BRIMBANK SHOPPING CENTRE GENERAL PRIVACY POLICY

Your privacy is important to Brimbank Shopping Centre. Brimbank Shopping Centre 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 are intended to protect your privacy in respect of any personal information that you may provide to us. 

JY Mulpha BB Level 1 Pty Ltd ((ACN 637 517 803) as trustee for the JY Mulpha Brimbank Level 1 Trust (ABN 99 173 824 180)  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 "Brimbank Shopping Centre".

What personal information Brimbank Shopping Centre generally collects and why:

Customers
Brimbank Shopping Centre 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 (either while in one of our shopping centres ("in-centre") or online), customers provide us with their contact details. Your name and address are automatically entered into Brimbank Shopping Centre database when you enter competitions.  Brimbank Shopping Centre collects these details to contact competition winners, and to inform customers about events, activities and promotions, both in centre and as part of Brimbank Shopping Centre other activities.  Customers have the option to opt out from receiving this information.
• When customers hire mobility aids or other equipment from Brimbank Shopping Centre or apply to use certain restricted spaces at Brimbank Shopping Centre, customers provide Brimbank Shopping Centre with certain information, including contact details. Brimbank Shopping Centre collects this information to ensure that there is a record of the hirer and to enable customers to be informed about upcoming events, activities and promotions, both in centre and as part of Brimbank Shopping Centre other activities.
• When customers attend Brimbank Shopping Centre and its car parks under video and camera surveillance. When entering Brimbank Shopping Centre and its car parks, customers' personal information, car licence plate details and images may be collected by Brimbank Shopping Centre , and Brimbank Shopping Centre 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 Brimbank Shopping Centre. This information may be used by Brimbank Shopping Centre in connection with the management and security of Brimbank Shopping Centre. When customers park in Brimbank Shopping Centre car parks with a ticketless parking system or car locator functionality, customers consent to provide us with their car licence plate details and, in some circumstances, other information including name, email address and telephone number. These details are used for measuring and analysing car parking dwell times and shopper behaviour in order to improve our centres, for the purposes of managing car parking at the centre, marketing purposes and also to assist customers to locate their cars including via online and mobile applications. 
• When customers use mobile applications developed by Brimbank Shopping Centre, or logon to Wi-Fi provided in-centre or third party applications utilising Brimbank Shopping Centre infrastructure (including Bluetooth beacon networks), customers provide Brimbank Shopping Centre with certain information including their contact details. Brimbank Shopping Centre  collects this information to enable customers to be informed about upcoming events, activities and promotions, both in centre and as part of Brimbank Shopping Centre other activities, sponsor and retailer promotions, and other activities, which will be notified to customers as they sign in to use those facilities.
• When customers purchase, redeem or are provided with Brimbank Shopping Centre Gift Cards, they may provide Brimbank Shopping Centre with their contact details. These details are used for card fulfilment purposes and, if customers opt in, to contact customers about events, activities and promotions, both in centre and as part of the Brimbank Shopping Centre other activities.

In addition to the purposes set out above, this information may be used by Brimbank Shopping Centre in connection with the management and security of Brimbank Shopping Centre generally, to obtain feedback about a customer experiences at a centre (including with our retailers), and may be provided to law enforcement and government bodies, insurers, Brimbank Shopping Centre staff and subcontractors, third parties who provide Brimbank Shopping Centre 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 Brimbank Shopping Centre may connect information provided to us for one purpose, with other information for use for one or more of the above purposes.

Additionally, Brimbank Shopping Centre also conducts certain online activities through the Brimbank Shopping Centre websites, and associated sites managed by their subcontractors. The collection of personal information through these activities and information associated with these websites is dealt with in the Brimbank Shopping Centre Online Privacy Policy, which can be found below.
 

Retailers
Brimbank Shopping Centre 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 Brimbank Shopping Centre:

• name, address and date of birth;
• contact and insurance details;
• ABNs;
• information as to retailers' financial standing and retailing experience; and
• other financial and trading information.

