Atomic

Privacy policy

This Privacy Policy describes how 151 Property Corporate Pty Limited (ABN 59 623 927 284) (151 Property), 151 Property NZ Limited (NZBN 9429046994202) (151 Property NZ) and their  related bodies corporate (together, 151 Property Group; we) collects, holds, uses and discloses personal information consistent with the Privacy Act 1988 (Cth), and if you are in New Zealand, the Privacy Act 2020 (each, the Act) and, where applicable, the Australian Privacy Principles (APPs) and Information Privacy Principles (IPPs) found in those Acts.

Overview

151 Property and 151 Property NZ are real estate investment companies. Each company collects, holds, uses and discloses personal information to carry out its activities which include managing real estate in commercial, industrial, retail, hotel, residential and development sectors in Australia and New Zealand.

Collection of personal information

The kinds of personal information that 151 Property Group members collect and hold include:

•  Name
• Gender
• Date of birth
• Contact details (for example, postal address, e-mail address, telephone number(s), facsimile number)
• Occupation – company and position
•  Bank account details
•  Passport and drivers licence information
•  Financial information, such as bank account statements
•  Utility bills
•  Rates notices
•  Dietary needs
•  Preferences in property requirements
•  Employment history

In the case of employees, 151 Property Group members also collect and hold personal information including:

• personal and emergency contact details
•  information about terms and conditions of employment
• wage or salary details
• leave balances
• records of work hours
• records of engagement, resignation or termination of employment
• information about training, performance and conduct
•  TFN
•  taxation, banking or superannuation details
• union, professional or trade association membership information

151 Property Group members collect personal information directly from you, including from correspondence, emails and business cards that you provide to us, and from telephone conversations we have with you. Sometimes a third party will collect this personal information from you on behalf of a 151 Property Group member. 151 Property Group members also collect personal information from related bodies corporate, and service providers, such as leasing agents, external legal services providers and property managers. We also collect de-identified information from our residential property manager.

Use and disclosure of personal information

The purposes for which 151 Property Group uses personal information include:

• providing real estate investment management services;
• administrative functions, including monitoring, auditing, evaluation, modelling data, answering queries;
• verifying your identity;
• processing job applications;
• to communicate with you; and
• in the case of current and former 151 Property Group employees, managing our employment relationship with you.

Your personal information may also be used so that 151 Property Group, service providers, agents and contractors can provide you with information about our services, such as direct mail and telemarketing, and, where you have opted in, by email, SMS and MMS, or to request your feedback for promotional purposes. You always have the right to opt-out of receiving such information. You may exercise that right by contacting us as set out below or using the unsubscribe facility provided in our communications to you.

In order to deliver our services to you, each 151 Property Group member may need to disclose personal information to its agents, contractors, related bodies corporate, including Revantage Global Services ANZ Pty Ltd, or third party service providers, such as other providers of administrative, telecommunications, information technology/computer or other services.

Your personal information may also be disclosed to other parties where you have agreed or it is required or authorised under law or by court/ tribunal orders. For example, a 151 Property Group member may disclose personal information associated with its regulatory reporting and compliance obligations, to statutory bodies such as the Australian Securities and Investments Commission.

151 Property Group members may share personal information with related bodies corporate or other third parties that are located outside of the country you are located in. They are generally located in:

• Australia
• New Zealand;
• the United States of America;
• United Kingdom;
• Hong Kong;
• Singapore;
• India; and
• Luxembourg.

When a 151 Property Group member discloses personal information to an overseas recipient, it takes reasonable steps to ensure that the personal information is handled securely and in accordance with this policy and the APPs and the IPPs.

Security

151 Property Group maintains strict standards and security procedures to prevent misuse, interference and loss, unauthorised access, modification or disclosure.

Personal information received by 151 Property Group is held electronically on secure information technology systems of 151 Property Group and may only be accessed by its authorised employees, contractors and service providers who require access in connection with the purposes described in this Policy. We take all reasonable steps to protect against the loss, misuse and/or alteration of the information under our control, and that the information we hold is accurate, complete and up to date including through appropriate physical and electronic security strategies. Only authorised personnel are provided access to personal information, and these employees are required to treat this information as confidential. Data is backed up daily, weekly and monthly and archives are stored in a secure location.

Personal information is also held in hard copy format. These documents are stored in lockable storage cabinets in secure premises.

Website

Cookies

We use “cookies” to enhance functionality and to keep track of visits to our website.

Cookies by themselves cannot be used to identify you personally; they only identify your computer to our servers when you visit our site. The information gained by us from the use of Cookies provides us with statistics, which can be used to analyse and improve our services.

Access to information

You can request access to personal information that 151 Property Group holds about you, and you can request that 151 Property Group corrects that personal information.

Before giving you access to your records, 151 Property Group will require you to prove your identity. We may ask you to verify your full name and other aspects of personal information.

151 Property Group will give you access to your personal information, and take reasonable steps to correct it if we consider that it is incorrect, unless there is a law that allows or requires us not to.

If 151 Property Group refuses to give you access to your personal information, or to correct it, 151 Property Group will notify you in writing and will provide reasons.

If you would like to access or correct your personal information, contact our Privacy Officer (details are below).

Complaints

If you wish to make a complaint to 151 Property Group about how a 151 Property Group member has handled your personal information, including if you believe it has not complied with this Privacy Policy or the Acts, you should forward a written complaint to our Privacy Officer:

Privacy Officer 151 Property

Suite 602, Level 6

151 Castlereagh Street

SYDNEY NSW 2000

Email:privacy@151property.com.au

Phone: 02 8257 6600

Our Privacy Officer will investigate the complaint and determine whether a breach has occurred and what action, if any, to take.  151 Property Group will respond in writing within 30 days of receiving a complaint.

If the complaint remains unresolved, you have the option of notifying the Office of the Australian Information Commissioner (OAIC) or New Zealand’s Office of the Privacy Commissioner (OPC):

Office of the Australian Information Commissioner (OAIC)

Complaints must be made in writing.

1300 363 992

Director of Compliance

Office of the Australian

Information Commissioner

GPO Box 5218

Sydney NSW 2001

Australia

www.oaic.gov.au

New Zealand’s Office of the Privacy Commissioner (OPC)

www.privacy.org.nz

0800 803 909

Or write to the office at PO Box 10 094, Wellington 6143, New Zealand

Changes to this Privacy Policy

Our Privacy Policy may change from time to time as updated on this website. Before providing us with personal information, please check this Policy on our website for any changes.

This Privacy Policy was last updated 24 July 2023.