Scentre Group general privacy policy
Scentre Group 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 Australian Privacy Principles that form part of the Privacy Act 1988 (Cth) (Australia) and the Information Privacy Principles that form part of the Privacy Act 1993 (New Zealand), as required, and are intended to protect your privacy in respect of any personal information that you may provide to us. We have also taken steps to ensure that, if you tell us you are located in the European Union, and advise us that you wish to exercise the additional rights available to you under the General Data Protection Regulation, we will endeavour to meet those requests subject to the below terms.
Members of the Scentre Group, comprising Scentre Group Limited ABN 66 001 671 496, Scentre Management Limited ABN 41 001 670 579 (as responsible entity of Scentre Group Trust 1 ABN: 55 191 750 378), RE1 Limited ABN 80 145 743 862 (as responsible entity of Scentre Group Trust 2 ABN 66 744 282 872) and RE2 Limited ABN 41 145 744 065 (as responsible entity of Scentre Group Trust 3 ABN 11 517 229 138) and their respective controlled entities, and the owners of the Australian and New Zealand shopping centres managed by members of the Scentre Group (referred to in these terms and conditions as Westfield shopping centres), may collect personal and other information in the circumstances set out below, either directly or through their authorised agents and subcontractors. We refer to each of these entities in this policy as "us", "we", or "Scentre".
Scentre collects information from customers in a number of different ways. These include the following:
Scentre may collect the following types of personal information from unincorporated retailers, guarantors and other individuals related to retailers during negotiations for, and during the term of, the lease/licence for premises, kiosks and other activations at Westfield shopping centres:
Scentre requires this information to evaluate whether the relevant centre owner should enter into a lease, licence or other agreement with a retailer; to assist Scentre in the preparation of that document; to manage Scentre’s relationship with retailers; in connection with the management and security of Westfield shopping centres; and in order to monitor the performance of Westfield shopping centres. Occasionally, the information may also be made available to others in connection with these activities, in order for those people to provide services to Scentre or as required by law, as well as to third parties in connection with any transactions involving the ownership of the Westfield shopping centre.
If the retailer provides Scentre with direct debit or direct credit details, Scentre will only disclose those details to Scentre'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 Scentre. This information may be used by Scentre in connection with the management and security of Westfield shopping centres and may be provided to law enforcement and government bodies, insurers, Scentre staff and subcontractors, third parties who provide Scentre with services from time to time and other retailers for those purposes. This information is held securely and in a format which is access controlled, unless it is necessary to use this information for these purposes.
Scentre maintains securityholder registers through an external service provider, currently Computershare Investor Services Pty Limited (Computershare). Scentre requires Computershare to comply with the requirements of the Privacy Act 1988 (Cth) in Australia or the Privacy Act 1993 in New Zealand when performing these services. Scentre Group may collect personal information of its securityholders either from Computershare or directly from securityholders.
Personal information collected from securityholders (being members of the Scentre Group (ASX code: SCG) and Carindale Property Trust (ASX code: CPD) includes: contact information, bank account and securityholding details and tax file numbers.
This information is used primarily to carry out registry or investor relations functions such as payment of distributions, sending annual and half yearly reports, notices of meetings or newsletters and notifications to the Australian Tax Office or New Zealand Inland Revenue Department (where necessary).
This information may also be used for the purposes of Scentre Group complying with legal or regulatory requirements, investigating or preventing any suspected fraud or crime, informing securityholders about new initiatives concerning Scentre Group, or for any other purpose which a securityholder authorises Scentre Group to from time to time.
More information on Computershare’s privacy policy can be found at www.computershare.com/au/help/Pages/privacy-policies.aspx
If you, or a company you work for, supplies goods or services to Scentre, Scentre may collect personal information about you in connection with the provision of those goods or services, either directly from you or from that company. This information may include your name, date of birth, contact information, and any other information you provide, or provided on your behalf, as part of our induction and compliance processes. This information will be used for the purposes of managing the provision of those good or services.
