This Privacy Policy (“Policy”) applies in relation to The retail and commercial properties identified on www.qicre.com (“QIC Real Estate”), including the domain www.qicre.com and any centre-specific websites related to that domain (such as www.watergardens.qicre.com) (“Websites”), and the online marketplace available at www.shopindee.com.au (“Shopindee Marketplace”).
The QIC Real Estate and Websites are owned by QIC Limited ACN 130 539 123, its related bodies corporate, and its joint venture partners, and managed by QICP Pty Ltd ACN 075 744 151. The Shopindee Marketplace is owned by eShop TT Company Pty Ltd ACN 652 001 477 and managed by QICP Pty Ltd ACN 075 744 151. These entities are collectively referred to as “QIC” throughout this Policy.
This Policy outlines how QIC handles personal information in connection with QIC Real Estate, the Websites and the Shopindee Marketplace. This includes personal information relating to customers, prospective customers, suppliers, tenants, retailers, visitors to our premises, and users of our websites and mobile applications (collectively referred to as “you”).
By providing personal information to us (or otherwise enabling us to collect your personal information), you consent to the collection, use and disclosure of your personal information in accordance with this Policy and any other arrangements that apply between us.
1. Overview
QIC respects your privacy and we are committed to being transparent about our privacy practices and security. This Policy explains how we handle your personal information by setting out:
The Policy also describes how you can access or correct any personal information we hold about you, and how you can ask further questions or make a complaint.
Generally, “personal information” refers to information or an opinion about an individual, where that individual is identified or reasonably identifiable.
“Sensitive information” is a subcategory of personal information which is strictly regulated. Sensitive information includes information about your racial or ethnic origin, your religious or political beliefs, your sexual preferences and orientation, or your biometric or health information.
2. Collection of personal information
QIC collects personal information in order to conduct its business operations and deliver products and services. Your Personal information may be collected by or on behalf of QIC, or Third party suppliers who provide digital platform services to QIC and its customers.
Where you provide information to us in different ways, or where we already hold information about you, we may connect your information for use for one or more of the purposes listed in this Policy. If this occurs, the relevant information will be treated in the same manner as the personal information to which it has been linked.
This section identifies the kinds of personal information we collect, and the reasons why personal information is collected.
2.1 QIC Real Estate
QIC collects information at QIC Real Estate in a number of different ways:
Suppliers: If you, or a company you work for, supplies goods or services to QIC, QIC 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 which is 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.
2.2 Shopindee Marketplace, Websites and Mobile Applications
You may provide us with your contact and billing details (including credit card details) when you create an account or place an order through the Shopindee Marketplace, or when your business registers as a seller on the Shopindee Marketplace. QIC collects these details to enable us to contact you, to fulfil purchases, to inform you about sales or promotions, and to better target and personalise shopping experiences (where applicable).
We may also collect information from you via our other online services, such as the Websites and our mobile applications. This information may be collected using “cookies”, which are small data files placed on your computer or mobile device when you visit a website. Most browsers enable you to disable cookies in your browser settings.
The information we collect may include:
We collect this information (and may use or hold this information) for the following purposes:
2.3 Do Not Track Signals
Some web browsers incorporate a “Do Not Track” (DNT) feature that signals to web services that a visitor does not want to have their online activity tracked. DNT is not a standardised feature in browsers and not all web browsers offer DNT options, which prevents QIC guaranteeing support of the feature to users. As such, while respecting users’ privacy and their ability to request that data not be collected, or deleted on request, we and many other website operators do not, as standard, respond to DNT signals.
2.4 Anonymised data
QIC may collect or create anonymised data, such as foot traffic data and information about customer demographics, interests and behaviours. Anonymised data is not personal information and does not identify you. QIC may use anonymised data for the purposes listed in this Policy, as well as to inform our promotional and marketing strategies, and for research and profiling purposes.
Any research, statistical analysis or profiling we perform may be compiled and analysed on an aggregate basis, and we may share this aggregate data with our affiliates, agents and business partners. 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.
2.5 Unsolicited Information
If we receive personal information about you that we did not ask for, whether received directly from you or on your behalf, 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 we collect about you will only be used for the purposes for which it was provided.
2.6 Sensitive Information
Except as outlined in this Policy, we do not collect sensitive information unless required by law or where you consent for us to do so (and in any event, only where it is relevant). We will not collect sensitive information about you where this is expressly prohibited by applicable law.
3. Disclosure of Personal Information
We understand how important it is to keep your personal information private, so we only disclose personal information we have about you when:
To the extent permitted by law, we may also disclose information about you to:
We may disclose your personal information to law enforcement, government agencies and/or regulatory authorities in response to requests made in the course of enquires and/or investigations.
In certain circumstances, we may disclose your personal information overseas. We will not send your personal information outside Australia unless it is authorised by law and we can be satisfied that the recipient of the personal information has adequate data protection arrangements in place. The countries to which we usually provide information are the United States of America, Ireland, Denmark, Sweden, Finland, and Singapore.
We do not sell personal information to other organisations for marketing purposes. Any data sharing will be in compliance with local privacy laws and governed by our strict standards and policies, and where appropriate, confidentiality and other agreements to ensure your information is secure and treated with the utmost care and respect.
4. Storage of information
We protect personal information with appropriate safeguards and security measures and restrict access to those who have a legitimate business purpose and reason for accessing it. Personal information is only retained for as long as it is necessary for the identified purposes, or as required by law.
All personal information collected by QIC is held securely, whether on QIC’s physical files, in QIC’s computer systems or in a database (which may be hosted by QIC or a third party on QIC’s behalf). This information is only made available to QIC’s staff on a 'need to know' basis 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.
Examples of the steps QIC takes to protect the security of the personal information we hold include:
If other organisations provide support services on our behalf, we require them to take appropriate technical and organisational measures to secure the privacy of the information provided to them.
5. Information access and correction
At QIC, decisions and actions may be taken or made on the basis of personal information in our possession. You have rights to access and correct the personal information we hold about you. We will take reasonable steps to ensure that your personal information is up-to-date, accurate and complete.
If you wish to access or correct your personal information, please contact the Centre Manager at your relevant QIC shopping centre (by using the ‘Contact Us’ feature on the homepage of the relevant Website) or our Privacy Officer, whose details appear below.
6. Opting Out of Communications
We will not provide you with marketing communications unless you request to receive such communications. If you change your mind about receiving marketing communications from us, you may easily request not to receive such communications by following the instructions on the communication to opt-out or unsubscribe from further communications.
7. Resolving enquiries or complaints
If you have any questions, concerns or complaints about the treatment of your personal information, please contact the Centre Manager at your relevant QIC shopping centre (by using the ‘Contact Us’ feature on the homepage of the relevant Website) or our Privacy Officer, whose details appear below. We will respond to let you know who will be handling your matter and when you can expect a further response.
If you are unsatisfied with the resolution of your concerns, you may be able to escalate your complaint to the Office of the Australian Information Commissioner on 1300 363 992 or by email to [email protected]. You can also visit their website and obtain further information relating to Australian Privacy Legislation at www.oaic.gov.au.
QIC services are targeted towards persons located in Australia. The Office of the Australian Information Commissioner website is an Australian based website. 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 website.
8. Changes to our Privacy Policy
This Policy outlines our current privacy practices. You should check this page from time to time to make sure you are aware of any changes. We will notify you of any changes by publishing the latest version of this Policy at www.qicre.com/privacy-policy.
9. Contact
If you have any questions or comments about this Policy, please contact our Privacy Officer by emailing [email protected].