Last Revised: 23/03/22
Centuria Property Services Pty Limited (Centuria, we, us, and our) respects your privacy and is committed to protecting your privacy in accordance with this privacy policy (Policy). This Policy informs users and prospective users (user, you and your) of our online tenant engagement platform and associated downloadable mobile app, (together, the Platform) as to:
the purposes for which we collect, hold, use and disclose personal information; and
This Policy may change from time to time and it is therefore important that you review it regularly. Any changes to this Policy will become effective when we publish the revised Policy online via the Platform.
This Policy should be read in conjunction with our terms of use of the Platform (Terms of Use), and where applicable the terms of any lease or similar agreement between the owner or landlord of a building and its tenants (Tenant Agreement).
The software and technology used to operate the Platform is provided by Ility Pty Ltd (Platform Provider).
What information do we collect?
The types of information we collect depends on the nature of our engagement with you and the types of services you receive via the Platform. The types of information collected by us may include:
contact information (such as your physical address, contact number and email address);
location information for use with the building access functionality of the Platform;
payment information (which includes card or other payment information (e.g. PayPal, bank details).
If you provide a third party's personal information (such as a visitor’s personal information) when booking or requesting visitor services you must ensure that you have obtained the necessary consent of your visitor.
When providing your personal information, please provide only relevant information and do not provide unnecessary information, (e.g. drivers licence numbers, credit card information or other unnecessary personal information) when it is not needed. In addition, your user account credentials should be kept confidential to you.
How do we collect your personal information?
Personal information will generally be collected directly from you. For example, we collect personal information when you:
register for a user account on the Platform;
communicate or interact with us by telephone, email, online (including through our Platform) or in person;
use the Platform to purchase or hire products or services;
respond to any surveys or marketing materials we may send out;
interact with other users on the Platform; and
use our Platform to enable us to manage your use of the Platform and to provide you with technical support.
We may also collect personal information about you from the following other sources:
the Platform Provider that provides access to and use of the Platform;
tenants and other users of the building;
our suppliers and other third parties who provide services to us; and
publicly available sources where relevant.
If you use the mobile application, Centuria will also track your location using Bluetooth and location services while the mobile application is open and in the background. This information is used in connection with the mobile building access functionality and in order to determine if you are close enough to the physical access readers installed in the buildings. We collect and store the minimum amount of personal information required to provide you with building access and user support, as needed.
Centuria does not store payment details of its users. We use third party payment gateway providers, such as Stripe Payments Australia Pty Ltd, to process payments made for our services made on the Platform. If you purchase products or services from us through the Platform (such as those offered by third party vendors), your payment information will be collected by that third party provider.
Except as described in this Policy, we do not collect any sensitive information (this includes medical information, details of race or ethnic origin, religious beliefs, political opinions or associations, philosophical beliefs, sexual orientation, criminal record or membership of a trade union). Nor do we collect any information about your health, genetic background or biometric personal information. We may collect sensitive information about you if this information is provided by you or a third party vendor through the Platform in connection with products and services purchased from that third party vendor. If you provide us or any third party with sensitive information for any reason, you consent to us collecting that information and using and disclosing that information for the purpose for which you disclosed it to us and as permitted by law.
The Platform is not intended for use by children and should not be accessed by individuals under the age of 18 years old or the age of majority (Age Limit). We do not intentionally seek to gather information from
individuals under the Age Limit nor do we anticipate them to be engaging with the Platform or services. We strongly encourage parents and guardians to provide adequate protection measures to prevent minors from providing us with any personal information. We will, upon notice or discovery, take all reasonable steps to securely remove, erase or destroy any personal information that may have been collected or stored by us about any person under the Age Limit without our knowledge.
