Sunland Group Limited and each of its associated entities (as that term is defined in the Corporations Act 2001 (Cth)) from time to time (Sunland Group, we, our, us) are committed to protecting your privacy. Sunland Group takes all reasonable steps to comply with the Australian Privacy Principles and the Privacy Act 1988 (Cth) (Privacy Act) with respect to the collection, use, disclosure, security of, and access to, personal information.
Personal information includes information or an opinion about an individual that is reasonably identifiable. For example, this may include your name, age, gender, postcode and contact details. It may also nclude financial information, including your credit card information.
We may collect and hold personal information that can identify you that is necessary in order to conduct our business or communicate with you. The personal information collected by Sunland Group depends on your interaction with Sunland Group.
Sunland Group may collect and hold information about individuals who use our services or otherwise interact with us as part of a transaction, or communicate with us.
Sunland Group typically collects personal information such as your name, address, phone number, email address, and other information/documents for the purposes of identifying you.
The Privacy Act imposes restrictions on collecting sensitive personal information such as information about religious views, ethnicity, political opinions and personal health. We generally do not collect sensitive personal information about an individual but may need to if it is necessary to allow Sunland Group to deal with the individual, and provided the individual has given consent for us to do so.
Personal information will generally be collected by us directly in a number of ways, including but not limited to, through our websites, Wi‐Fi services or mobile applications, your participation in surveys, questionnaires, customer loyalty programs, competitions and promotions run by or on behalf of us, or generally through your communications with us.
If the personal information you provide to us is incomplete or inaccurate, we may be unable to provide you, or someone else you know, with the services you, or they, are seeking.
3. ONLINE USERS
If you access our website, we may collect additional personal information about you in the form of your IP address and domain name.
Sunland Group may use technology to track the patterns of behaviour of visitors to our websites. This can include using a “cookie” which would be stored on an individual’s browser. An individual can usually modify their browser to prevent this occurring. The information collected in this way can be used to identify an individual unless browser settings are modified.
We use both first‐party and third‐party cookies. Cookies are categorized as third‐party or first‐party depending on whether they are associated with the domain of the site a user visits. This doesn’t change the name or content of the actual cookie. The difference between a third‐party cookie and a first‐party cookie is only a matter of which domain a browser is pointed toward.
3.2 Similar technologies
3.3 Third Party Links
Our website may contain links to other websites. Those links are provided for convenience and may not remain current or be maintained. We are not responsible for the privacy practices of linked websites and linked websites are not subject to our privacy policies and procedures.
4. USE AND DISCLOSURE
Sunland Group operates a number of businesses which handle personal information. Our policy is only to use personal information for the purpose which was either specified or reasonably apparent at the time when the information was collected. We may also use or disclose the information collected for any other related purpose for which the individual would reasonably expect it to be used. If we wish to use or disclose your personal information in other circumstances, we need to obtain your consent to do so.
Generally, we will only collect, use and hold personal information if it is reasonably necessary for or directly related to the performance of our functions, and for the purposes of:
(a) selling and/or leasing property or premises, or in response to an expression of interest to do so;
(b) marketing and promotion of our projects, including through our website and through target advertising on other websites;
(c) direct marketing and promotion of our goods and services, and the goods and services of our selected business partners and third parties, including through email;
(d) acquiring goods, services and information;
(e) enabling you to access and use our website and services;
(f) facilitating Sunland Group’s internal business operations;
(g) monitoring, auditing, evaluating and analysing Sunland Group’s products and services and customer needs in order to develop its business
(h) assessing the suitability of prospective tenants;
(i) managing security and safety requirements in Sunland Group buildings and sites;
(j) fulfilling any legal or regulatory requirements; or
(k) dealing with complaints or queries.
We may disclose personal information about you to:
(a) our employees;
(b) our related entities to facilitate our and their internal business processes;
(d) the Australian Securities Exchange, the Australian Securities and Investments Commission and to other government agencies as agreed to or required by law; and
(e) anyone authorised by a provider of personal information.
In some circumstances, the law may permit or require us to use or disclose personal information for other purposes (for instance where you would reasonably expect us to and the purpose is related to the purpose of collection).
We limit the information disclosed to external parties to what is required for them to perform their services for us or the relevant individual, or what is required by law.
