Privacy Policy

Policy snapshot

We are committed to protecting your privacy in compliance with our legislative obligations.

We will only collect, use, handle and disclose personal information as allowed by, and in compliance with, the privacy legislation applicable to us.

Your privacy is important to us

QIC Limited and its subsidiaries (including without limitation QIC Properties Pty Ltd, QIC Robina Pty Ltd, QIC Logan Hyperdome Pty Ltd, QIC Logan Hyperdome (No 2) Pty Ltd, QIC Noosa Civic Pty Ltd, Eastland Property Holdings Pty Ltd, Pacific Echo Pty Ltd, Watergardens Pty Ltd, Canberra Centre Investments Pty Ltd and QIC Westpoint Pty Ltd) together ‘QIC’, ‘we’, ‘us’ or ‘our’ are committed to protecting your privacy, in compliance with the Australian Privacy Principles (APPs) and the Privacy Act 1988 (Cth). Our subsidiaries in the U.K. and the U.S. also protect your privacy in compliance with local privacy laws.

We are committed to being open about how we use personal information and this Policy sets out how we handle your information.

Collection of information

We limit our collection of personal information[1] to those details we identify as reasonably necessary for the lawful purposes of our business.  Being a wholesale funds manager, we do not collect or hold personal information in relation to individual members of funds who invest with us.  Personal information will only be collected by lawful and fair means from the individual concerned or their representative.  The collection of ‘sensitive information’[2] will only be in accordance with the law.

We will inform you at or before the time of collection (or as soon as possible afterwards) of the purposes for collection, to whom your information might be disclosed and any other relevant details that will help you to ensure we are protecting your privacy.

We take reasonable steps to keep personal information as accurate, complete, and up-to-date as is necessary for the purposes we have identified.

Handling of information

We only collect and use information for the purpose of providing our products or services, including sending you information, or undertaking our business.  Examples of who we usually collect information from, types of information, purposes for collection and method of collection are contained below:

Person

Types of information

Identified purposes

Method of collection

Key individuals employed by our investment clients or their representatives

Business and personal contact details, family information (such as name of spouse/partner, and details of children), social preferences (information which enables us to tailor events and entertainment), special dietary information

Client relationship management, business development, seminars and other client events, and for the conduct of daily business operations including the identification of clients as required by law or regulation

Verbally or by email, directly from the individual or personal assistant / secretary

Tenants or key individuals associated with the corporate tenants of various retail and commercial properties held as assets of QIC investment funds

Financial and contact details

Leasing negotiations, decisions and documentation, operational tenancy communications, and sale of premises

Leasing documentation and communications with tenants and solicitors

Potential employee candidates

Employment history, experience, qualifications, contact details, and checks as to criminal history, personal insolvency and regulatory sanction

Assessment for suitability for a current or future position

Resumes received from applicants in response to positions advertised, or unsolicited resumes, or completion of a criminal history / insolvency check form (or by way of a response received from an external agency verifying the details provided on the form)

Industry-related contacts and other individuals interested in QIC or the funds management industry

Contact details (including job title and name of their organisation)

Distribution of newsletters and other publications to provide regular information about the views and operations of QIC

Directly from the individual, either verbally or via a form for updating details

Individuals who supply (or are employed by organisations that supply) goods or services to QIC – this includes those who facilitate our investment transactions

Contact details and bank account details (where financial transactions are undertaken)

In relation to the supply of the goods and services and to facilitate the credit and payment arrangements

From the individual directly, usually verbally or from transaction documentation

Individuals in respect of who we are obliged by law to conduct AML/CTF checks

Copies of identification documents

To enable QIC to comply with our AML/CTF obligations

Directly from the individual, either verbally or via a form for collecting details

Customers of retail properties held as assets of QIC investment funds (Shopping Centre)

Contact details (including name, address, gender, email address, date of birth), shopping preferences, interests, photographic images

Direct marketing (e.g., promotional activities, distribution of newsletters and other publications). Photographic images are used for security purposes or for promotional activities  

Directly from the individual, either verbally or via a form for collecting details. For images, from video surveillance cameras when customers visit our Shopping Centre or when using cameras for promotional activities

Individuals who use our Shopping Centre websites (website)

Contact details (including name, address, gender, email address, date of birth), shopping preferences, interests, IP address, the date and time an individual accesses our website and the pages accessed

Direct marketing (e.g., promotional activities, distribution of newsletters and other publications)

Directly from the individual when they sign up for membership of our Shopping Centre. We use cookies to track usage of our website

Disclosure of information

At QIC, personal information is strictly confidential.  We will only disclose personal information in accordance with the law.  We may disclose your personal information:

‒       to other companies within the QIC group;

‒       to our commercial partners;

‒       to third parties who perform services for us;

‒       to government agencies to meet our statutory obligations; or

‒       where it is required or authorised by law.

We may use and disclose your personal information overseas. Any information sharing will be in compliance with the law and governed by our strict standards and policies, and where appropriate, confidentiality agreements to ensure your information is secure and treated with the utmost care and respect.

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.

Information access

We will give you, or your authorised representative, access to your information unless the request is frivolous, vexatious or there are other lawful reasons to restrict access. We may require identification to ensure the person requesting access is entitled to such access. If you, or your representative, is denied access to your information, we shall provide reasons for the denial.

If you are a registered member of our Shopping Centres, you may be able to access and update the information on your member profile in the applicable section of the Shopping Centre website.

Checking and correcting information

At QIC, decisions and actions may be taken or made on the basis of personal information in our possession and we take reasonable steps to keep personal information as accurate, complete, and up-to-date as is necessary.   

If you believe any part of the information is inaccurate, incomplete or not up-to-date, you should contact your usual QIC contact and request we amend it accordingly.    We may ask you to put your request in writing.  If we are reasonably satisfied our records need correcting, we will make the correction as soon as possible.  If we do not agree our records need correcting, we will inform you of the reason(s) and you may require us to keep a statement on our records that you believe the information is inaccurate, incomplete, misleading, irrelevant or not up-to-date.

Resolving enquiries or complaints

If you have any questions, concerns or complaints about the treatment of your personal information, the first step is to discuss the issue with your usual QIC contact.

If your concerns have not been resolved to your satisfaction, please contact our Privacy Compliance Officer on +61 7 3360 3922 or by email at privacy@qic.com. In the U.K., please contact our UK Data Protection Officer on +44 20 7092 8220 or by email at privacy@qic.com. We may ask you to put your query in writing.

If after contacting our Privacy Compliance Officer your concerns remain unresolved, you may contact the Office of the Australian Information Commissioner on 1300 363 992, or by email on enquiries@oaic.gov.au. You can also visit their website at www.oaic.gov.au. In the U.K., you may contact the Information Commissioner’s Office on 0303 123 1113. You can also visit their website at www.ico.gov.uk

 

[1]Personal information’is information or an opinion about an identified individual, or an individual who is reasonably identifiable:

(a)whether the information or opinion is true or not; and

           (b)hether the information or opinion is recorded in a material form or not.

[2]Sensitive information’ is a subset of personal information.  It means information or an opinion about an individual’s racial or ethnic origin, political opinions, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual orientation or practices, criminal record, health, genetics or biometrics.  As a general rule, the only type of sensitive information we hold is in relation to an individual’s professional or trade association membership.

See also...

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