P.T. Limited ACN 004 454 666 as custodian for the Charter Hall Office Collins Street Trust and CBUS Property Pty Ltd ACN 115 826 741 (“171 Collins Street”) respects the privacy of personal information. This Privacy Policy sets out our personal information management practices.
171 Collins Street is committed to ensuring the confidentiality and security of individuals’ personal information. We recognise that your privacy is very important to you and that you have a right to request access and correct your personal information. We know that providing personal information is an act of trust and we take that seriously.
We are committed to complying with applicable privacy laws in relation to the personal information that we collect in the course of running our business. Where applicable privacy laws provide for exceptions or exemptions, we may rely on those exceptions or exemptions in our information handling practices. Personal information will be treated confidentially and we will not use or disclose personal information for the purpose for which it was collected or any reasonable secondary purpose, or as otherwise permitted by law, as further described below.
While reasonable steps are taken to protect all the personal information in our possession that we have collected via the Website, 171 Collins Street cannot guarantee the security of all data submitted to us over the internet.
The Website has been designed to provide Tenant services and facilities online. This privacy policy applies to any users of our Website or any application (including any mobile or tablet application hosted by third parties for us) or device functionality which refers to this privacy policy. By using any 171 Collins Street website or application, you agree to our Privacy Policy. We outline our approach to privacy and the handling of personal information below.
We are guided by the Australian Privacy Principles as set out under the Privacy Act 1988 (Cth).
171 Collins Street may handle personal information relying on exemptions under these laws, such as in the case of employee records. Any permitted handling of personal information under such exemptions will take priority.
The types of personal information we collect about you depends on the circumstances in which the information is collected. Typically, including where you register as a tenant on our Website, the types of personal information we collect can include (but are not limited to) your basic contact details (such as your name, address, email address and mobile number).
If we enter into contracts with you to request or receive goods or services from us or have any other commercial dealings with us, we may also collect your signature, date of birth, credit card or bank details and billing information.
If you attend a premises we operate or manage, we may:
If you call us via telephone, we may monitor and in some cases record such telephone conversations for staff training, quality assurance and record-keeping purposes.
When you access our Website or mobile application:
Like most standard websites we use log files to administer the site, track usage and analyse trends of users. This data is collected as an aggregate and are not linked in any way to personally identifiable information.
We only collect sensitive information about you with your consent, or otherwise in accordance with the Privacy Act. The main types of sensitive information we may collect include:
If you do provide sensitive information to us for any reason (for example, if you provide us with information about a disability you have), you consent to us collecting that information and to us using and disclosing that information for the purpose for which you disclosed it to us and as permitted by the Privacy Act and other relevant laws.
In addition to the types of personal information identified above, we may collect personal information as otherwise permitted or required by law.
Where you do not wish to provide us with your personal information, we may not be able to provide you with requested goods or services and/or certain functionality of our Websites.
We will collect and hold your personal information in a fair and lawful manner, and not in an intrusive way. Where it is reasonably practical to do so, we will collect your personal information directly from you. We may collect the personal information you directly give us through some of the following means:
However, in certain cases we may collect personal information from publically available sources and third parties, such as building management, concierge, suppliers, our clients and business partners. If we collect personal information about you from a third party we will, where appropriate, request that the third party inform you that we are holding such information, how we will use and disclose it, and that you may contact us to gain access to and correct and update the information.
As a general rule, we only process personal information for purposes that would be considered relevant and reasonable in the circumstances. The purposes for which we use and disclose your personal information will depend on the circumstances in which we collect it. Whenever practical we endeavour to inform you why we are collecting your personal information, how we intend to use that information and to whom we intend to disclose it at the time we collect your personal information.
We may use or disclose your personal information:
In general we collect, use and disclose your personal information so that we can do business together and for purposes connected with our business operations.
Some of the specific purposes for which we collect, hold, use and disclose personal information are as follows:
We store information that we collect through online forms, session IDs, log files and building management records to create a profile of our users which is then used to determine security level, tailored content and preferences. This is to facilitate the services offered to you through the Website and to allow us to manage and administer those services easily. Your information may be disclosed and shared to third parties for the purpose of providing the requested services.
Personal information will be used and disclosed for the primary purpose for which the information was collected or for related purposes such as completing transactions or providing a requested service, or as otherwise consented to by you, or permitted by law.
We may disclose your personal information to third parties in connection with the purposes described in section 3 of this Privacy Policy. This may include disclosing your personal information to the following types of third parties:
We may also disclose your personal information in accordance with any consent you give or where disclosure is authorised, compelled or permitted by law.
If we disclose information to a third party, we generally require that the third party protect your information to the same extent that we do.
If you post information to certain public parts of our Website or to our social media pages or other websites, you acknowledge that such information may be available to be viewed by the public. You should use discretion in deciding what information you upload to such sites.
