PRIVACY POLICY

PRODEV Australia (ACN 658 331 223) recognises the importance of privacy and is committed to protecting individuals’ personal information.

PRODEV Australia is subject to the Australian Privacy Principles contained in the Privacy Act 1988 (Cth).

This Policy describes how PRODEV Australia complies with its privacy obligations in protecting the personal information PRODEV Australia holds about individuals.

PRODEV Australia is an Australian real estate investment and development company. It operates within Australia's key cities of Melbourne, Sydney, Brisbane, Perth and Adelaide. It is headquartered in Melbourne. Its key activities include:

• Development: PRODEV Australia develops commercial and residential assets. 

• Investment: PRODEV Australia invests and facilities investment opportunities in commercial and residential assets

For more information regarding PRODEV Australia, please visit our website: www.prodevaustralia.com

Personal information is defined as information or an opinion that can identify or can reasonably identify an individual. This may include an individual’s name, address, email address and telephone numbers. The type of personal information that PRODEV Australia collects will depend upon what dealings the relevant individual may have with PRODEV Australia.

PRODEV Australia may collect and hold personal information about individuals who:

• purchase, or express an interest to purchase, a PRODEV Australia home or apartment (for example, when entering into a sale and purchase agreement, or when responding to requests for information about a PRODEV Australia home or apartment)

• register or subscribe for electronic newsletters (either in person at one of our shopping centres or online) customer loyalty programs, competitions or promotions run by PRODEV Australia;

• lease, or express an interest to lease, premises, or spaces (including retail pop up spaces), including any related guarantors (for example, when negotiating, entering into or applying to enter into a lease with PRODEV Australia).

• seek employment with PRODEV Australia or are PRODEV Australia employees (for example, when conducting background checks for the purposes of employment);

• supply goods and services (for example, when establishing records and systems to enable payment for goods).

• use PRODEV Australia’s websites, social media and other online services;

• may otherwise come into contact with PRODEV Australia; or

• are provided loans or other financial accommodation by PRODEV Australia. 

PRODEV Australia only collects personal information which is reasonably necessary for its dealings with the relevant individual. The types of personal information may include, but are not limited to:

• information that identifies the individual (for example, name, gender, address, contact details, date of birth, photographic or video images); 

• information needed verify an individual’s identity such as driver licence number; 

• information about the individual’s financial position and credit-worthiness; 

• an individual’s employment history, and other information an individual provides as part of the recruitment process; 

• information about the individual that is required or authorised by law; 

• the individual’s tax file number; 

• the individual’s opinion/preferences about PRODEV Australia products, services or staff. 

The Privacy Act imposes restrictions on collecting sensitive personal information such as information about religious views, ethnicity, political opinions and personal health.

PRODEV Australia generally does not collect sensitive personal information about an individual. However, in certain circumstances, PRODEV Australia may collect some sensitive information if it is necessary to allow PRODEV Australia to deal with the individual and provided the individual has given consent for PRODEV Australia to do so.

Whenever it is reasonable and practical to do so, PRODEV Australia collects personal information directly from the individual. However, in some circumstances, personal information may be provided to PRODEV Australia by other parties such as the individual’s agent, employees or PRODEV Australia authorised agents, service providers and subcontractors. PRODEV Australia will take reasonable steps to inform the individual that it has the individual’s personal information, unless it is obvious from the circumstances.

When PRODEV Australia collects personal information, PRODEV Australia will generally provide notification of the collection to the individual to inform the individual about the purpose for the collection, the types of entities that the information is disclosed to, the overseas recipients the information is disclosed to (where applicable), and that PRODEV Australia Privacy Policy contains information about how the individual may access the personal information held by PRODEV Australia and how the individual may make a complaint.

PRODEV Australia operates a number of businesses which handle personal information. PRODEV Australia policy is only to use personal information for the purpose which was either specified or reasonably apparent at the time when the information was collected. PRODEV Australia may also use or disclose the information collected for any other related purpose for which the individual would reasonably expect it to be used. 

If PRODEV Australia wishes to use or disclose the personal information in other circumstances, it needs to obtain the individual’s consent to do so.