If you are employed by a member of the Scentre Group, or are seeking employment with a member of the Scentre Group, Scentre may collection personal information about you in connection with your employment. This information may include your name, date of birth, contact information, and any other information you provide, or provided on your behalf, as part of our induction and compliance processes. This information will be used for the purposes of our recruitment process and, if successful, managing your employment, in accordance with the requirements of the Privacy Act 1988 (Cth) in Australia or the Privacy Act 1993 in New Zealand. You need to ensure this information is up to date, in accordance with Scentre’s policies and procedures.
If we receive personal information about you that we did not ask for either directly from you, from someone on your behalf, or through someone on our behalf, and we determine that we could have collected this information from you had we asked for it, we will take reasonable steps to notify you, as soon as practicable, that we have collected your personal information. If we could not have collected this personal information from you (or if you do not agree to us collecting information in this way), we will lawfully de-identify or destroy that personal information. Any unsolicited information provided by you, someone on your behalf or someone on our behalf, will be used for the purposes for which it was provided.
We may also collect the following information from you:
Personal information collected about individuals (as described above) may be collected by, or on behalf of:
All personal information collected by Scentre is held securely, whether on Scentre's physical files, in Scentre's computer systems or in a database (which may be hosted by Scentre or a third party on Scentre’s behalf). This information is only made available to Scentre staff on a 'need to know' basis and for the purposes outlined above or to other people as outlined in this policy who have agreed to treat that information confidentially. These databases are 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 a database and may also be transferred across borders to recipients in foreign countries other than Australia and New Zealand, including the United States of America and United Kingdom, and may be stored on servers, using databases or via cloud technology in a number of countries other than Australia and New Zealand, including regions such as the Americas, the European Union and Asia, where doing so is part of Scentre’s ordinary business practices relating to the storage of data and where permitted by law.
If Scentre ever has a requirement to transmit such data over the Internet (for example, to make an off-site back up) it will be in an encrypted or otherwise secured form. By providing us with your personal information, you consent to these transfers.
Securityholder information is held by the registry in accordance with registry arrangements which require such information to be held securely.
We will use all reasonable endeavours to keep your personal information in a secure environment. However, this security cannot be guaranteed due to the nature of the Internet. These measures are designed to assist in your personal information not being accessed by unauthorised personnel, lost or misused. If you reasonably believe that there has been unauthorised use or disclosure of your personal information please contact us (see below).
All reasonable steps are taken by us to ensure that your personal information held by us is accurate, complete and up to date. If you believe that any of your personal information is inaccurate, please contact us (see below) and we will take all reasonable steps to correct it within a reasonable timeframe.
The electronic environments are monitored by Scentre Group and third party specialist security monitoring companies. Scentre Group reviews its security arrangements regularly, and implements improvements when necessary.
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 have rights 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.
We will keep your personal information for only as long as is necessary to achieve the purpose for which we collected it.
SCENTRE ONLINE PRIVACY POLICY
When you become a registered user of westfield.com.au, scentregroup.com, westfield.co.nz, or any associated site (Site), including when you use services offered by a Site, subscribe to Scentre's Email Newsletters service or shop with Participating Retailers, we may ask for information including:
On the Site we invite you to:
We may also collect the following information during your visit to the Site and to the websites of Participating Retailers:
Information held about you (for example, your E-mail Newsletter subscriptions) is held in a database. The database is protected by a firewall as well as host-based security. Your personal data 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 Scentre’s business practices relating to the storage of data and where permitted by law. If Scentre ever has a requirement to transmit the data over the Internet (for example, to transmit your purchase through a payment gateway or to make an off-site back up) it will be in encrypted form. If you provide us with additional information to verify your identity, we will destroy the copies of the documents you provide to us after we have successfully verified your identity.
You can choose to unsubscribe from our email newsletters either by clicking the “unsubscribe” link at the bottom of any email newsletter you receive or by going to:
There is no fee for this access.
Scentre may allow advertising on its Site from time to time. Once you have clicked on an advertisement and have left the Site, our privacy policy no longer applies. You must read the privacy policy of the advertiser or subsequently visited site to see how your personal information will be handled on those sites. In addition, many business advertisements may be managed and placed on our Site by third-party companies. These "network advertisers" collect non-personal information when you click on or scan one of their banner advertisements. The information is collected using technology, so you may not realise it is being collected. The network advertisers collect this information so that they may show you ads that are more relevant or interesting to you.