We take protection of our users’ information seriously and we take every reasonable step to ensure that any personal details submitted are protected both online and off-line. We will hold personal information as either secure physical records, electronically on our intranet system, in cloud storage, and in some cases, records on third party servers. Our developers utilise the latest technologies to ensure that your information is kept secure and confidential. Our management team and developers are authorised to handle your information and we will retain your data on file no longer than is required by us. By law we are required to keep on file your login information for seven years after the login is cancelled, however some information may be deleted earlier than that depending on our legal requirements.
Like most businesses, marketing is important to our continued success. We therefore like to stay in touch with customers and let them know about new offers and opportunities. We may provide you with information about products, services and promotions either from us, or from third parties which may be of interest to you, where:
You may opt out at any time if you no longer wish to receive direct marketing messages from us. You can make this request by contacting our Privacy Officer.
Advertising content that appears on our Website is provided to us by third party advertisers and this Privacy Policy covers the use of information by 171 Collins Street only and does not cover the use of information by any third parties.
A cookie is a small text file stored in your computer’s memory or on your hard disk for a pre-defined period of time. We use cookies to identify specific machines in order to collect aggregate information on how visitors are experiencing our websites and online applications. This information will help to better adapt our websites ad applications to suit personal requirements. While cookies allow a computer to be identified, they do not permit any reference to a specific individual. For information on cookie settings of your internet browser, please refer to your browser’s manual.
We may use third party vendors to show our ads on sites on the Internet and serve these ads based on a user’s prior visits to our websites and online applications, and other internet activity. We may also use analytics data supplied by these vendors to inform and optimise our ad campaigns based on your prior visits to our websites and online applications.
You may contact our Privacy Officer (see section 12) to request access to the personal information that we hold about you and/or to make corrections to that information, at any time. On the rare occasions when we refuse access (which we will only do in accordance with applicable laws), we will provide you with a written notice stating our reasons for refusing access. We may seek to recover from you reasonable costs incurred for providing you with access to the personal information we hold about you.
We are not obliged to correct any of your personal information if we do not agree that it requires correction and may refuse to do so. If we refuse a correction request, we will provide you with a written notice stating our reasons for refusing.
We will respond to all requests for access to or correction of personal information within a reasonable time.
In the ordinary course of business we do not commonly disclose personal information to recipients located in other countries.
From time to time we may also engage an overseas recipient to provide services to us, such as cloud-based storage solutions. Please note that the use of overseas service providers to store personal information will not always involve a disclosure of personal information to that overseas provider.
By providing your personal information to us, you consent to us disclosing your personal information to any such overseas recipients for purposes necessary or useful in the course of operating our business, and agree that APP 8.1 will not apply to such disclosures. For the avoidance of doubt, in the event that an overseas recipient breaches the Australian Privacy Principles, that entity will not be bound by, and you will not be able to seek redress under, the Privacy Act.
We collect information in relation to employees of 171 Collins Street as part of their application and during the course of their employment, either from them or in some cases from third parties such as recruitment agencies, referees, government bodies (e.g. police checks, if required) and academic and professional bodies (e.g. to validate details and currency of qualifications). Such information may include contact details, qualifications, resume, current and former employment details, pay rate and salary, bank details, feedback from supervisors, training records and logs of your usage of our equipment (e.g. phones, computers and vehicles).
Under the Privacy Act, personal information about a current or former employee may be held, used or disclosed in any way that is directly connected to the employment relationship. We handle employee information in accordance with legal requirements and our applicable policies in force from time to time.
If you have any questions, concerns or complaints about this Privacy Policy or how we handle your personal information, including if you believe we have breached the APPs, please contact our Privacy Officer (see section 12).
When contacting us please provide as much detail as possible in relation to your question, concern or complaint.
We take all complaints seriously, and will respond to your complaint in accordance with any applicable timeframes imposed by law and otherwise within a reasonable period. We request that you cooperate with us during this process and provide us with any relevant information that we may need.
If you are dissatisfied with the handling of your complaint, you may contact the Office of the Australian Information Commissioner:
Office of the Australian Information Commissioner
GPO Box 5218, Sydney NSW 2001
Telephone: 1300 363 992
Email: enquiries@oaic.gov.au
If you have any further information with respect to the Privacy Policy please contact:
General Manager
Postal address: 171 Collins Street Melbourne
Telephone: 03 8651 2111
Email: admin@171collins.com.au
Our Website may contain links to third party websites. We make no representation or warranties, and are not responsible for, the privacy practices or policies of such third party websites. Third party websites are responsible for informing you about their own privacy practises and procedures. We recommend that users read the privacy statements on each website visited that collects personal information.
We reserve the right to change the terms of this Privacy Policy from time to time, without notice to you. An up-to-date copy of our Privacy Policy is available on our Website.
