Privacy Policy

YOUR RIGHTS IN RELATION TO PRIVACY

1. Your rights in relation to privacy

We understand the importance of protecting the privacy of an individual’s personal information. This policy statement sets out how Dennis Family Corporation Pty Ltd ABN 15 089 081 667 and its related entities set out below (we/our/us/Group) aim to protect the privacy of your personal information, your rights in relation to your personal information managed by us and the way we collect, hold, use and disclose your personal information.

For the purposes of this policy, reference to the Group includes the following entities:

Dennis Family Corporation Pty Ltd;
Dennis Personnel Pty Ltd;
Dennis Family Homes Pty Limited;
Ranfurlie Asset Management Pty Limited; and
any other related bodies corporate (as defined under the Corporations Act 2001) of the above entities.

In handling your personal information (including credit-related personal information), we are committed to preserving your privacy in accordance with the Privacy Act 1988 (Cth) (Privacy Act) and its 13 Australian Privacy Principles. This policy may be updated from time to time.

To the extent that we handle your credit-related personal information, we will also comply with the Credit Reporting Code.

This policy statement addresses the following:

What kinds of personal information do we collect?
How do we collect your personal information?
Why do we need your personal information?
To whom do we disclose your personal information?
Overseas disclosures
Direct marketing
Security of your personal information
Third party links
Electronic contracts
Can you access and correct the personal information that we hold about you?
Right to refuse access or correction
Web site cookies
Wi-Fi services
Bluetooth Surveillance
CCTV surveillance
Privacy complaints
Changes to this policy
How to contact us

2. What kinds of personal information do we collect

Personal information is information or an opinion about an identified or reasonably identifiable individual During the provision of our products and services we may collect your personal information

Generally the kinds of personal information we collect include

your contact and identification information such as your name previous names and change of name documentation address previous addresses telephone number email address and date of birth
banking financial loan and trading information including information about your assets tax assessments rental contracts occupation employers and previous employers income account balances and activities and transactions with us or third parties
property and title information including information about land values
credit information being creditrelated personal information lawfully created and accessible within the Australian credit reporting system including
identification information including viewing or obtaining copies of your drivers licence Medicare card passport birth certificate or extract citizenship certificate or evidence of permanent residence marriage certificate or other evidence of your relationship status and ATM cards
consumer credit liability information including
information about existing and previous credit providers and credit accounts
the types of consumer credit provided
the day on which the accounts were entered into terminated or otherwise ceased to be in force
the terms and conditions of the consumer credit relating to the repayment of the credit or otherwise prescribed by law and
the maximum amount of credit available under the consumer credit

repayment history information being information about whether you have met your monthly payment obligations with respect to consumer credit
information about defaults
information regarding whether another entity has sought creditrelated personal information about you from a credit reporting body
information about the types of credit and the amounts of credit you have sought from a credit provider
information about court proceedings related to credit provided to you or for which you have applied
personal insolvency information and other publicly available information relating to your credit worthiness
a credit providers reasonable belief that you have committed a serious credit infringement and
any other information lawfully obtainable within the Australian credit reporting system
personal information for actual or prospective tenant of premises or kiosks licensee or assignee
Retailers and licensees names addresses dates of birth contacts and insurance details job descriptions business details trading history financial capacity and private and business assets and liabilities For retailer or licensee personnel staff it includes name job position contact details and any other information required for registering retailer personnel for centre services such as retailer carparking entry passes and keys for which we collect number plate details
Guarantors name job position contact details and all other information on your business experience trading history financial capacity as well as personal and business assets and liabilities
your vehicles license plate number when attending our retail locations
credit eligibility information which is information about you including the Information set out above that we obtain from a credit reporting body together with information we derive from such information based on our own analysis This may include an internally generated assessment which reflects your suitability for a loan arrangement
insurance information
information including your photographic or video image collected via various methods including by our CCTV surveillance systems
if you are a prospective employee your employment history academic results personal interests and other information you may provide as part of the recruitment process
sensitive information including health information and criminal record information where you are applying for a position with us and it is relevant to the recruitment process through which you must progress or where you have consented to such collection
your opinion or preferences regarding our products or services
information concerning your online presence and the websites you access as provided to us through your use of our websites and your use of our WiFi services
information concerning your location and movement as provided to us through your use of Bluetooth surveillance and
other personal information required for our functions and activities and to enable you to deal with us
In some circumstances we may also hold other personal information provided by you or a credit reporting body

