Privacy Policy
1 Background
To provide you with our Services, HCPT Pty Ltd, Related Entities and agents (we, our, us) need to collect Personal Information. If we do not collect Personal Information or if any of the Personal Information you provide is incomplete or inaccurate, we may not be able to provide the Services or those Services may be compromised.
We recognise the trust you place in us when you provide us with Personal Information and are committed to protecting your Personal Information and complying with our obligations under the Australian Privacy Principles. This document provides you with information on how we collect, use, store and disclose your Personal Information.
2 Definitions
In this policy:
3 What Personal Information do we collect?
The type of Personal Information we collect may differ depending upon the circumstances of our relationship with you and the nature of the Services we provide to you. Depending on the nature of the Services we provide to you, Personal Information we collect may include but not be limited to:
Name, email address, telephone numbers, address, date of birth and any other contact details, Gender, Surveillance images, Shopping preferences, Interests, Debit or credit card information, If you seek credit from us, your financial and trading information and credit reference information, Sensitive Information, (for example, if you advise us of any disability or medical issue), Information as to Retailer’s financial standing and retailing experience, Financial and trading information and credit reference information, Qualifications Employment history, Information provided in response to application, Licensing information, Identification documents.
4 Credit
To the extent allowed by law, we may and you authorise us to collect, use and disclose information in respect to any credit we provide to you, including to a Credit Reporting Body (CRB). This includes information the CRB requires to provide us with a report to assist us in assessing your credit worthiness, payment or default information, information about fraud or any other serious credit infringement, information about adverse court judgments, insolvency or bankruptcy and publicly available credit information about your credit worthiness.
If you default in the payment of any monies owed to us, you authorise us to provide Personal Information to the CRB. This information may then be used and disclosed by the CRB in accordance with the Privacy Act and the CRB’s privacy policy, including providing credit assessments to other credit providers. You may request the CRB not to use or disclose your credit information in some circumstances, e.g. if you have been a victim of fraud. Information about the CRBs we use may be obtained from our Privacy Officer, whose details are set out below.
5 How do we collect the Personal Information?
We collect Personal Information:
If at any time you supply Personal Information to us about any other person (e.g. by posting a photo on our Facebook page), you represent and we accept that information on the basis that you are authorised to do so and that the relevant person has consented to the disclosure to us.
6 CCTV, other imaging and tracking
We use video and camera surveillance within and in the car parks outside our Centres. In addition, our Retailers may have video and camera surveillance within their stores or offices.
The surveillance video and camera images may include images of you and anyone accompanying you, as well as details of your vehicle and your vehicle registration number. The images will be used for the purpose of identifying security issues and for any other purpose authorised under the Privacy Act.
7 How do we use Personal Information?
We use the Personal Information we collect for operational purposes, including:
8 Marketing
We may use and disclose your Personal Information to provide you with information on offers, products and services offered by us, our Retailers, our Related Entities and our business associates. If at any time you no longer wish to receive any additional marketing material from us or do not want your information disclosed for direct marketing purposes, contact our Privacy Officer and we will remove your details from our marketing database. We do not use Sensitive Information for marketing purposes.
9 Disclosing Personal Information
In addition to the situations above, we may disclose your Personal Information to our Related Entities and third parties in certain circumstances including:
10 Security considerations
While we do all we reasonably can to protect your Personal Information from misuse, loss, unauthorised access, modification or disclosure, including investing in security software, the Internet is not a secure environment. The open nature of the Internet is such that information exchanged via the Internet may be accessed and used by people other than those for whom the data is intended. If you send us any information, including (without limitation) Personal Information, it is sent at your own risk. If you access a third party links (e.g. Retailers) from our website, you do so and provide Personal Information in accordance with the terms and conditions under which the provider of that website operates.
11 How your information is stored
We endeavour to keep our information systems and files secured from unauthorised access. Those who work with us are aware of the importance we place on protecting your privacy and their role in helping us to do so. Our procedures to securely store Personal Information include electronic and physical security measures, staff training and use of password protection software.
When the Personal Information that we collect is no longer required, we will remove or de-identify the Personal Information as soon as reasonably possible. We may, however, retain Personal Information for as long as is necessary to comply with any applicable law, for the prevention of fraud, for insurance and governance purposes, in our IT back-up, for the collection of any monies owed and to resolve disputes.
12 How you can update, correct, or delete your Personal Information
You may request access to your Personal Information or correct any inaccurate or out of date information by contacting our Office. For security purposes, we may ask you to provide evidence of your identity. Upon request, in most cases we will give you access to the personal information that we hold about you and take reasonable steps to correct any incorrect information. We will try to make the process as simple as possible.
You may request the source of any information we collect from a third party. We will provide this, unless under the Privacy Act or other law there is a reason for this information being withheld. If there is a reason under the Privacy Act or other law for us not to provide you with information, we will give you a notice of refusal setting out the reasons for the refusal except to the extent it would be unreasonable to do so and the mechanisms available to you to complain about the refusal.
13 Changes to our Privacy Policy
This document sets out our current Privacy Policy. Our Privacy Policy will be updated from time to time. You should therefore review our Privacy Policy each time you visit our Website or provide us with Personal Information. By continuing to access and use our Website or providing us with Personal Information you agree to our Terms and Conditions as updated and modified.
14 Contacting us
You should contact us immediately if you believe:
Our contact details are:
Attention: The Privacy Officer
Mail: HCPT Pty Ltd
PO BOX R430 Royal Exchange Sydney NSW 2000
Email: info@hadleygreen.com.au
Please provide details of your complaint and your contact details to enable us to discuss it with you and conduct our investigations. We will respond to you within 30 days.
More information about your rights and our obligations in respect to privacy and information on making a privacy complaint are available from the Office of the Australian Information Commissioner at:
Website: www.oaic.gov.au
Post: GPO Box 5218 Sydney NSW 2001
Email: enquiries@oaic.gov.au
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