PRIVACY POLICY

Your privacy is important to Westfield

Westfield recognises the trust you are placing in us through your dealings with us. We are committed to the protection of your personal information. Our policies comply with our obligations under the National Privacy Principles that form part of the Privacy Act 1988 and are intended to protect your privacy in respect of any personal information that you may provide to us.

 

Members of the Westfield Group, comprising Westfield Holdings Limited ABN 66 001 671 496, Westfield Management Limited ABN 41 001 670 579 (as responsible entity of Westfield Trust), Westfield America Management Limited ABN 66 072 780 619 as responsible entity of Westfield America Trust) and their respective controlled entities, and the owners of the Australian shopping centres managed by members of the Westfield Group, may collect personal and other information in the circumstances set out below.

We refer to each of these entities in this policy as "us", "we", or "Westfield".

What personal information Westfield generally collects and why:

Customers

Westfield collects information from customers in a number of different ways. These include the following:

 

  • • In connection with competitions or signing up to email or mobile newsletters, customers provide us with their contact details. Westfield collects these details to contact competition winners, and to inform customers about Westfield events, activities and promotions, both in centre and as part of Westfield's other activities. Customers have the option to opt out from receiving this information.
  • When customers hire mobility aids or other equipment from Westfield, or apply to use certain restricted spaces at Westfield managed centres, customers provide Westfield with certain information, including contact details. Westfield collects this information to ensure that there is a record of the hirer and to enable customers to be informed about upcoming Westfield events, activities and promotions, both in centre and as part of Westfield's other activities.
  • Westfield shopping centres and car parks are under video and camera surveillance. When entering Westfield shopping centres and car parks, customer's personal information and images may be collected by Westfield, and Westfield may collect customer's personal information and images from third parties (for example, the police or retailers). This information may be used by Westfield in connection with the management and security of the Westfield shopping centres and may be provided to law enforcement and government bodies, Westfield staff and subcontractors, insurers and retailers for those purposes. The licence plates of vehicles parked by customers in car parks may also be collected and used for the above purposes and also to assist customers to locate their cars including via online and mobile applications.
  • When customers use mobile applications developed by Westfield, or logon to WiFi provided in Westfield centres, customers provide Westfield with certain information including their contact details. Westfield collects this information to enable customers to be informed about upcoming Westfield events, activities and promotions, both in centre and as part of the Westfield's other activities, and sponsor and retailer promotions, and other activities which will be notified to customers as they sign in to use those facilities.
  • When customers purchase Westfield Gift Cards or are provided with Westfield Insurance Cards, they may provide Westfield with their contact details. These details are used for card fulfilment purposes and, if customers opt in, to contact customers about Westfield events, activities and promotions, both in centre and as part of the Westfield's other activities.
  • Where donations are made to Westfield Charity Limited or the Westfield Charities Fund by cheque, contact details of customers may be collected to verify the payer details or notify payers if the cheque is not able to be processed.

 

In addition to the purposes set out above, this information may be used by Westfield in connection with the management and security of the Westfield shopping centres generally, and may be provided to law enforcement and government bodies, insurers, Westfield staff and subcontractors, third parties who provide Westfield with services from time to time and retailers for these purposes.

 

Additionally, Westfield also conducts certain online activities through the Westfield Online site. The collection of personal information through these activities and information associated with the Westfield Online site is dealt with in the Westfield Online Privacy Policy, which can be found at http://www.westfield.com.au/au/help/online-privacy-policy.


Retailers

Westfield collects the following types of personal information from unincorporated retailers and guarantors during negotiations for, and during the term of, the lease/licence for premises and kiosks at Westfield shopping centres:

 

  • contact and insurance details;
  • ABNs;
  • information as to retailers' financial standing and retailing experience; and
  • other financial and trading information,

 

Westfield requires this information to evaluate whether the relevant centre owner should enter into a lease or licence with the retailer; to assist Westfield in the management of their relationship; and to monitor the performance of the centre. Occasionally, the information may also be made available to others in connection with any transactions involving the ownership of the centre.

 

If the retailer provides Westfield with direct debit or direct credit details, Westfield will only disclose those details to Westfield's bank to facilitate the provision of that service.