Automated information collection
To provide services through our Platform, or to understand more about visitors to our Platform, Centuria and the Platform Provider may also collect and store information about your interaction with the Platform. This information is collected using automated tools which may collect information as statistical data and includes the IP address, browser type, preferred language and access times and this information may include personal information. Our Platform also uses cookies to track the pages you have viewed and the actions you have taken while using the Platform. Our Platform may also use third party website tools from time to time, for example data analytics and online survey tools. Cookies are a small data file transmitted from a visited website which is sent to your device’s hard drive. Your browser or electronic device may offer settings that allow you to accept browser cookies or to reject them. We recommend that you leave cookies active to enable full use of the Platform’s attractive features and to receive optimum functionality. Centuria and the Platform Provider may use the following categories of cookies on the Platform:
Third party websites and services
We work with a number of service providers of marketing communications technology. These service providers may use various data collection methods to improve the performance of the marketing campaigns we are contracting them to provide. The information collected can be gathered on the Platform and also on the websites where our marketing communications appear. For example, we may collect data where our banner advertisements are displayed on third-party websites. This may include web beacons which can
track certain things from your computer and can report activity back to a web server allowing us to understand some of your behaviour. If you choose to receive emails from us, we may use web beacons to track your reaction to our emails. We may also use them to track the time and date you click on links. Some third-party marketers we engage with may use web beacons to track your interaction with online advertising banners on the Platform. This information is only collected in aggregate form and will not be linked to your personal information. Please note that any image file on a webpage can act as a web beacon. Embedded web links provided in our emails and, in some cases, on third party websites may include tracking technology embedded in the link. The tracking is accomplished through a redirection system which allows us to understand how the link is being used by email recipients. Some of these links will enable us to identify that you have personally clicked on the link and this may be attached to the personal information that we hold about you. This data is used to improve our service to you and to help us understand the performance of our marketing campaigns.
Your choices and selecting your privacy preferences
We want to provide you with relevant information that you have requested. Any such communications you receive from us will be administered in accordance with your preferences and this Policy. If we provide subscription-based services, such as email newsletters, we will allow you to make choices about what information you provide at the point of information collection or at any time after you have received a communication from us while you are subscribed. Transactional or service-oriented messages are usually excluded from such preferences, as such messages are required to respond to your requests or to provide goods and services, and are not intended for the purposes of marketing.
From time to time we may send you marketing communication regarding our products and services and those we consider may be of interest. We may contact you by electronic messages (e.g. email), online (e.g. through the Platform), by mail and other means. You have the right to withdraw consent to receive marketing at any time by contacting us via the contact details at the bottom of this Policy or by using the opt-out mechanism included at the bottom of marketing emails. In the event you opt-out of marketing communications you will still continue to receive important business communications related to your relationship with us, such as communications about subscriptions or event registrations, service announcements or security information. In addition, we may continue to provide you with messages that are not regarded as "direct marketing" under privacy legislation, including changes to our terms, system alerts, and other information related to your account as permitted under privacy legislation.
Safeguarding the information we collect
We store personal information in both physical and electronic form at our offices or on our servers or those managed by the Platform Provider or other third party service providers. We use reasonable technical, administrative, and physical safeguards in order to protect your personal information against accidental loss and from unauthorised access, use, alteration, and disclosure. We strongly recommend you also safeguard your personal information through the proper use and security of any online credentials required to access your personal information, such as a username and password. If you believe your credentials have been compromised, please change your password and notify us immediately of any unauthorised use of your personal information or credentials. In addition, we limit the access to your personal information to those employees, agents, contractors and other third parties who need to access your personal information to do their job. They will only process your personal information upon our instructions, and they are subject to a duty of confidentiality.
How we use your personal information
We collect, hold, use and disclose information, including your personal information, primarily for business purposes that are directly related to our business activities and when it is necessary and relevant to our relationship with you. In addition, we may also collect information, including personal information, for other purposes, including for the following purposes:
verifying your identity and information;
facilitating account creation and the logon process;
assisting you with items such as personalised experiences, to facilitate the use of products and services (whether offered by Centuria or third party providers), and enforcement of the Terms of Use;
preventing malicious activity and providing you with a secure experience;
providing service and support for services you request;
managing your access to services and electronic resources with or managed by Centuria and its related bodies corporate which the Platform relates or the building manager;
providing marketing communications;
keeping you up-to-date with the latest benefits available from us;
preventing unwanted messages or content;
measuring the performance of our marketing programs;
monitoring and analysing Platform usage and trends, and to personalise and improve the Platform and users ‘experience with the Platform, such as providing content or features that match their profiles or interest, and to increase the Platform’s functionality and user friendliness;
issuing building, Centuria or the building manager related information such as anything specific to your organisation, location or tenancy;
for other purposes to which you have consented and related purposes which would be reasonably expected by you; and
as otherwise authorised or required by law.