3. How do we collect your personal information

Generally we collect your personal information including creditrelated personal information directly from you through the completion of a manual or online form an interaction or exchange in person or by way of telephone facsimile email post or through the use of our website including but not limited to when you

make enquiries about our products or services
ask to be placed on our mailing lists
complete a form
use any of our various websites
utilise our WiFi services or by Bluetooth surveillance
meet with any of our staff
become a client debtor lessee or licensee or
apply for a job with us
There may be occasions when we collect your personal information from other sources including but not limited to

an information services provider
a publicly maintained record or other publicly available sources of information including social media and similar websites
the Land Titles Office and other property registers
relevant State and Territory Valuers General
real estate agents
ASIC
Australian Federal Police
Department of health services
local road regulator
Medicalallied health providers
the Insolvency and Trustee Services of Australia
credit reporting bodies including Equifax Australia Pty Ltd Equifax Level 15 100 Arthur Street North Sydney NSW 2060 or other credit reporting bodies to assist us in determining whether we will provide a credit account to you or to an entity you represent or for which you are a director or guarantor
if for recruitment purposes an external recruitment or background screening services provider or
third party providers which collate information which may otherwise be available through a generally available publication In particular we collect information from a third party provider which collates information from real estate agents property registers and relevant Valuers General for the purpose of identifying comparable land values
We may also collect personal information about you when conducting market research

Generally we only collect your personal information from sources other than you if it is unreasonable or impracticable to collect your personal information from you

4. Why do we need your personal information

We collect hold use and disclose your personal information where it is reasonably necessary for the purposes of

providing our products and services to you including
building and construction of residential homes
completing land and property sales
ascertaining comparable land values
leasing and property management
operation of retail centres
enabling our contractors to provide products and services to you including
building and construction of residential homes
completing land and property sales
ascertaining comparable land values
enabling our contractors subcontractors to assist our contractors to provide products and services to you
enabling our contractors to engage in direct marketing with you
complying with our legal obligations
as a corporate credit representative of an Australian Credit Licence holder
under the AntiMoney Laundering and Counter Terrorism Finance Act 2006 and
under the National Consumer Credit Protection Act 2009 including the responsible lending guidelines and
carrying out our business functions including
recruitment processes for potential employment
personalizing and customizing your customer experience
engaging you as a contractor or consultant
tracking when you visit our offices retail centres and display villages
tracking your customer sales experience
distributing promotional materials
market research
conducting customer profiling device tracking and traffic management
offer mobility equipment for hire within our shopping centres
monitor car park usage and help you locate your vehicle
accounting billing and other internal administrative purposes
identifying and informing you of products and services that may be of interest to you
managing and enhancing our services including managing security and safety requirements at all our sites
providing as part of our business data to third parties
protecting the security of our property buildings and assets including building perimeters entrances exits reception and corridors
verifying alarm and access control system conditions
investigating any complaints about or made by you or if there is any reason to suspect that you are in breach of any of our terms and conditions or that you have engaged in any unlawful activity
to assist law enforcement agencies for example in connection with the detection investigation or prosecution of an offence and
any other legal requirements
If you lease license or apply to lease or license from us to
Determine whether to grant a lease license or other rights to use our facilities or services
Manage and operate our relationship agreements payment systems and processes and communications with you this includes notices issued under leases and licenses
Manage and operate the centres and its facilities in which you lease or license space from us
Manage and monitor the performance of our centres
Observe all emergency procedures and contact you in the event of an emergency
Understand your interests preferences and activities as a retailer or licensee at our centres
Conduct market research surveys and interviews how to improve the retailer experiences at our shopping centres display homes and sales centers
We may also use your personal information including creditrelated personal information for purposes related to the above purposes and for which you would reasonably expect us to do so in the circumstances or where you have consented or the use is otherwise in accordance with law
Where personal information including creditrelated personal information is used or disclosed we take reasonable steps to ensure it is relevant to the purpose for which it is to be used or disclosed