 

Additionally, as noted above Westfield shopping centres are under video and camera surveillance. When entering Westfield shopping centres, the personal information and images of retailers and their staff may be collected by Westfield. This information may be used by Westfield in connection with the management and security of the Westfield shopping centres and may be provided to law enforcement and government bodies, insurers, Westfield staff and subcontractors, third parties who provide Westfield with services from time to time and other retailers for those purposes.


Securityholders

Westfield maintains securityholder registers through an external service provider, currently Computershare Investor Services Pty Limited. Westfield requires Computershare to comply with the National Privacy Principles when performing these services.

 

Personal information collected from securityholders (being members of the Westfield Group (ASX code: WDC) and Carindale Property Trust (ASX code: CPD) includes: contact, bank account and securityholding details and tax file numbers.

 

This information is used to carry out registry functions such as payment of distributions, sending annual and half yearly reports, notices of meetings or newsletters and notifications to the Australian Tax Office.

Who collects the information

Personal information collected about individuals (as described above) may be collected by, or on behalf of:

 

  • members of the Westfield Group; and
  • the owners of the Australian Westfield shopping centres.

 

Information may also be collected by Westfield on behalf of other people as set out in notices given to customers, or consents given by customers, at or prior to the time the personal information is collected.

How your personal information is stored

All personal information collected by Westfield is held securely, whether on Westfield's physical files, in Westfield's computer systems or in a database. This information is only made available to Westfield staff on a 'need to know' basis or to other people as outlined in this policy, who have agreed to treat that information confidentially. The database is protected by a firewall as well as host-based security. Your personal information may be transmitted over the Internet once it has been stored in the database and may also be transferred across borders to foreign countries, where doing so is part of Westfield’s business practices relating to the storage of data and where permitted by law. If Westfield ever has a requirement to transmit such data over the Internet (for example, to make an off-site back up) it will be in encrypted form.

 

Securityholder information is held by the registry in accordance with registry arrangements which require such information to be held securely.

Disclosing your personal information

We understand how important it is to keep your personal information private, so we will disclose personal information we have about you only in certain specific circumstances, when:

 

  • you agree to the disclosure;
  • we use it for the purposes we collected it; or
  • disclosure is required or authorised by law.

 

To the extent permitted by law, we may also disclose information about you to:

 

  • related companies for marketing purposes;
  • the owners of the shopping centres managed by members of the Westfield Group from time to time;
  • third parties who provide services to Westfield from time to time;
  • government agencies as part of our statutory obligations,

 

or as otherwise permitted by law.

Right of access to your information

You have the right to access, update and correct your personal information held by us. We will take reasonable steps to ensure that personal information is up-to-date, accurate and complete.

 

If you wish to access, update or correct your personal information held by us, please contact our Privacy Officer, whose details appear below, or your relevant shopping centre manager.

Other information we collect

We may also collect the following information from you:

 

  • where devices are able to connect to, or are identifiable by, in-centre infrastructure, we may collect data including usage, location and type of device, from those devices, and other data which users consent to us collecting from time to time;
  • the fully qualified domain name from which you accessed our website, or alternatively, your IP address;
  • the date and time you accessed each page on our web site;
  • the URL of any webpage from which you accessed our site (the referrer);
  • cookies which track your visits to the Site; and
  • the web browser that you are using and the pages you accessed.

 

We use this information so that we can tell which pages are the most popular and where shoppers spend most of their time. We use this information to improve our website.

Changes to our privacy policy

This privacy policy relates to our current privacy standards. We may vary our privacy policy from time to time. We will notify you of any changes by publishing the latest policy from time to time at http://westfield.com.au/au/help/privacy-policy.

 

Westfield also has a specific privacy policy tailored to its internet operations that can be viewed at http://www.westfield.com.au/au/help/online-privacy-policy.

Further information regarding Australian Privacy Legislation

If you would like further information relating to the Australian Privacy Legislation and the National Privacy Principles, please visit www.privacy.gov.au.

Westfield Contact

Please contact Westfield's Privacy Officer or your centre manager if you believe:

 

  • someone has gained access to your personal information by mistake;
  • we have breached our privacy obligations or your privacy rights in any way; or
  • you would like to discuss any issues about our privacy policy.

 

You can contact Westfield's Privacy Officer on (ph) 02 9358 7000, via email at privacy@au.westfield.com, or in writing to: Privacy Officer, Westfield Group, Level 30, 85 Castlereagh Street, Sydney, NSW 2000.