PRIVACY POLICY

Privacy Policy

The last review of this Policy was conducted in March 2020.

This Privacy Policy covers all of the entities within the HLG Australia Holdings Limited, including HLG Investments & Capital Partners(HICP), HLG Ventures(HV), HLG Property & Asset Management (HPAM), HLG Retail, Resources & Energy(HRRE), HLG Services(HS) and related entities.

HLG Holding Australia Limited (ABN 57 14221 3250), partners, and affiliates members of the HLG Holding  Group (HLG Holding Australia, we, and us) recognize that your privacy is important and is committed to protecting and maintaining your privacy. HLG Holding Australia is bound by the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth). This Privacy Policy explains how HLG Holding Australia handles the personal information that it collects in the course of performing its functions and activities.

HLG Holding Australia  is an Australian holding and business service group, and its activities include:

  1. Direct property portfolio for its investors and shareholders – HLG Holding Australia  owns, develops, manages and trades Australian residential and industrial properties; and
  2. Third-party asset management – HLG Holding Australia transacts, designs, and manages Australian private, industrial, retail, and other investment asset portfolios on behalf of third-party capital partners.

HLG Holding Australia also has a portfolio of other asset classes. To manage these services, HLG Holding Australia may need to collect and use your personal information. If you provide incomplete or inaccurate information or withhold personal information from us, we may not be able to provide you with the services you are seeking.

Why HLG Holding Australia  collects personal information

The purposes for which HLG Holding Australia uses personal data depends on the dealings you may have with us, and these purposes may differ for tenants, investors, customers service providers, and job applicants.

  1. Tenants and prospective tenants

HLG Holding Australia collects personal information from individual tenants and guarantors, and representatives of corporate tenants, during negotiations for, and during the terms of, leases for its properties.

HLG Holding Australia uses personal information for purposes, including evaluating whether to grant leases and/ or enter into agreements with prospective tenants, documenting these leases and/or agreements, performing its obligations under leases and/or agreements with tenants, managing relationships with tenants and monitoring properties.

  1. Investors

Personal information collected from investors includes personal information such as name, date of birth and contact details, as well as security holding details and balances and tax file numbers.

HLG Holding Australia’s may use security holder, and unitholder registers that may be are maintained by external service providers Link Market Services Limited (for HLG Holding Australia itself) and BoardRoom Pty Limited (for unlisted funds). This information may be used to carry out registry functions, including facilitating distribution payments and corporate communications such as financial results, annual and half-yearly reports.

HLG Holding Australia  requires these external service providers to comply with the requirements of the Privacy Act and the APPs in handling the personal information of its investors.

  1. Customers

If you are a customer of HLG Holding Australia  Place, a we may use your personal information to provide, administer, improve and personalise our services, process payments, identify you, to communicate with you in relation to our services and to respond to your enquiries.

HLG Holding Australia conducts a Membership program for use of HLG Holding Australia  Place facilities. If you join the Membership program, we will use your personal information to provide you with rewards, discounts and access to unique member services though the program. We may also use your personal information to analyse usage of the program, improve our membership content and product offers, and conduct advertising and promotions.

  1. Service providers

If you, or a company you work for, supplies goods or services to HLG Holding Australia , HLG Holding Australia  may collect your personal information in connection with the provision of these goods or services. HLG Holding Australia  will use your personal information for purposes associated with managing the supply of these goods and services.

  1. Job applicants

HLG Holding Australia  collects personal information of job applicants for the purpose of assessing and (if successful) engaging applicants.

HLG Holding Australia  may store information provided by job applicants who were unsuccessful for the purposes of future recruitment. If you do not agree with this information to be retained by HLG Holding Australia , please contact our Privacy Officer (details below).

  1. CCTV

HLG Holding Australia uses personal information collected through camera surveillance systems (commonly referred to as CCTV) for the purpose of maintaining the safety and security of property and individuals working at or visiting its features. CCTV recordings in HLG Holding Australia properties/assets may also collect license plate details or body features.

  1. Other

We may use your personal information to send you direct marketing communications and information about our services, mostly by email. You may quickly request not to receive direct marketing communications by following the “unsubscribe” instructions on the communication, or by contacting HLG Holding Australia’s Privacy Officer at the address below.

Who HLG Holding Australia  may disclose your personal information to?

HLG Holding Australia  may disclose your personal information to our contractors and third-party service providers who assist HLG Holding Australia  in the operation of the business and/or the provision of our services. HLG Holding Australia  may disclose your personal information, for example, to financial institutions for payment processing, and to organisations that provide archival, auditing, professional advisory (including legal, accounting and business consulting), marketing, advertising, electronic mailing houses, and information technology services to HLG Holding Australia .

HLG Holding Australia may provide images of individuals collected by CCTV to tenants, law enforcement bodies and insurers for purposes associated with ensuring the security of HLG Holding Australia  properties and investigating unlawful conduct.

How we hold your personal information

We may hold your personal information in either electronic or hard copy (paper) form. We retain your personal information in our computer systems and databases, and in our physical files.

Security

HLG Holding Australia  takes reasonable steps to protect your personal information from misuse, interference and loss, unauthorised access, modification or disclosure. HLG Holding Australia  uses technologies and processes such as access control procedures, network firewalls, encryption, password protected databases and physical security measures to protect your personal information.

We keep your personal information for only as long as is necessary for the purpose for which we collected it.

Access to and correction of your personal information

You have the right to access the personal information that we hold about you. You can also request an amendment of your personal information if you believe that it contains inaccurate information.

HLG Holding Australia  will allow access or make requested changes to your personal information unless there is a reason under the Privacy Act or other relevant law to refuse you access or refuse to make the requested changes.

If you wish to obtain access or to request changes to your personal information, you can contact our Privacy Officer (details below).

HLG Holding Australia  may recover reasonable costs associated with providing you with access to your personal information.

Complaints and questions

If you have questions about how HLG Holding Australia handles your personal information, or if you have a complaint about HLG Holding Australia’s information handling practices, you can contact the Privacy Officer (details below).

In particular, if you wish to make a complaint about how HLG Holding Australia  has handled your personal information, you should provide a written complaint to our Privacy Officer.

HLG Holding Australia  will acknowledge receipt of your complaint within 48 hours and will investigate and respond within 10 days of receiving a complaint from you. If you are not satisfied with the decision, you can contact us to discuss your concerns. If the complaint remains unresolved, you have the option of notifying the Office of the Australian Information Commission (OAIC). Contact details can be found at the OAIC’s website: www.oaic.gov.au.

How to contact us

By letter

Privacy Officer
HLG Holding Australia Limited

GPO Box 2732

Brisbane, QLD 4000

Australia

By email

privacy@hlg.com.au

By telephone

Ph : +61 7 3209 4088

M: +61 413 883 299