You are under no obligation to provide your personal information to us However without certain information from you we may not be able to provide our products and services to you This includes assessing any application you make for employment or engagement as a contractor with us

5. To whom do we disclose your personal information

We disclose your personal information including creditrelated personal information for the purpose for which we collect it That is generally we will only disclose your personal information for a purpose set out at paragraph 3 above

This may include disclosing your personal information to third parties engaged by us to perform administrative or other services lenders or other credit providers mortgage insurers our contractors including without limitation building contractors related bodies corporate stationery printing houses mailing houses professional advisors or people or entities considering acquiring an interest in our business or assets

We also disclose to the credit reporting body Equifax the contact details of which are set out in paragraph 2 information about you having applied for credit This enables us to collect from Equifax credit related personal information about you for the purposes of

assessing your suitability for a loan and
facilitating financial advice and suitable loan arrangements
Our disclosures of your personal information including creditrelated personal information to third parties are on a confidential basis or otherwise in accordance with law We may also disclose your personal information including creditrelated personal information with your consent or if disclosure is required or authorised by law
Social Media Channels
social media channels on which we have a presence such as Facebook Twitter and Instagram generally in these cases we limit disclosure of your personal information to your first name and surname

6. Overseas disclosures

We do not disclose personal information including creditrelated personal information to overseas recipients However in the event we need to do so

we will only do so in order to provide our services and products and manage our business functions and
before disclosing any personal information including creditrelated personal information to an overseas recipient we will take reasonable steps to ensure the overseas recipient complies with the Australian Privacy Principles or is bound by a substantially similar privacy scheme unless you consent to the overseas disclosure or it is otherwise required or permitted by law

7. Direct marketing

We may use and disclose your personal information in order to inform you of our products services offers including offers of employment or engagement and promotions that may be of interest to you and the products services offers and promotions of our contractors and third party service providers for example building contractors

In order to inform you of such products services offers and promotions such communications may be sent to you by email SMS or other form of electronic communication

In the event you do not wish to receive such communications from us or our third party service providers you can optout by contacting us via the contact details set out in paragraph 18 or through any optout mechanism contained in a marketing communication to you

8. Security of your personal information

We take reasonable steps to ensure that the personal information including creditrelated personal information we hold is protected from misuse interference and loss and from unauthorised access modification or disclosure We hold personal information in both hard copy and electronic forms in secure databases on secure premises accessible only by those who have a legitimate business purpose and reason for accessing it The secure databases are operated either by us or by our external service providers and we have implemented a range of security measures including strict confidentiality agreements passwords firewalls and encryption to restrict access

Credit eligibility information such as information we receive from Equifax or other credit reporting bodies for the purpose of assessing credit worthiness is stored through equally secure methods

We will destroy or deidentify personal information in circumstances where it is no longer required unless we are otherwise required or authorised by law to retain the personal information

You should be aware that the Internet is not a secure environment Although we will use reasonable endeavours to protect your personal information we cannot guarantee the security of personal information that is being transferred via the Internet If you use the Internet to send us personal information including your email address it is sent at your own risk Once we have received your personal information we will use strict processes and security measures to prevent unauthorized access

If we engage external service providers to assist us to fulfil our functions and activities we will also require them to implement appropriate measures to protect any personal information that is provided to them

