INFORMATION » Privacy Policy
Privacy Policy

Karingal Hub Privacy Policy


The personal information you provide to us will be retained only for as long as necessary to fulfil the purposes for which the information was collected or as required by law. We do not share personal information with third parties except as necessary to carry out our business or your request or as required by law or other legal processes. Karingal Hub will never sell your personal information. Karingal Hub complies with the National Privacy Act.


Karingal Hub recognises its responsibility for protecting the online privacy of your personal information. If you have any questions or comments about our administration of your personal information, or would like to opt out of receiving any marketing material from us, please contact us on marketing@karingalhub.com.au. You may also use this address to communicate any concerns you may have regarding compliance with this privacy policy.


This privacy policy sets out the approach which Karingal Hub will take in relation to the treatment of personal information. It includes information on how Karingal Hub collects, uses, discloses and keeps secure, individuals’ personal information. This policy has been drafted having regard to Karingal Hub’s obligations under the Privacy Act 1988 (including the new National Privacy Principles) (the Privacy Act). This policy is a public document and has been prepared in light of National Privacy Principle 5, Openness.


1.    COLLECTION

1.1. Karingal Hub will only collect personal information where the information is necessary for Karingal Hub to perform one or more of its functions or activities. In this context, “collect” means gather, acquire or obtain by any means, information in circumstances where the individual is identifiable or identified.


1.2. Karingal Hub collects personal information primarily to supply customers with the information and services from it and its related companies. Karingal Hub also collects and uses personal information for secondary purposes including to provide individuals with information about promotions, as well as the products and services of Karingal Hub affiliated companies and other organisations.


1.3. Karingal Hub will not collect sensitive information from individuals except with consent and only where it is necessary for Karingal Hub to collect such information for an activity or function.


1.4. Karingal Hub will not collect personal information secretly or in an underhanded way.

2.    USE

2.1. Karingal Hub will obtain an individual’s consent for use of non-sensitive personal information for secondary purposes at the time of collection, unless the use is a related secondary purpose which would be within the relevant individual’s reasonable expectations.

2.2. Karingal Hub uses personal information primarily for the purposes listed in 1.2 above.

2.3. If Karingal Hub relies on the direct marketing exception to direct market to individuals it will ensure that the individual is clearly notified of their right to opt out from further direct marketing, there is only one use of the information before the opt out right is given and this use applies across all Karingal Hub related entities, if the information is shared between those related entities. The individual is also given an opt out in all further instances of direct marketing if they have not previously chosen to opt out and if the individual opts out of all direct marketing the opt out will be respected by Karingal Hub and all its related entities.

2.4. Karingal Hub will not use sensitive information for direct marketing.

2.5. Karingal Hub may use personal information to avoid an imminent threat to a person’s life or to public safety. It may also use personal information for reasons related to law enforcement or internal investigations into unlawful activities.

2.6. Karingal Hub will not use personal information without taking reasonable steps to ensure that the information is accurate, complete and up to date.

3.    DISCLOSURE

3.1. Karingal Hub may disclose personal information to related or unrelated third parties if consent has been obtained from the individual.

3.2. Karingal Hub may disclose personal information between related entities. Where information is disclosed to such a related entity that related entity is bound by the original primary purpose for which the information was collected.

3.3. Karingal Hub may disclose personal information to unrelated third parties to enable outsourcing of functions (such customer relations management), where there is disclosure or use for a related secondary purpose and has been notified to individuals or where such disclosure is within the individual’s reasonable expectations.

3.4. Karingal Hub will take reasonable steps to ensure that its contracts with third parties include requirements for third parties to comply with the use and disclosure requirements of the Privacy Act.

3.5. Karingal Hub may disclose personal information to law enforcement agencies, government agencies, courts or external advisers where permitted or required by law.

3.6. If a disclosure is not for a primary purpose; is not for a related secondary purpose; or upfront consent has not been obtained. Karingal Hub will not disclose personal information otherwise than in accordance with the exceptions set out at 3.1 to 3.5 above.

3.7. Karingal Hub does not generally sell or share its customer lists on a commercial basis with third parties but if it did, it would only do so if we had the appropriate consent of the individual involved. If the consent provided is conditional, Karingal Hub will take steps to ensure (by contract) that the use of its customer list by third parties does not exceed the scope of the consent.

