Privacy Policy

Personal information is information or an opinion, whether true or not, and whether recorded in a material form or not, about an identified or reasonably identifiable individual.

The amount and type of personal information we collect from and hold about you will vary depending on whether you are an existing customer, have made enquiries about our services, and the extent to which you have used our services.

The type of personal information which we hold about you may include:

• Your name, address, telephone and email contact details, age or birth date;
• gender;
• profession, occupation or job title and/or employer details, social media profiles;
• any additional information relating to you that is provided to us directly through Investa Websites or indirectly using third party intermediaries, including marketing contractors, third party websites, portals and registries;
• any information needed to satisfy our obligations under relevant legislation; and
• any other information you provide to us through our customer surveys, web forms or visits to us or by our representatives from time to time.

Consequences if information not provided

If you do not provide us with the requested personal information, or provide information that is incomplete or inaccurate, it may prevent or limit:

• Our ability to provide Investa Services to you;
• Your ability to use some functions of the Investa Websites and or benefit fully from the Investa Services;
• Our ability to provide you with the level of service which you would normally expect from us; or
• Us from being able to contact you.

Sensitive information

Sensitive information is a subset of personal information that has the same meaning that it has under the Privacy Act. We do not generally collect sensitive information about you. In certain limited circumstances, if we do collect sensitive information about you, we will only do so where you have provided that sensitive information or with your consent, or otherwise in accordance with the law.

When Investa collects information

We may collect your personal information when you:

• register with us, creating a user account and insert personal information to log into and become a member of an Investa Website;
• communicate with us and our staff;
• access and use the Investa Websites and Investa Services;
• respond to any surveys or marketing materials we send out; and
• deal with us in other ways involving your personal information such as when you contact us or when we otherwise provide you with the Investa Services.

We may also collect your personal information from third parties including:

• other third parties who provide you services via the Investa Websites or in connection with the Investa Services;
• through applications provided by third parties and which are available from or referenced by Investa Websites or Investa Services; and
• third parties who supply services to Investa.

We try to collect personal information directly from you or through your authorised intermediaries.

Children and young people

The Investa Websites and the Investa Services are not intended for use by children and should only be accessed by individuals of at least 18 years old (the “Age Limit”). If you are under the Age Limit, please do not use the Investa Websites or the Investa Services and do not supply us your personal information.

Personal information which is collected by Investa is used and disclosed for the main purpose for which the information was collected or for related purposes. This may include the following purposes:

• to provide products and services to you and to send communications requested by you;
• to answer enquiries and provide information or advice about existing and new products or services;
• to conduct business processing functions including providing personal information to our related bodies corporate, contractors, service providers or other third parties;
• for the administrative, marketing (including direct marketing), planning, product or service development, quality control and research purposes of Investa, its related bodies corporate, contractors or service providers;
• to provide your updated personal information to our related bodies corporate, contractors or service providers;
• to update our records and keep your contact details up to date; and
• to process and respond to any complaint made by you.

We may otherwise use or disclose your personal information where the use or disclosure is required or authorised by law (for example, disclosure to government regulatory and law enforcement agencies) or in emergency situations.

If Investa wishes to use or disclose your personal information in other circumstances, we will seek your consent to do so.

We may share an individual’s personal information with our related entities. In this case, the information may only be used or disclosed by the related entity for the main purpose for which it was collected, for purposes related to the main purpose, where needed or authorised by law, or for other purposes if the individual has consented.

Investa does not sell personal information to companies outside the Investa Group.

We may disclose your personal information to our:

• contractors and service providers that assist us in the operation of our business or the provision of services (for example, our internet service providers, cloud computing service providers, applications partners, mailing houses, marketing contractors and providers of any website, portal or share registry); and
• our lawyers, accountants and other professional advisors.

Investa endeavours to ensure that these organisations agree to comply with this Privacy Policy or are otherwise subject to reasonable obligations to protect your personal information.

Our related and associated entities and third-party service providers may be in countries outside of Australia, and which may include the United States, the United Kingdom and India. Our contracts with these parties include an obligation for them to comply with Australian privacy law and our Privacy Policy.

Marketing

We may send you direct marketing communications and information about our products and services that we consider may be of interest to you. These communications may be sent in various forms, including email, mail, SMS and fax, in accordance with applicable marketing laws.

The Spam Act 2003 (Cth) restricts the circumstances in which Investa can send you commercial electronic messages (including email and SMS text messages). Investa may send other advertising material to you where the advertising material is related to the purpose for which the personal information was collected. You consent to us sending you those direct marketing communications by any of the above methods. If you indicate a preference for a particular method of communication, we will endeavour to use that method wherever practical to do so. If you no longer wish to receive such promotional information from Investa, you may advise us in writing. Commercial electronic messages from Investa will include information about how to contact us and unsubscribe if required. Investa’s records would normally be amended within 30 days or as otherwise required by the Spam Act. Details of how to contact us are set out below.

