As at 1 June 2019
Rundle Mall Plaza (RMP) recognizes the trust you are placing in us through your dealings with us. We respect and 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 are intended to protect your privacy in respect of any personal information that you may provide to us.
RMP does not sell your personal information to any other party, nor do we purchase lists of information from any source.
Purpose for which RMP collect your personal information:
RMP may collect personal and other information in the circumstances set out below, either directly or through their authorized agents and subcontractors.
Type of personal information collected and why:
RMP 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. Your name and address are automatically entered into RMP’s database when you enter competitions. RMP collects these details to contact competition winners, and to inform customers about events, activities and promotions. Customers have the option to opt out from receiving this information.
- When customers attend RMP, the Paid Private Car Park and/or Loading Dock under video and camera surveillance. When entering the above locations customers’ personal information, car plate license details and images may be collected by RMP, and RMP may also collect customers’ personal information and images from third parties (for example, the police or retailers) in connection with the management and security of RMP. This information may be used by RMP in connection with the management and security of RMP. This information may be provided to law enforcement and government bodies, RMP staff and subcontractors, third parties who provide RMP with services from time to time, insurers and retailers for those purposes.
- When customers logon to Wi-Fi provided in RMP or third party applications utilising RMP’s infrastructure, customers provide RMP with certain information including their contact details. RMP collects this information to enable customers to be informed about upcoming events, activities and promotions in RMP, sponsor and retailer promotions, and other activities, which will be notified to customers as they sign in to use those facilities.
In addition to the purposes set out above, this information may be used by RMP in connection with the management and security of RMP generally, to obtain feedback about a customer’s experiences at RMP (including with our retailers), and may be provided to law enforcement and government bodies, insurers, RMP staff and subcontractors, third parties who provide RMP 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 RMP may connect information provided to us for one purpose, with other information for use for one or more of the above purposes.
RMP 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 RMP:
- name, address and date of birth;
- contact and insurance details;
- information as to retailers’ financial standing and retailing experience; and
- other financial and trading information.
RMP requires this information to evaluate whether it should enter into a lease, licence or other agreement with a retailer; to assist RMP in the preparation of that document; to manage RMP’s relationship with retailers; in connection with the management and security of RMP; 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 RMP or as required by law.
Additionally, as noted above, RMP is under video and camera surveillance. When entering RMP, the personal information and images of retailers and their staff may be collected by RMP. This information may be used by RMP in connection with the management and security of RMP and may be provided to law enforcement and government bodies, insurers, RMP staff and subcontractors, third parties who provide RMP 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.
If you, or a company you work for, supplies goods or services to RMP, RMP 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 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:
- where devices are enabled to connect to, or are identifiable by, in centre infrastructure (for example, in centre WiFi networks or blue tooth transmitter (beacon) infrastructure), we and our third party providers may automatically collect data from those devices including usage, type of device and location and proximity of your wireless device in centre, centre arrival and departure time, and other data which users consent to us collecting from time to time;
- audience measurement information collected passively using in centre technologies which utilise image processing software to aggregate data such as shopper numbers and demographics. These technologies do not identify individual shoppers, or record or retain images of individual shoppers.
- the fully qualified domain name from which you accessed our websites, or alternatively, your IP address, device ID number (MAC address), the date and time you accessed each page on our websites;
- the URL of any webpage from which you accessed our websites or using in centre WiFi, and the details of any mobile Apps you have accessed from a device using in centre WiFi;
- publicly accessible social media posts and any personal information you allow us to collect by linking your account on the RMP website with a third-party social-networking site including but not limited to Facebook, Twitter, or Instagram;
- cookies which track your visits to the RMP website; and
- the web browser that you are using and the pages you accessed.
We are collecting this information (and may use or hold this information) for the following purposes:
- so that we can tell which web pages are the most popular and where shoppers spend most of their time;
- to improve our website or in centre experience;
- for the purposes of and incidental to your use of in centre Wi-Fi services;
- to measure shopper numbers, characteristics and demographics, and analyse shopper behaviour in order to continuously improve RMP and for use otherwise in connection with our business;
- to send to you special deals and discounts, surveys and other marketing materials based on your location or known web usage;
- for other purposes to which you, either expressly or impliedly, consent to, and for the purposes set out in these terms and conditions, we may provide this information to RMP’s agents, contractors, service providers, joint venture and commercial partners and regulatory authorities.
RMP 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.
RMP 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 members of RMP.
Information may also be collected by RMP 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 RMP stores & secures your personal information:
To protect the security of personal information at RMP, all data is stored electronically in a security protected database or in secure archiving/storage areas.
Our database and archiving/storage areas are secured in the Adelaide CBD.
We will at all times seek to ensure that the personal information collected and held by us is protected from misuse, loss, unauthorized access, modification or disclosure. At all times your personal information is treated as confidential and any sensitive information is treated as highly confidential.
This information is only made available to RMP 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.
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.
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 and we will take all reasonable steps to correct it within a reasonable timeframe.
The electronic environments are monitored by RMP and third-party specialist security monitoring companies. RMP reviews its security arrangements regularly, and implements improvements when necessary.
Disclosure Of 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; or
- 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;
- third parties who provide services to RMP from time to time;
- government agencies as part of our statutory obligations,
or as otherwise permitted by law.
RMP is a South Australian based company that primarily works within Australia and it is unlikely that your information will be disclosed to overseas recipients.
How To Update & Access Your Personal Information:
If you would like access to this information you can do so by contacting our office on (08) 8224 0099, emailing our office at email@example.com or writing to us at Level 1, 202 Rundle Street, Adelaide 5000. You can correct any information if it is inaccurate, incomplete or out of date. Real Estate and Tax laws require some of this information to be collected.
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.
If You Have A Query Or Complaint:
Our employees and management at RMP are aware of their privacy obligations to you and must comply with clear privacy guidelines when dealing with your personal information. Any inappropriate dealings with your personal information will be seen as a serious matter and dealt with accordingly.
Should you have a query, or wish to provide feedback about privacy matters, or wish to make a privacy related complaint, please contact our Privacy Officer by emailing firstname.lastname@example.org or calling (08) 8224 0099.
We advise that you must not rely on this information and would always recommend you seek independent advice.