9. Third party links

In the event that our website contains links to websites that are operated by third parties such links are provided as a convenience to you and should not in any way be interpreted as an endorsement of any company content or product that may be linked Any access to a third party website that is linked to our website is at your own risk and we have no control over and are not responsible for the accuracy validity or ownership of any content of a linked site and the privacy practices of those linked websites

10. Electronic contracts

We use electronic contracts econtracts to facilitate transactions with you and to enable us to provide our products and services to you This also includes any offer of employment or engagement with us Under this policy you consent to us using econtracts in your dealings with us We handle personal information including creditrelated personal information collected by econtracts in the same way we handle all other personal information as set out in this privacy policy

11. Can you access and correct the personal information that we hold about you

We take reasonable steps to ensure personal information including creditrelated personal information we collect hold use and disclose is accurate uptodate complete relevant and not misleading

Under the Privacy Act you have a right to access and seek correction of your personal information that is collected and held by us

If at any time you would like to access or seek correction of the personal information including creditrelated personal information that we hold about you or you would like more information on our approach to privacy please contact our Privacy Compliance Officer via the contact details set out in paragraph 18

We will grant access to your personal information to the extent required or authorised by the Privacy Act or other law and take reasonable steps to correct personal information including creditrelated personal information where necessary and appropriate
Where necessary to resolve a request for correction of your creditrelated personal information we may also consult with other relevant entities including but not limited to any relevant credit reporting body

To obtain access to your personal information including creditrelated personal information

you will need to provide proof of identity This is necessary to ensure that personal information is provided only to the correct individuals and that the privacy of others is protected
we request that you be reasonably specific about the information you require and
we may charge you a reasonable administration fee which reflects the cost to us for providing access in accordance with your request
In the event we correct personal information that we have previously disclosed to another entity you may request us to notify that other entity of the correction In these circumstances we will take reasonable steps to notify the other entity of the correction unless it would be impracticable or unlawful to do so
We will endeavour to respond to your request to access or correct your personal information within 30 days from your request

You may also seek to access and correct personal information we have obtained about you from Equifax by contacting them on the details set out in paragraph 2

12. Right to refuse access or correction

We reserve our right to refuse your request to access or correct your personal information if we consider your request to be frivolous or vexatious or if we are otherwise legally entitled to do so

If we refuse your request to access or correct your personal information we will provide you with written reasons for the refusal and details of complaint mechanisms We will nevertheless take reasonable steps to provide you with access in a manner that meets your and the needs of the Group

If we refuse your request to correct your personal information that we hold and you provide us with a statement that the information is inaccurate outofdate incomplete irrelevant or misleading we will take reasonable steps to associate the statement in such a way that will make the statement apparent to users of your personal information

Google Analytics
By accessing our websites you consent to the collection and processing of your personal nonidentifiable information or data for the above purposes including the association of such information or data with the visitation information Google Analytics collects from our websites

13. Web site cookies

We make limited use of cookies technology on our website We use cookies which can record information about your visit to our website to improve the functionality of our website and enable us to better understand your needs The cookies store a log file which is retained for technical and statistical purposes only

We also make use of third party cookies for example those that are sent by advertisers on websites that you visit Third party cookies are used on our website to enable remarketing and reporting of user demographics and user interests

The information collected is not personal information and to the extent any personal information is collected it is deidentified prior to being analysed for technical and statistical purposes Cookies are a feature of your Internet browser that you can disable at any time but this may mean that you are not able to use the full functionality of our website

14. WiFi services

We offer WiFi services to customers and prospective customers at certain sites including our sales offices buildings shopping centres and display home villages
If you are in possession of a device that is enabled for WiFi and you are within range of one of our networks we will automatically collect your location information and other information about your device while you are within range of our WiFi network for example the type of device you hold MAC address signal strength information specific to the handset and operating system and its movement patterns Such information is unlikely to personally identify you unless you connect to our WiFi network

