As at 1 August 2018
YOUR PRIVACY IS IMPORTANT TO SCENTRE GROUP
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".
WHAT PERSONAL INFORMATION SCENTRE GENERALLY COLLECTS AND WHY
Scentre collects information from customers in a number of different ways. These include the following:
In addition to the purposes set out above, this information may be used by Scentre in connection with the management and security of the Westfield shopping centres generally, to obtain feedback about a customer’s experiences at a centre (including with our retailers), 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 retailers for these purposes.
Where you provide information to us in different ways, or we hold information about you Scentre may connect information provided to us for one purpose, with other information for use for one or more of the above purposes.
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:
other financial and trading information.
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 the Westfield shopping centres; and in order to monitor the performance of the shopping centre. 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 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 the 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. 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.
Personal information collected from securityholders (being members of the Scentre Group (ASX code: SCG) and Carindale Property Trust (ASX code: CPD) includes: contact, bank account and securityholding details and tax file numbers.
In addition, contact information may be used from time to time to inform securityholders of new initiatives concerning Scentre Group.
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.
Employees or potential employees
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.
Other information we collect
We may also collect the following information from you:
We are collecting this information (and may use or hold this information) for the following purposes:
Scentre Group may use the anonymised data for the purposes set out above and to inform our promotional and marketing strategies, as well as research and profiling purposes including customer demographics, interests and behaviours based on personal information and other information provided to us. This research may be compiled and analysed on an aggregate basis, and we may share this aggregate data with our affiliates, agents and business partners. This aggregate information does not identify you personally. We may also disclose aggregated information in order to describe our services to current and prospective business partners, and to other third parties for other lawful purposes.
Scentre Group may connect information you provide to us for one purpose with other information for use for one or more of the above purposes. If you access or log-in to an in-Centre Wi-Fi service, and we already hold other information (both personal or non-personal) that can be associated to you or the device on which you are accessing the Wi-Fi service (including, but not limited to a device ID number (MAC address)), then that information may be linked with personal information we hold about you as set out in this policy, and will be treated in the same manner as the personal information to which it has been linked.
Who collects the information
Personal information collected about individuals (as described above) may be collected by, or on behalf of:
Information may also be collected by Scentre on behalf of other people as set out in notices given to individuals, or consents given by individuals, at or prior to the time the personal information is collected.
How your personal information is stored and kept secure
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 encrypted 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.
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:
To the extent permitted by law, we may also disclose information about you to:
or as otherwise permitted by law.
Right of access to and correction of your information
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.
How long do we hold your information?
We will keep your personal information for only as long as is necessary to achieve the purpose for which we collected it.
What information we collect and why
When you become a registered user of westfield.com.au, www.scentregroup.com, www.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:
The Site is an Australian based website, and it is not intended to provide services to EU residents, and its terms may not be fully consistent with the General Data Protection Regulation. If you are an EU resident and you choose to use the Website then you do so at your own risk, and on the terms of the Site.
On the Site we invite you to:
We collect this information in order to facilitate your access to the Site and the functionality provided by the Site. If you do not provide us with this information, we may not be able to provide you with access to all or part of the Site or functionality offered through the Site. In addition to the purposes set out above, this information may be used by Scentre in connection with the management and security of the Westfield shopping centres and the operation of the Site generally, 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 retailers for these purposes. If you submit your resume to us (including other related information relating to job applications), we will keep it in a database (which may be hosted by Scentre or a third party on Scentre’s behalf) for consideration of particular jobs that arise within Scentre. We also use this information to send to you special deals and discounts, surveys and other marketing materials based on your location or known web usage.
The Customer Service Survey that you complete will be used to help us improve our services at Westfield shopping centres, or to improve our Site.
We update the information we hold about you, for example, your resume, when you provide or we receive new information about you. We may connect information, including personal information with other information for use for one or more of the above purposes.
Other information we collect
We may also collect the following information during your visit to the Site and to the websites of Participating Retailers:
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 Site. We may connect information you provide to us for one purpose, with other information for use for one or more of the above purposes. If this information is linked with personal information we hold about you as set out above, this information becomes personal information and will be treated in the same manner as the personal information to which it has been linked.
How your information is stored
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.
How you can unsubscribe from the Email Newsletters service
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.
Advertisers and Partners on Scentre Group Websites
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.
Disclosing your 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:
We may also disclose information about you to:
Junk mail or unsolicited email
You will only receive emails from Scentre if:
What is a cookie and what are they used for?
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.
Tips on sending us information
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:
If something goes wrong
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 email@example.com, or phoning +61 2 9358 7000 (Australia) or +64 9 978 5050 (New Zealand).
Further information regarding Privacy Legislation
If you would like further information relating to the Australian Privacy Legislation and the Australian Privacy Principles, please visit www.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/
Scentre Group Contact Details
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)
Post: Privacy Officer, Scentre Group
Level 30, 85 Castlereagh Street
Sydney, NSW 2000, Australia
Privacy Officer, Scentre Group
P.O. Box 109-280, Newmarket
Auckland 1149, New Zealand
As at 14 August 2019
Scentre Group, through the Westfield Plus application, collects your personal information to establish a profile of you, give you access to membership services and serve up personalised offers. Scentre Group may share information with our service providers who provide services to you through your Westfield Plus membership, including processing of payments relating to orders, mailing houses, call centres, 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 firstname.lastname@example.org.
THE INFORMATION WE COLLECT
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.
If you choose to add a vehicle number plate to your profile and you are not the registered owner of that vehicle, you agree that you have authority from the registered owner to allow the collection and use of the number plate details as set out in this Privacy Statement. If you do not have this authority, you cannot add the number plate to your Westfield Plus Membership profile.
Information relating to your use of the Services
We may collect additional personal information when you choose to use a variety of services as a Westfield Plus Member, including the Westfield Plus App, the ticketless parking service, payment service and valet services. This includes:
HOW WE USE YOUR PERSONAL INFORMATION
We collect your personal information in order to:
How we use your location information
When using the Westfield Plus app, we use your location information to check your proximity to a Westfield centre. We use this information to display the centre nearest to you, and to check if your vehicle has entered the car park. We may also enable certain features and information in the Westfield Plus app when you are at a Westfield centre. If you are not at a Westfield centre, then you may continue to use the Westfield Plus app, however some of the functionality may not be available.
We also use this information to improve the location-based services we provide.
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).