We take reasonable steps to protect all the personal information we hold from misuse, loss, unauthorised access, modification or disclosure. This protection applies in relation to information stored in both electronic and hard copy form.

Investa will destroy or permanently de-identify any personal information collected which is no longer needed.

External organisations which supply support services to Investa are also required to appropriately safeguard the security of the personal information which we provide to them.

Data protection measures are never completely secure and, despite the measures we have put in place, we cannot guarantee the security of your personal information. You must take care to protect your personal information (for example, by protecting your usernames and passwords). You should let us know as soon as possible if you become aware of any security breaches.

You may request access to your personal information or request us to correct information which we hold about you. To make a request, please put your request in writing using the contact details below. We may need proof of your identification before we can provide you with access to your personal information.

In normal circumstances we will give you full access to the personal information which we hold about you. However, in some circumstances, we may not be required by law to provide an individual with access to or to correct their personal information. If this is the case, you will be provided with the reason(s) for our decision.

We will normally supply access without charge unless you request access to a large volume of personal information or we must access our archived records to obtain the information. In these circumstances, we may impose a fee to recover our reasonable costs.

This section outlines the way we handle personal information which we collect when an individual uses the Investa Websites.

We outsource the development, maintenance and hosting of the Investa Websites to third party service providers. We may disclose personal information about an individual to our third-party service providers so that they can effectively supply these services.

 Collection of personal information

An individual may visit the Investa Websites without providing us with any personal information. We may collect personal information about an individual accessing the Investa Websites if they use the ‘Contact us’ section of the Investa Websites, or if they create an account through the Investa careers or tenants’ portals.

Use of cookies and web tracking

A cookie is a small data file that contains information about your visit to a website. This information is provided by your computer during your first visit to a web server.

The server records this information in a text file and stores this file on your hard drive. When you visit the same website again, the server looks for the cookie and structures itself based on the information provided.

The types of cookies Investa use include:

• Essential cookies (these are required for the Investa Websites in relation to security, accessibility and functionality);
• Performance and functional cookies (we use these to improve the user experience on the Investa Websites);
• Advertising and marketing cookies (we use these to improve how we communicate with you, including being able to show you ads that are relevant to the way you interact with the Investa Websites); and
• Social media cookies (these are third-party cookies used by third-party companies which supply a service to Investa, such as including or excluding you from social media advertising).

Most browsers are initially set up to accept cookies. You can reset your browser to refuse all cookies or to warn you before accepting cookies. If you have set your browser to warn you before accepting cookies, you will receive the warning message with each cookie. Alternatively, you may wish to visit www.aboutcookies.org, which contains comprehensive information on how to manage cookies on a wide variety of desktop browsers.

Investa does not use cookies or web bugs to keep personal profiles of its customers’ use of the Investa Website.

Links

We may, from time to time, include links in the Investa Websites to the websites of other organisations which may be of interest to you. These websites operate independently from the Investa Websites and we make no representations or warranties in relation to the privacy practices of any third-party website and we are not responsible for the privacy policies or the content of any third-party website. Third party websites are responsible for informing you about their own privacy practices and use of personal information. If you decide to access or interact with any of the third-party sites listed on the Investa Websites, you do so at your own risk.

Website security

We take reasonable steps to protect all the personal information in our possession that we have collected via the Investa Websites in accordance with our general personal information management practices to reduce the risk of misuse and loss and from unauthorised access, modification or disclosure.

Email

If an individual emails us, the email may hold personal information about that individual. We will treat the information following our general personal information management practices outlined in this Privacy Policy.

If you wish to make a privacy complaint, you may contact the Privacy Officer using the contact details above. You will need to provide us with sufficient details of your complaint, as well as any supporting evidence and/or information.

The Privacy Officer will investigate the issue and decide the steps we will undertake to resolve your complaint. We will contact you if we need any other information and will notify you in writing of the outcome. We will aim to ensure that your complaint is resolved in a prompt and appropriate manner.

If you feel that we have not adequately dealt with your complaint, you may contact the Australian Privacy Commissioner via www.oaic.gov.au.

We regularly review our practices and procedures about how we collect, hold, use, disclose and otherwise manage personal information. It replaces any other Privacy Policy published by us to date, in any form. Your continued use of the Investa websites or the Investa Services, indicates your acceptance of any revised Privacy Policy, as it may change from time to time.

Latest update: September 2023