In addition to the information referred to above if you connect to our WiFi network we may collect personal information from you including your name phone number email address and details of the websites you access while you are connected to our network This is only in circumstances where you are inputting this information whilst using our WiFi network We may use your personal information in aggregate form to improve our services and make them more responsive to your needs

If you prefer that the above information is not collected via our WiFi services simply opt out by turning off your phones WiFi when entering our buildings

15. Bluetooth Surveillance

If you are within range of one of our networks and have Bluetooth capability on your smartphone switched on and are in possession of a device that is enabled for WiFi we will automatically collect your location information and other information about your device while you are within the range of our WiFi network for example the type of device you hold MAC address signal strength information specific to the handset and operating system and its movement patterns Through the use of this Bluetooth surveillance we will also be provided with your mobile number

One of the ways we will collect this information is through the use of Skyfii through Bluetooth capabilities available in our carparks offices buildings and retail centres for the purpose of tracking visitor flows tracking customer sales experiences and marketing to customers For further details please refer to Skyfiis Privacy Policy httpswwwbeoniccomprivacypolicy and Terms and Conditions httpswwwbeoniccomtermsandconditions
For customers already on our database we use the information gathered via Bluetooth surveillance for promotional marketing purposes For those individuals not already on our database we will not use the information gathered through Bluetooth surveillance for promotional marketing purposes

One of the ways we will collect this information is through the use of Blix Traffic whereby we install Blix sensors in our carparks sales offices buildings and display home villages for the purpose of tracking visitor flows tracking customer sales experiences and marketing to customers

If you prefer that the above information is not collected via our Bluetooth surveillance simply opt out by turning off your phones WiFi and Bluetooth capabilities when entering our display villages buildings and associated car parks

16. CCTV surveillance

We use CCTV surveillance systems to record activity at our sites including sales offices and car parks We collect hold use and disclose your personal information including your visual image gathered via CCTV surveillance systems for one or more of our legitimate purposes related to our operations including

ensuring the safety and security of staff and our premises and facilities
protecting the security of our property buildings and assets including building perimeters entrances exits reception and corridors
verifying alarm and access control system conditions
training security staff under appropriate supervision and

to assist law enforcement agencies for example in connection with the detection investigation or prosecution of an offence

17. Privacy complaints

Please direct all privacy complaints to our Privacy Compliance Officer At all times privacy complaints
will be treated seriously
will be dealt with promptly
will be dealt with in a confidential manner and
will not affect your existing obligations to us or affect the commercial arrangements you have with us
In the event you have a complaint with respect to privacy the Privacy Compliance Officer will commence an investigation and inform you of the outcome of the investigation If you are dissatisfied with the outcome of the investigation you may refer the complaint to the Federal Office of the Australian Information Commissioner or if you would like to participate in an external dispute resolution process to Credit Ombudsman Services Ltd Phone 1800 138 422 or PO Box A252 Sydney South NSW 1235

Specifically if your complaint relates to creditrelated personal information andor our failure to comply with our obligations regarding creditrelated personal information under the Privacy Act andor the Credit Reporting Code

we will acknowledge your complaint within 7 days of receipt in writing and endeavour to resolve it within 30 days unless we inform you otherwise and seek your agreement in writing
we may consult with relevant third parties such as a credit reporting body or other credit provider in order to sufficiently and expeditiously resolve the complaint and
if your complaint relates to our refusal to provide access to or correct your credit related personal information you may complain directly to the Office of the Australian Information Commissioner

Further Information

Changes to this policy

If we decide to change this privacy policy we will publish those changes on our website so that you are aware of what information we collect how we use it and under what circumstances if any we disclose it.

How to contact us

For further information or enquiries regarding your personal information, please contact our Privacy Compliance Officer at:

Email: privacy@denniscorp.com.au

Address: The Privacy Officer, Dennis Family Corporation, 863 High Street, Armadale, Victoria 3143. Ph: 03 9573 1208