Brimbank Shopping Centre requires this information to evaluate whether the relevant centre owner should enter into a lease, licence or other agreement with a retailer; to assist Brimbank Shopping Centre in the preparation of that document; to manage Brimbank Shopping Centre relationship with retailers; in connection with the management and security of Brimbank Shopping Centre; 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 Brimbank Shopping Centre 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 Brimbank Shopping Centre with direct debit or direct credit details, Brimbank Shopping Centre will only disclose those details to Brimbank Shopping Centre bank to facilitate the provision of that service.

Additionally, as noted above, Brimbank Shopping Centre is under video and camera surveillance. When entering Brimbank Shopping Centre, the personal information and images of retailers and their staff may be collected by Brimbank Shopping Centre. This information may be used by Brimbank Shopping Centre in connection with the management and security of the shopping centre and may be provided to law enforcement and government bodies, insurers, Brimbank Shopping Centre staff and subcontractors, third parties who provide Brimbank Shopping Centre 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.

Suppliers
If you, or a company you work for, supplies goods or services to Brimbank Shopping Centre, Brimbank Shopping Centre 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 Brimbank Shopping Centre or are seeking employment with Brimbank Shopping Centre, Brimbank Shopping Centre may collect 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.  You need to ensure this information is up to date, in accordance with Brimbank Shopping Centre policies and procedures.

Unsolicited Information
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 which may be collected passively using various technologies that identify the demographic, age group and gender of 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 our website with a third-party social-networking site including but not limited to Facebook, Twitter, or Google+;
• cookies which track your visits to the our web sites; 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 (if applicable);
• to measure and analyse shopping behaviour in order to improve our centres and 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 Brimbank Shopping Centre agents, contractors, service providers, joint venture and commercial partners and regulatory authorities, and may transfer your personal information to others in countries outside Australia (including to those that operate our cloud servers outside of Australia).

Brimbank Shopping Centre 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.

Brimbank Shopping Centre 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:

• Brimbank Shopping Centre; and
• The owners of Brimbank Shopping Centre in Australia.

Information may also be collected by Brimbank Shopping Centre 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 Brimbank Shopping Centre is held securely, whether on Brimbank Shopping Centre physical files, in Brimbank Shopping Centre computer systems or in a database (which may be hosted by Brimbank Shopping Centre or a third party on Brimbank Shopping Centre behalf). This information is only made available to Brimbank Shopping Centre 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, including the United States of America, Hong-Kong and the United Kingdom, and may be stored on servers, using databases or via cloud technology in a number of countries other than Australia, including regions such as the Americas, the European Union and Asia, where doing so is part of Brimbank Shopping Centre ordinary business practices relating to the storage of data and where permitted by law.
If Brimbank Shopping Centre 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.

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 Brimbank Shopping Centre and third party specialist security monitoring companies. Brimbank Shopping Centre 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:

• 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;
• the owners of Brimbank Shopping Centre from time to time;
• third parties who provide services to Brimbank Shopping Centre from time to time;
• government agencies as part of our statutory obligations,
• 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 Brimbank Shopping Centre 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. 

Brimbank Shopping Centre Online Privacy Policy
What information we collect and why
When you become a registered user of https://www.brimbankshoppingcentre.com.au/ or any associated site (Site), including when you use services offered by a Site, subscribe to Brimbank Shopping Centre Email Newsletters service or part take in other activities with Participating Retailers, we may ask for information including:

• your name;
• your email address; and
• in certain circumstances, your telephone number, address or credit card details.

On the Site we invite you to:

• view products from Participating Retailers;
• set up a membership of the Site;
• subscribe to Brimbank Shopping Centre Email Newsletters;
• purchase Brimbank Shopping Centre Gift Cards;
• submit your resume to us for consideration of job vacancies;
• tell us about your shopping experiences by completing a customer service survey; and
• tell us about any other matter by contacting us directly.

