, face-to-face, in writing, etc.) The type of information collected will depend on the circumstances in which you have engaged with the Centre, however examples are given below:

• To provide our services to clients;
• To manage third party relationships including with contractors and consultants;
• For security purposes (e.g. details collected at open inspections); and
• To conduct marketing activities, including keeping individuals informed about our services and properties we are dealing with.

Market Square will collect personal information directly from the individual to whom it relates whenever practicable. This may be done verbally (e.g. in person or over the telephone), in writing (e.g. by letter, fax, email, application or other form) or through contact via our any of our managed digital media channels.
In circumstances where it is not practicable to collect the information directly from the individual, Market Square may collect the information via third parties. This may occur, for example:

• From the individual’s employer;
• From credit reference agencies and financial institutions;
• From other agents and valuers who work with us;
• From property owners for whom we market properties or provide other services;
• From referees;
• From our contractors;
• From market research companies contracted by us to obtain information in relation to our services or from which we purchase mailing lists;
• From recruitment agencies; or
• From publicly available information and databases.

The types of personal information collected will depend on the services being provided and the circumstances of collection. Examples of private information collection include:

• Property transactions – we may collect personal information from the parties involved (including vendors, purchasers, landlords, tenants etc.) such as name, address, email address, telephone numbers, fax number, date of birth, gender, marital status, tax file number, details of employment and/or occupation, and financial information.
• Employment Applications – Market Square will also collect personal information from job applicants seeking employment with Knight Frank.
• Marketing Purposes – through Market Square digital media’s including social media applications, SMS and other digital technologies to communicate with you about events, specials, competitions and other marketing purposes. This information is collected for the purpose of analysis and marketing communications and is never sold or given to a third party. All marketing communications can be ceased by opting out or by contacting Market Square Centre Management.
• Cookies (small files placed on a user’s computer when you access a website) – are used on our website. Most web browsers allow you to control whether to accept Cookies. Unless you elect not to accept Cookies on your browser, the Market Square website will automatically place a Cookie on your computer to enable you to make full use of our website’s functionality.
• Competitions and events – (which can be within the Centre in paper format, through our website or other social media outlets, mobile, etc). This information will be used to sign you up to our VIP database and to contact the winner of the relevant competition.
• In the case of emergency, incident, police matter or similar.
• For the use of mobility aids.
• From contractors working at Market Square.
• Close Circuit TV (CCTV) – cameras are used within and around Market Square for your security. Information collected will only be shared upon request from the Police, relevant Government authority, Market Square staff or retailers for relevant security issues. If you require CCTV footage, you must first contact the Police, who will then contact us if CCTV footage is required.

From time to time, Market Square may include links on its website to the websites of other organisations. Market Square is not responsible for the content or privacy practices of those other websites or organisations.

Sensitive information

Sensitive information is a type of personal information that attracts special treatment under the Privacy Act. It includes information about a person’s:

• racial or ethnic origin
• political opinions or membership
• religious or philosophical beliefs and affiliations
• membership of a professional or trade association, or trade union
• sexual orientation or practices
• criminal record

If it is necessary to collect sensitive information from an individual, their consent will be obtained.

3.STORAGE of your Personal Information

Personal information received by Market Square is held securely, either in electronic files on Market Square’s computer systems or in physical files held on Market Square’s premises.

Your information is securely stored and electronic information is protected by a firewall and host-based security. Although Market Square endeavours to protect your electronic information to the highest standards, no data transferred electronically is 100% secure. To increase your electronic security, Market Square recommends you always close your browser upon completion of your session and do not share your personal information with others.

4. Disclosure of personal information to third parties

Knight Frank may disclose personal information to third parties – for example, to our contractors, customers/clients, potential vendors, purchasers, landlords or tenants, media organisations, other agents and their customers/clients, owners’ corporations/bodies corporate, and to parties engaged to evaluate a property – for the purpose for which the information was collected or related purposes (such as to complete a transaction or provide a requested service).

Personal information may also be disclosed to advisers (including but not limited to solicitors), financial institutions, government and statutory bodies, and to third party contractors engaged by Knight Frank (e.g. valuers, debt collection services, printing and mailing services, payroll and accounting services, information technology, marketing).

Personal information may be shared between Knight Frank Group companies (both within and outside Australia) where necessary for our purposes.

Personal information may be disclosed to overseas recipients, including but not limited to Knight Frank Group companies. Overseas recipients are likely to be located in the United Kingdom and Singapore.

Where we disclose personal information to another party, we will require the third party to use the personal information only for the specific purposes for which we supply the information.

Information collected for the purposes of marketing will not be sold or passed onto third parties unless you have authorised it or it is required by law.

5. How to request access or correct personal information

Under the Privacy Act, you have the right to seek access to personal information we hold about you, subject to some exceptions.

To request access or correct personal information, or to obtain more information about Market Square’s privacy policy, firstly direct your enquiry to Market Square:

Market Square Shopping Centre Manager – Sandy Kelly Burton
By telephone: 03 5221 2411
By Letter to:  Centre Management, Market Square Shopping Centre, Corner Moorabool & Malop Streets, Geelong, VIC, 3220.
By Email to: sandy.kellyburton@au.knightfrank.com

Secondly, to Knight Frank’s Privacy Officer who can be contacted:

By telephone: 03 8682 0666
By letter to: The Privacy Officer, Knight Frank, Level 31, 360 Collins Street, Melbourne, 3000
By email: privacy@au.knightfrank.com

Market Square and Knight Frank will respond to a request for access within a reasonable period of time. Where we refuse access, we will where possible provide you with a written notice setting out our reasons for the refusal and the avenues for complaint about the refusal.

We may charge a fee for providing access to personal information. No fee is charged for the making of a request for access.

6. How to get more information or make a complaint

Please direct any questions about this policy or complaints about a breach of privacy by Knight Frank firstly to:
Market Square Shopping Centre Manager – Sandy Kelly Burton
By telephone: 03 5221 2411
By Letter to: Centre Management, Market Square Shopping Centre, Corner Moorabool & Malop Streets, Geelong, VIC, 3220.
By Email to: sandy.kellyburton@au.knightfrank.com

Secondly, to Knight Frank’s Privacy Officer who can be contacted:

By telephone: 03 8682 0666
By letter to: The Privacy Officer, Knight Frank, Level 31, 360 Collins Street, Melbourne, 3000
By email: privacy@au.knightfrank.com

POLICY EFFECTIVE APRIL 2014

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