In general, PRODEV Australia uses personal information for the following purposes:

• providing products or services that have been requested;

• communicating with the individual;

• assessing the suitability of prospective tenants;

• helping PRODEV Australia manage and enhance its products and services, including analysing customer feedback and future customer needs;

• providing ongoing information and marketing about products and services to individuals that PRODEV Australia believes may be interested and where the individual has signed up;

• managing security and safety requirements in PRODEV Australia managed buildings and sites;

• complying with regulatory and legal obligations;

• recruiting employees and contractors; or

• fulfilling its obligations to employees. 

PRODEV Australia may send marketing materials to its customers or potential customers where PRODEV Australia has collected the personal information from the individual and the individual would reasonably expect PRODEV Australia to use the information for that purpose.

The individual’s prior consent will be obtained before personal information is used for marketing purposes in situations where the personal information has been collected from the individual and the individual would not reasonably expect PRODEV Australia to use the information for that purpose, the personal information has not been collected directly from the individual or where sensitive information is involved.

If the customer no longer wishes PRODEV Australia to use his or her personal information in order for PRODEV Australia to provide marketing materials, the customer is to advise PRODEV Australia via the relevant method provided for in the electronic marketing message sent to the customer (e.g. via an ‘unsubscribe’ link) or to write to the PRODEV Australia Privacy Officer (refer to contact details below). PRODEV Australia will act and amend its records promptly.

PRODEV Australia may disclose personal information to other entities within the PRODEV Australia Group.

External parties may be given access to personal information held by PRODEV Australia in certain circumstances. These include, but are not limited to:

• PRODEV Australia’s contractors, consultants, advisers and service providers who assist PRODEV Australia in the operation of its business or to provide a customer service (for example, a company which helps maintain PRODEV Australia’s computer systems or sends out PRODEV Australia’s mail); 

• joint venture partners for the purposes of seeking relevant regulatory approvals; 

• third party lenders and insurers; 

• the Australian Securities Exchange, the Australian Securities and Investments Commission and to other regulatory authorities or government agencies as agreed to or required by law; 

• anyone authorised by a provider of personal information; 

• relevant parties in situations when PRODEV Australia’s is required by law to provide the information.

PRODEV Australia limits the information disclosed to external parties to what is required for them to perform their services for PRODEV Australia or the relevant individual, or what is required by law..

PRODEV Australia does not sell personal information to any entities both foreign and domestic.

PRODEV Australia collects personal information from individuals who submit applications or register interest for employment with PRODEV Australia. If the application is unsuccessful, PRODEV Australia may retain the information in case a more appropriate opportunity becomes available. The unsuccessful applicant will be advised that they can contact PRODEV Australia to request PRODEV Australia not to retain the applicant’s information.

PRODEV Australia will take reasonable steps to protect personal information that it holds from unauthorised access, modification, misuse, interference and loss. PRODEV Australia maintains physical security measures over its physical premises, and a range of computer and network security measures (such as systems access, firewalls, data encryption) over its electronic systems. PRODEV Australia employees are required to maintain the confidentiality of any personal information held.

If other parties provide support services, PRODEV Australia generally requires them to agree to appropriately protect the privacy of the information provided to them.

Any individual can request access to the personal information PRODEV Australia may hold about them. To obtain access to the information, the individual needs to write to the PRODEV Australia’s Officer (refer to contact details below). PRODEV Australia will require evidence to verify the identity of the individual.

This service is free of charge unless the personal information requested requires preparation time. In this situation, PRODEV Australia will provide an estimate of how much this service will cost and request agreement before proceeding.

In normal circumstances, PRODEV Australia will provide the individual with access to the individual’s personal information. However, in some circumstances, there may be legal, regulatory or administrative reasons to deny the requested access. If access is denied, PRODEV Australia will provide the individual with the reasons for doing so.

If an individual wishes to change personal information that the individual believes may be inaccurate, out-of-date, incomplete, irrelevant or misleading, the individual may write to the PRODEV Australia’s Officer requesting the information to be changed.