When we disclose your personal information to our third party service providers, they may also hold other information about you. These third parties may combine that information in order to enable it and us to develop consumer insights so that we can better understand your preferences and interests, personalise your experience and enhance the products and services that you receive.
5. DIRECT MARKETING
We may send you direct marketing communications and information about our services, and the products and services of our carefully selected business partners. This may take the form of B:6668814_1 ESG
emails, SMS, mail or other forms of communication, in accordance with the Privacy Act and the Spam Act 2003 (Cth).
We will obtain your prior consent before your personal information is used for marketing purposes in situations where the personal information has been collected from you and you would not reasonably expect us to use the information for that purpose, or where sensitive information is involved.
You may opt‐out of receiving marketing materials from us by contacting us using the details set out below or by using the opt‐out facilities provided (for example, via an unsubscribe link).
6. DISCLOSURE OUTSIDE AUSTRALIA
We may disclose personal information outside of Australia to third party suppliers located outside of Australia, including in the United States of America, Canada, Ireland, Philippines, Singapore and Germany.
When you provide your personal information to us, you consent to the disclosure of your information outside of Australia and acknowledge that we are not required to ensure that overseas recipients handle that personal information in compliance with Australian Privacy Law. We will, however, take reasonable steps, including a sophisticated selection process, to ensure that any overseas recipient will deal with such personal information in a way that is consistent with the Australian Privacy Principles.
We take reasonable precautions to safeguard personal information from loss, misuse, unauthorised access, modification or disclosure. Personal information which is no longer required for business purposes or by law will be de‐identified, hard copies will be securely destroyed and soft copies will be permanently deleted from Sunland Group’s computer systems.
We store your personal information in different ways, including in paper and in electronic form. The security of your personal information is important to us. We take all reasonable measures to ensure that your personal information is stored safely to protect it from misuse, loss, unauthorised access, modification or disclosure, including electronic and physical security measures.
Your personal and sensitive information will be stored in servers located in Australia, and may be stored in servers located in or transferred to third party service providers in countries specified in section 6 for the purposes set out above.
You may access the personal information held about you by making a written request and on verification of your identity. We will try to acknowledge the request within 14 days of its receipt, and to provide access to the personal information within 30 days. Sunland Group may charge a reasonable fee for providing access to your personal information (but not for making a request for access).
We may decline a request for access to personal information in circumstances prescribed by the Privacy Act, and if we do, we will provide you with a written notice that sets out the reasons for the refusal (unless it would be unreasonable to provide those reasons).
If, upon receiving access to personal information or at any other time, you believe that the personal information held by Sunland Group is inaccurate, incomplete, or out of date, please notify Sunland Group immediately. We will take steps to correct the personal information so that it is accurate, complete and up to date.
If we refuse to correct your personal information, we will provide you with a written notice that set out the reasons for our refusal (unless it would be unreasonable to provide those reasons).
9. PRIVACY COMPLAINTS
If you believe that the Sunland Group or any of its subsidiaries have not dealt with your personal information in accordance with the Australian Privacy Principles in the Privacy Act (or any amendments), you may lodge a privacy complaint. Please contact us as set out below and we will take reasonable steps to investigate the complaint and respond to you. If you are not happy with our response, you may complain directly to the federal Australian Information Commissioner.
Privacy complaints made to the Sunland Group must:
(a) be in writing;
(b) state an address of the complainant to which notices may be forwarded under the Privacy Act;
(c) provide certified identification; and
(d) give particulars of the act or practice the subject of the complaint.
Privacy complaints need to be marked “Private and confidential” and addressed to:
The Privacy Officer
PO BOX 1301
Surfers Paradise QLD 4217
10. OPT OUT/UNSUBSCRIBE
You may request that your details be removed from Sunland Group’s marketing list at any time by using the unsubscribe link‐ firstname.lastname@example.org in any email Sunland Group may send, or by contacting the Sunland Group Head Office on 07 5564 3700.
Sunland Group’s contact details for any issues relating to personal information and this policy are:
The Privacy Officer
Sunland Group Limited
PO Box 1301
Surfers Paradise QLD 4217
Telephone: 07 5564 3700
11. MORE INFORMATION
For more information about privacy in general, you can visit the federal Information
Commissioner’s website at www.oaic.gov.au.
Effective date: 16 October 2017