On occasion the Site may also provide content that is created by a third-party partner website. In some instances the third-party sites will collect information in order to facilitate the transaction or to make the use of their content more productive and efficient. In these circumstances, the information collected is shared between Scentre and our third-party sponsors.
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:
We may also disclose information about you to:
You will only receive emails from Scentre if:
A cookie is a text file placed into the memory of your computer by our computers. A copy of this text file is sent by your computer whenever it communicates with westfield.com.au or westfield.co.nz (as applicable). Scentre uses cookies to identify you between multiple visits, to better understand how westfield.com.au or westfield.co.nz is used, and to provide you information which may be of interest to you based on your previous visits to westfield.com.au or westfield.co.nz and to provide targeted advertising to you (including through adservers and other third party advertisers) when you visit westfield.com.au or westfield.co.nz and certain other websites where advertising is found from time to time. We may provide the information we gather from cookies to third parties for these purposes and for other purposes connected with westfield.com.au. If cookie information is linked with personal information we hold about you as set out above, this cookie information becomes personal information and will be treated in the same manner as the personal information to which it has been linked. If you do not want adservers or other third party advertisers to use cookies to provide you with targeted advertising, we suggest you use an opt out mechanism which can be found on:
You do not have to accept cookies and you can set up your browser to notify you when you receive cookies. This will give you the opportunity to decide whether or not to accept the cookies. If you choose to disable cookies, you may not be able to access certain features of the website.
While we do all we can to guard your privacy, no data transfer over the Internet is 100% secure. When you share your information with us, it is at your own risk. There are ways you can help maintain the secrecy of your information:
Please contact us by email or by phone, if you believe:
We will try to satisfy any privacy questions that you have and correct any errors on our part. If you still have concerns please contact our Privacy Officer by email to privacy@scentregroup.com, or phoning +61 2 9358 7000 (Australia) or +64 9 978 5050 (New Zealand).
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 westfield.com.au/privacy-policy and at westfield.co.nz.
If you would like further information relating to the Australian Privacy Legislation and the Australian Privacy Principles, please visit oaic.gov.au.
If you would like further information relating to the New Zealand Privacy Legislation and the Information Privacy Principles, please visit privacy.org.nz.
Please contact Scentre's Privacy Officer or your centre manager if you believe:
You can contact Scentre's Privacy Officer by:
Phone: +61 2 9358 7000 (Australia) or +64 9 978 5050 (New Zealand)
Email: privacy@scentregroup.com
Post: Privacy Officer. Scentre Group Level 30, 85 Castlereagh Street Sydney, NSW 2000, Australia
or
Privacy Officer, Scentre Group P.O. Box 109-280, Newmarket Auckland 1149, New Zealand
As at 18 February 2020
Scentre Group, through the Westfield Plus application (the Westfield Plus App),
collects your personal information to:
• establish a profile of you;
• give you access to membership services;
• allow you to activate and manage Westfield Digital Gift Cards; and
• serve personalised offers.
Scentre Group may also share personal information with our service providers who provide services to you through your Westfield Plus Membership, including processing of payments relating to goods and services, issuing and processing Westfield Digital Gift Cards and related transactions, financial institutions, gateway providers, delivery service providers and organisations that assist us to check for or prevent unauthorised or fraudulent transactions, in order to deliver you relevant benefits when you are in our shopping centres.
If you have any questions or would like further information about the collection of your personal information, you can contact us at privacy@scentregroup.com.
We collect personal information about you when you create your Westfield Plus Membership or update your details.
The type of information we collect includes your email address, and it may also include, but is not limited to, your name, your vehicle’s number plate, payment details and mobile phone number. This also includes the preferences and settings you enable for your Westfield Plus Membership.
We may collect additional personal information when you choose to use services as a Westfield Plus Member, including the Westfield Plus App. This includes:
1.2.1 Location information: Where you have authorised the Westfield Plus App to access location services on your mobile device, and when the app is open, we use geo-location to collect location information in the following circumstances:
• Each time you use the Westfield Plus App to activate and add a Westfield Digital Gift Card to your mobile wallet, we use location services to check you are in Australia. This is because we do not allow the activation of a Westfield Digital Gift Card outside of Australia. We do not collect or store your specific location when performing this check.