If PRODEV Australia disagrees with the individual that the personal information should be changed, PRODEV Australia will provide the individual with the reasons for doing so. The individual has the right to request that a notation be included with their personal information to indicate their disagreement with their personal information held by PRODEV Australia.

PRODEV Australia may also collect the following information from you:

A cookie is a small data file that may be placed on the computer of a web user (usually in the browser software folder) during a visit to a PRODEV Australia’s website. Cookies are necessary to allow the PRODEV Australia’s website and the user’s computer to interact effectively and enhance security. Cookies can record information about the user’s visit to assist PRODEV Australia in better understanding the needs of the user. For example, user traffic data may be collected and used to infer the website user’s demographic using various web analytic technologies. PRODEV Australia sometimes also use performance tracking technology (such as conversion tags) to help PRODEV Australia to track user behaviour on its websites. General such user traffic and performance tracking data is non-personally identifiable and is collected on an aggregate level to report statistics to assist PRODEV Australia to improve the quality and relevancy of its services. However, if the user has completed the online registration form on PRODEV Australia’s websites, such cookie data may be linked to the personal information PRODEV Australia holds about the user. In these circumstances, this cookie data will be treated the same manner as the personal information which it has been linked. 

• PRODEV Australia may also use cookies from third party ad servers for the purpose of targeting our online advertisements on other sites. The cookies provided by the third party ad servers will collect information such as the device the user used to access the PRODEV Australia website (such as the type of device, the browser type or the operating system), the user’s browsing behaviour (such as what the user searched for, the pages the user viewed, the date and time of the visit and how long the user stayed) and the performance of our marketing campaigns (such as which ads or online content the user viewed or accessed). The information collected through this technology is not personally identifiable but such information will be shared with the third party ad servers for the purposes of showing the user more relevant advertising on PRODEV Australia’s websites or partner sites. 
  
  If users of a PRODEV Australia’s website do not wish to receive any cookies, they should set their browser to refuse cookies but this means that they may not be able to use certain parts of the PRODEV Australia’s website. If the user does not want third party ad servers to use cookies for targeted advertising purposes, the user can use an opt out mechanism provided by various advertising industry bodies such as Network Advertising Initiative opt-out (http://www.networkadvertising.org/choices/DAA).

PRODEV Australia’s websites use, among other technologies, Google’s suite of analytics programs to track website traffic. Where users have chosen to enable Google to associate their web and app browsing history with their Google account, and to use information from their Google account to personalise ads, Google will use data from its signed-in users together with PRODEV Australia’s Google Analytics data to build audience lists for cross-device remarketing. For users of PRODEV Australia’s websites, Google Analytics will collect Google-authenticated identifiers associated with the user’s Google Accounts (and therefore, personal information). Google Analytics will also temporarily join these identifiers to PRODEV Australia’s Google Analytics data. If a customer does not wish to have their Google-authenticated identifies joined with PRODEV Australia’s Google Analytics data, they should opt out of the ‘personalised ads’ option via their Google account. 

PRODEV Australia reserves the right to change this Policy at any time. PRODEV Australia will notify any changes to this Policy by posting an updated version of the Policy on the PRODEV Australia’s website.

An individual can make a complaint about the way in which PRODEV Australia’s has handled an individual’s personal information by writing to the PRODEV Australia’s Officer. PRODEV Australia will endeavour to act promptly in response to a complaint.

You may also contact the Office of the Australian Information Commissioner as follows: 

Phone:                      1300 363 992 
Web:                         www.oaic.gov.au 
Address: GPO Box 5218 Sydney, NSW 2001 

The PRODEV Australia’s Officer can be contacted as follows: 

Email:      prodevaustralia@gmail.com 
Address: PRODEV Australia’s Officer 
                                   PRODEV Australia
                                   Level 11, 50 Market Street
                                   Melbourne, VIC 3000 

For further information about privacy issues and the protection of privacy, visit the Office of the Australian Information Commissioner’s website at http://www.oaic.gov.au.

This policy was approved and adopted by PRODEV Australia Directors on 25th March 2022.