YTL Starhill Global REIT Management Limited (Singapore Company Registration No. 200502123C) as manager of Starhill Global REIT (SG REIT Management) recognises the importance of protecting the privacy of personal information collected about our tenants, suppliers and visitors to our properties in Australia.
We are required to comply with the Privacy Act 1988 (Cth) (Privacy Act), including the Australian Privacy Principles, to the extent that we carry on business in Australia and collect personal information about individuals in Australia. Our procedures for the handling of personal information, as generally outlined in this Policy, are in accordance with the Privacy Act.
1. How we collect, hold, use and disclose personal information
1.1 Personal information
The types of personal information we collect about you, and our use of that information, depends upon your dealings with us. Generally, the types of personal information we collect and hold may include your name, telephone number, residential and email address and financial information (e.g. for invoicing and payment of goods and services). We may also collect other personal and sensitive information from you if necessary, for example, some health information if you borrow a wheelchair from us when visiting one of our properties, or certain personal information we are required to collect by law (including laws other than those of Australia), such as passport number, date of birth and nationality.
If you do not provide all of the personal information we require, we may be unable to provide you with the products or services you are seeking.
We generally collect personal information directly from you. We may collect your personal information in person, by telephone or through written information or forms that you submit to us.
We may collect personal information about you from a third party appointed to provide property management services to customers and retailers of a Starhill Global REIT property.
We collect personal information that we require for the purposes of our business functions and activities.
If you provide us with personal information about a third party, you warrant that that third party consents to us collecting and using their personal information in accordance with this Policy.
We take reasonable, industry-standard steps to protect personal information from misuse, interference, loss or unauthorised access, modification or disclosure. We hold your personal information either as physical records, electronic records on our servers, or in some cases electronic records on third party servers, which may be located overseas.
We use the following security measures to protect personal information:
- locked and alarmed offices;
- locked files and cabinets;
- password-protected computers;
- a firewall on our computer network, which is monitored; and
- virus protection software.
We will keep personal information as long as we need it for the purposes in clause 1.4 of this Policy, or as long as we are required by law to retain it, after which time we will destroy or de-identify the personal information.
1.4 Use and Disclosure
We will use and disclose your personal information (and that of third parties) for the purposes for which we collected it, for other related purposes that you would reasonably expect, and as otherwise permitted or required by law.
By providing us with your personal information, you consent to us holding, using and disclosing your personal information for the following purposes:
- to operate our properties;
- to provide property management services to customers and retailers;
- ongoing management of tenancy agreements with retailers;
- to comply with our obligations at law (including without limitation obligations prescribed by Singaporean law);
- to communicate with you and provide information to you about our business; and
- to respond to enquiries and provide you with information you have requested.
We may disclose personal information to third party contractors performing services for us which involves or requires access to or use of your personal information, or to third parties where we are required or authorised by law to do so. If we disclose personal information to a third party, we generally require that the third party must protect that personal information to the same extent we do.
By providing us with your personal information, you consent to us sending you marketing and promotional material about our properties and the products, services, special offers and promotions that we and the retailers in our properties offer. You agree that we may send you such information by post or by electronic means (including email and SMS). You can opt-out of marketing and promotional communications at any time by contacting our Privacy Officer, or by using the opt-out mechanism provided in each communication.
We will not otherwise disclose your personal information to third parties without your consent.
2. Access to Personal Information
You may seek access to the personal information we hold about you by contacting our Privacy Officer via the details in this Policy. We may require you to provide us with sufficient identification before we provide access to your personal information. If we are required or authorised by law to do so, we may refuse a request for access.
We may charge a reasonable fee for you to access your personal information, but that fee will not exceed our reasonable costs of assessing your request and providing access. We will advise the amount once we have assessed your request, and we may require payment prior to providing access.
Access to your personal information may be provided in a number of ways, including by providing you with a hard or electronic copy, or by allowing you to view our records.
If you believe the personal information we hold about you is inaccurate, incomplete or out of date, please contact us via the details shown below. If you satisfy us that any personal information we hold about you is not accurate, complete or up-to-date, we will amend our records accordingly.
3. Cross-border disclosures
SG REIT Management is the manager of Starhill Global REIT, a Singapore-based real estate investment trust. As such, we are likely to disclose personal information to service providers located outside Australia, including (without limitation) in Singapore.
SG REIT Management will take reasonable measures to ensure that disclosure is in compliance with the requirements of the Privacy Act. By providing us with your personal information, however, you consent to the disclosure of such information to overseas recipients, and acknowledge that in the event that an overseas recipient breaches the APPs, that entity will not be bound by, and you will not be able seek redress under, the Privacy Act.
4. Credit checks
If you are seeking to become a tenant of a Starhill Global REIT property, we may need to collect, use and disclose particular consumer and commercial credit information (for example, collecting and disclosing particular information to credit reporting agencies or other credit providers about you). Where we intend to collect consumer credit information about you we will provide you with further information about how we will handle that information and obtain specific consents from you.
This Policy is current as at November 2015.
We may amend this Policy at any time, without notice to you, to ensure that we maintain the highest standards. Updates will be posted on our website at www.starhillglobalreit.com. The date of this Policy will inform you as to whether there have been updates since your last visit.
6. Do you have any concerns, queries or complaints?
If you have any concerns, queries or complaints about our management of your personal information, please contact our Privacy Officer for further information at the details set out below:
YTL Starhill Global REIT Management Limited
391B Orchard Road
#24-03 Ngee Ann City Tower B
Tel. +65 6835 8633
Fax +65 6835 8644
We request that any dispute or complaint be submitted into writing to our Privacy Officer. We will confirm receipt of your complaint and will investigate it and respond to you within a reasonable time.
If you are dissatisfied with the handling of your complaint, you may contact the Office of the Australian Information Commissioner, see www.oaic.gov.au/privacy/making-a-privacy-complaint for further information.