4.    INFORMATION QUALITY

4.1. Karingal Hub will review, on a regular and ongoing basis, its collection and storage practices to ascertain how improvements to accuracy can be achieved.

4.2. Karingal Hub will take steps to destroy or de-identify personal information after as short a time as possible and after a maximum of seven years from the date of the last customer interaction, unless the law requires otherwise.

5.    INFORMATION SECURITY

5.1. Karingal Hub and related entities requires employees and contractors to perform their duties in a manner that is consistent with Karingal Hub legal responsibilities in relation to privacy.

5.2. Karingal Hub will take all reasonable steps to ensure that paper and electronic records containing personal information are stored in facilities that are only accessible by people within Karingal Hub who have a genuine “need to know” as well as “right to know”.

5.3. Karingal Hub will review, on a regular and ongoing basis, its information security practices to ascertain how ongoing responsibilities can be achieved and maintained.

6.    ACCESS AND CORRECTION

6.1. Karingal Hub will allow its records containing personal information to be accessed by the individual concerned in accordance with the Privacy Act.

6.2. Karingal Hub will correct its records containing personal information as soon as practically possible, at the request of the individual concerned in accordance with the Privacy Act.

6.3. Individuals wishing to lodge a request to access and / or correct their personal information should do so by contacting Karingal Hub Centre Management, as per the details on the Karingal Hub website.

6.4. Karingal Hub can charge a fee for processing an access request but will generally not do so unless the request is complex or is resource intensive.

7.    OPENNESS

7.1. Karingal Hub Centre Management will be the first point of contact for inquiries about privacy issues. Individuals wishing to make an inquiry or complaint regarding privacy should do so by contacting Karingal Hub Centre Management, as per the details on the Karingal Hub website.

7.2. Karingal Hub websites will contain a prominently displayed privacy statement and will include a copy of this Karingal Hub privacy policy.

8.    ANONYMOUS TRANSACTIONS

8.1. Karingal Hub will not make it mandatory for visitors to its website to provide personal information unless such personal information is required to answer an inquiry or provide a service. Karingal Hub may however request visitors to provide personal information voluntarily to Karingal Hub (for example, as part of a competition or questionnaire).

9.    TRANSFERRING PERSONAL INFORMATION OVERSEAS

9.1. Karingal Hub will take reasonable steps to limit the amount of personal information it sends to unrelated organisations overseas.

9.2. If personal information must be sent by Karingal Hub overseas for sound business reasons, Karingal Hub will require the overseas organisation receiving the information to provide a binding undertaking that it will handle that information in accordance with the National Privacy Principles, preferably as part of the services contract.

10. GLOSSARY

  1. Collection information means the information outlined in 1.2 notified to individuals prior to, or as soon as practical after, the collection of their personal information.
  2. Direct marketing means the marketing of goods or services through means of communication including written, verbal or electronic means. The goods or services which are marketed may be those of Karingal Hub or a related body corporate or those of an independent third party organisation.
  3. Disclosure generally means the release of information outside Karingal Hub, including under a contract to carry out an “outsourced function”.
  4. Opt out means an individual’s expressed request not to receive further direct marketing.
  5. Karingal Hub means ISPT Karingal Shopping Centre Trust, ABN 14 113 009 273, located at 330 Cranbourne Road, Frankston VIC 3199.
  6. Personal information means information or an opinion (including information or an opinion forming part of a database), whether true or not and whether recorded in a material form or not, about an individual whose identity is apparent, or can reasonably be ascertained from the information or opinion.
  7. Primary purpose is the dominant or fundamental reason for information being collected in a particular transaction.
  8. Reasonable expectation means a reasonable individual’s expectation that their personal information might be used or disclosed for the particular purpose.
  9. Related Entities means Karingal Hub, all associated companies, advisors and agencies and all those entities’ personnel.
  10. Sensitive information 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 preferences or practices, criminal record; that is also personal information or health information about an individual.
  11. Use means the handling of personal information within Karingal Hub.

 

Centre Management 330 Cranbourne Road Karingal, VIC 3199 | (03) 9789 1192