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 Brimbank Shopping Centre in connection with the management and security of the shopping centre and the operation of the Site generally, and may be provided to law enforcement and government bodies, insurers, Brimbank Shopping Centre staff and subcontractors, third parties who provide Brimbank Shopping Centre with services from time to time and retailers for these purposes. If you submit your resume to us, we will keep it in a database for consideration of particular jobs that arise within Brimbank Shopping Centre.  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 Brimbank Shopping Centre, 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:

• the fully qualified domain name from which you accessed our Site, or alternatively, your IP address;
• the date and time you accessed each page on our 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 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 Brimbank Shopping Centre business practices relating to the storage of data and where permitted by law. If Brimbank Shopping Centre 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 by clicking the “unsubscribe” link at the bottom of any email newsletter you receive. There is no fee for this access.
Advertisers and Partners on Brimbank Shopping Centre Website(s)

Brimbank Shopping Centre 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 Brimbank Shopping Centre 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:

• you agree to the disclosure;
• we use it for the purposes we collected it; or
• disclosure is required or authorised by law.
• We may also disclose information about you to:
• related companies for marketing purposes;
• the owners of Brimbank Shopping Centre from time to time; Participating Retailers or their agents (such as financial institutions or our courier companies) from time to time;
• third parties who provide services to Brimbank Shopping Centre from time to time, including marketing, recruiting and survey services; and
• law enforcement and government agencies as required from time to time.

Junk mail or unsolicited email
You will only receive emails from Brimbank Shopping Centre if:

• You subscribe to our Email Newsletters service. Our Email Newsletters will keep you informed of the latest offers, current promotions and specials at Brimbank Shopping Centre. If you no longer wish to receive Email Newsletters, you may unsubscribe by clicking the “unsubscribe” link at the bottom of any email newsletter you receive;
• A friend nominates you to receive a page from the Brimbank Shopping Centre Site. The email will be sent to you on behalf of your friend. You will not receive subsequent e-mails from us, because Brimbank Shopping Centre will not record your e-mail address;
• You request information about our services when you choose to contact us. You will not be added to a mailing list of any kind and will only receive e-mail in the matter that you have contacted us about;
• You provide your details and request that we contact you when you send us your resume or when you complete our customer service survey; or
• They are otherwise relevant to the reasons for which we hold your email address, where we are permitted to do so by law.

What is a cookie and what are they used for?
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 https://www.brimbankshoppingcentre.com.au/ Brimbank Shopping Centre uses cookies to identify you between multiple visits, to better understand how https://www.brimbankshoppingcentre.com.au/ is used, and to provide you information which may be of interest to you based on your previous visits to https://www.brimbankshoppingcentre.com.au/ and to provide targeted advertising to you (including through adservers and other third party advertisers) when you visit https://www.brimbankshoppingcentre.com.au/ 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 https://strathpinecentre.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:

• the Network Advertising Initiative opt-out provided; throughhttp://www.networkadvertising.org/choices/DAA;
• the Digital Advertising Alliance opt-out provided ;through http://www.aboutads.info/choices/; or
• the Interactive Advertising Bureau (EU) opt-out provided throughhttp://www.youronlinechoices.eu.
• 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.

General
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:

• always close your browser when you have finished your user session; and
• ensure others cannot access your personal information and emails if you use a public computer.
• If something goes wrong

Please contact us by email or by phone, 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.

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 admin@brimbankcentral.com.au or 03 9363 5188

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 https://www.brimbankshoppingcentre.com.au/privacy-policy

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.privacy.gov.au

Brimbank Shopping Centre Contact Details
Please contact Brimbank Shopping Centre Privacy Officer or Brimbank Shopping Centre, 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 Brimbank Shopping Centre by:
Phone: 03 9363 5188
Email:  admin@brimbankcentral.com.au 
Post:   Privacy Officer, Brimbank Shopping Centre, 28-72 Neale Road, Deer Park VIC 3023