• When you use the Westfield Plus App for any other purpose, we check your proximity to a Westfield centre. If we are able to determine that you are in a Westfield centre, then we also collect your precise latitude and longitude. If we determine that you are not at a Westfield centre, then we do not collect or store your specific location.
1.2.2 Usage information: We collect information about how you use our services as a Westfield Plus Member. This includes when you use our services in a Westfield centre, including the types of service used, when and how long for. It also includes when you access the Westfield Plus app, the app features used or pages viewed, app error reports, and other system activity.
• If you have activated a Westfield Digital Gift Card, we also collect transaction information made with the card, including the retailer and cost of each transaction.
1.2.3 Device information: We may collect information about the devices you useto access the Westfield Plus App, including but not limited to the hardware models, operating systems and versions, and mobile network information.
2.1 Operate and administer the Westfield Plus Membership program. This includes providing it to third parties who provide services to us in connection with your Westfield Plus membership, including processing of payments relating to goods and services, issuing and processing Westfield Digital Gift Cards and related transactions, financial institutions, gateway providers, delivery service providers and organisations that assist us to check for or prevent unauthorised or fraudulent transactions, or who facilitate payments made through the Westfield Plus App;
2.2 Communicate with you about your Westfield Plus Membership, including surveys about your visits to Westfield centres and experience with the Westfield Plus App;
2.3 Combine de-identified and aggregated data with other third party-provided data sets that Scentre Group has authorised access to for business insight purposes;
2.4 Share data analytics and insights of de-identified and aggregated data with other owners of Westfield centres and their retailers, as well as Scentre Group’s commercial and brand partners, for business insight purposes;
2.5 If you have given us consent to receive marketing and promotional offers, send you information about the Westfield Plus Membership program, including member benefits and targeted offers from Scentre Group and our commercial and brand partners.
2.6. Optimise and personalise your experience, including the Westfield Plus App experience, the marketing communications you have consented to receive, and your experience when you visit a Westfield centre;
2.7 Comply with our legal, audit and reporting obligations where required by law;
2.8 Respond to feedback, queries and complaints regarding your Westfield Plus membership or the Westfield Plus App; and
2.9 Comply with purposes to which you, either expressly or impliedly, consent to.
3.1 When using the Westfield Plus App to activate your Westfield Digital Gift Card we use your location information to check that you are in Australia.
3.2 We also use your location information while using the Westfield Plus App to check whether you are in Australia or New Zealand so that we can determine your proximity to a Westfield centre and show the nearest Westfield centre to you. We may also enable certain features and information, such as parking information, in the Westfield Plus App when you are near or in a Westfield centre. If you are not at a Westfield centre, then you may continue to use the Westfield Plus app, however some functionality may not be available.
3.3 Where you have otherwise enabled your mobile device to connect to, or be identifiable by, other in-centre infrastructure (for example, in-centre WiFi networks or blue tooth transmitter (beacon) infrastructure) outside the Westfield Plus App, we may also combine the location information you have consented to be collected through those other sources with location information collected through the Westfield Plus App for the purposes set out in 2.4 and 2.5. We also use this information to improve the location-based services provided to you.
Please also refer to the Privacy Policy, which contains further information about:
• How we handle your personal information;
• How you can access, update or correct the personal information we hold about you; and
• How you can make a privacy complaint and how we deal with privacy complaints.
Members of Scentre Group means Scentre Group Limited ABN 66 001 671 496,
Scentre Management Limited ABN 41 001 670 579 (as responsible entity of Scentre Group Trust 1 ABN: 55 191 750 378), RE1 Limited ABN 80 145 743 862 (as responsible entity of Scentre Group Trust 2 ABN 66 744 282 872) and RE2 Limited ABN 41 145 744 065 (as responsible entity of Scentre Group Trust 3 ABN 11 517 229 138) and their respective controlled entities, and the owners of the Australian and New Zealand shopping centres managed by members of the Scentre Group (referred to in these terms and conditions as Westfield shopping centres).