We also may use, disclose or otherwise transfer and assign your information:
in response to a subpoena or similar investigative demand, a court order, or a request for cooperation from a law enforcement or other government agency;
to establish or exercise our legal rights;
to defend against legal claims;
to comply with applicable laws and regulations;
to detect and prevent fraudulent activity; or
to protect and defend the rights, property or safety of our company, our customers, our employees, or others.
How we share your personal information
We may disclose your personal information to third parties set out below for any of the purposes set out above. The types of third parties to whom we disclose personal information include:
the property and facility manager;
the concierge at the building;
our related entities (defined as any other entity that directly or indirectly through one or more intermediaries, controls, is controlled by, or is under common control with us) and third-party business partners in accordance with this Policy;
the Platform Provider and our other service providers, including providers of campaign, promotion, accounting, auditing, legal, banking, payment, debt collection, delivery, data processing, data analysis, document management, research, investigation, technology services, retailers and training providers;
third party vendors that offer their products and services to you through the Platform;
law enforcement and government agencies for reporting and compliance purposes;
persons who you authorise to access and use our Platform, products and services or who have authorised you to access and use our Platform, products and services;
your organisation and its representatives; and
to a third party organisation in connection with a business transaction involving Centuria, such as the sale of our business, a divestiture, merger, consolidation, asset sale, or the like or in the unlikely event of winding up.
While the Platform Provider provides the software and technology to process the information and materials on the Platform, the Platform Provider does not collect, use or otherwise store your Personal Information, unless necessary to provide its services for the Platform. However, the Platform Provider may aggregate or otherwise anonymise any data collected on the Platform for purposes of analytics, research, marketing and other business interests of the Platform Provider. Such use by the Platform Provider shall not include personal information or information that can identify you as an individual or reasonably be used to identify you. In addition, we will not share, sell, distribute or otherwise transfer your Personal Information to the Platform Provider unless it is necessary to perform its services for the Platform.
From time to time, we may provide links or mechanics to interface with our Platform for your information or convenience or offer additional services through separate websites. These websites or other domains operate independently from us and may be subject to alternative terms of use, including terms concerning use of your personal information. We have not reviewed these third party websites and do not control and are not responsible for any of these websites, their content or their privacy policies. If you decide to access or interact with any of the third party websites on our Platform, this Policy does not extend to them and you therefore do so at your own risk. We encourage you to read any posted privacy policy of the third party website before using their service or site and providing any personal information.
Overseas disclosure
We may transfer your personal information to other members of the Centuria group, who may be located overseas in other countries in which we conduct business. We may also subcontract certain activities and share your personal information with third party suppliers or partners located in other countries. In addition, we, or our subcontractors, may use cloud technology to store or process your personal information, which may result in storage of data outside Australia. The countries in which these organisations are located will vary, but, in the course of our business operations, we generally disclose personal information (including for hosting and data storage) to supplier organisations located in India and the United States of America. Such transfers are made in order to provide the services and carry out the activities specified in this Policy. When we disclose information in accordance with this Policy, it may be accessed from, transferred to, and/or stored outside the country in which you are located.
How you can access and correct your personal information
From time to time, we may need to reject your request to access or correct the information we hold about you, if we believe it to be necessary and to the extent permitted by law. You may also contact us if you wish to obtain further information regarding our privacy practices and the way we handle your personal information.
We take your privacy concerns seriously. If you have a question or complaint regarding our treatment of your personal information or concerning our privacy practices, you may raise it with us using the contact details below. Any query or complaint will be assessed with the aim of resolving any issues in a timely and efficient manner. We may need to contact you to request further details relating to your query or complaint. If you are unsatisfied with our response to your complaint, you may also raise a complaint and contact the Office of the Australian Information Commissioner, www.oaic.gov.au.
We value your opinions and welcome your feedback. If you have any questions or to contact us about this Policy, our privacy practices, or you would like to request access to or correction of any personal information we may hold about you, or exercise any other rights you may have under applicable privacy laws, please contact our privacy officer by using the details below or the “Get in touch” function of the Platform.
Contact: The Privacy Officer
Email: compliance@centuria.com.au Phone: +61 2 8923 8923
Address: Level 41, Chifley Tower, 2 Chifley Square, NSW 2000