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Last updated: 28 May 2020

We are subject to the operation of the Privacy Act 1988 (Cth) (Privacy Act) and the Health Records Act 2001 (Vic) (Health Records Act). This policy explains how we handle personal information relating to individuals, whether or not they are tenants, so as to ensure we meet our obligations under these Acts. This policy relates to all of our activities, including operation of the premises and the ONE end-of-trip facilities, our activities related to the RISE by Studio PP wellness centre and the operation of our websites, including the wellness portal and our concierge portal.

Terminology

In this policy: 

"health information" is used in this policy in the same way as that term is defined in the Health Records Act.

"personal information" is used in this policy to refer to information or an opinion about an identified individual, or an individual who is reasonably identifiable:

whether the information or opinion is true or not; and
whether the information or opinion is recorded in a material form or not.

"sensitive information" is used in this policy in the same way as that term is defined in the Privacy Act.

"premises" refers to the building at 101 Collins Street. Melbourne, Victoria 3000, maintained by us, including the basement and carpark areas.

"RISE by Studio PP" means Premium Performance Pty Ltd as the Trustee for Premium Performance Trust, a subcontractor of ours that operates the premium fitness, health and wellbeing services in the wellbeing centre contained in the premises and via the wellness portal. 

"we", "us" and "our" are a reference to 101 Collins Street Pty Ltd.

"websites" refers to the websites operated by us from time to time at www.101collins.com.au, rise.101collins.com.au, concierge.101collins.com.au and any other portals or subdomains (or a replacement URL).

"wellness centre" refers to the 'RISE by Studio PP' wellness centre which is operated by us and our contractors at the premises.  

"wellness portal" refers to the 'RISE by Studio PP' wellness portal website which is operated by us and our contractors at rise.101collins.com.au (or a replacement URL).  

"you" and "your" refer to each and every individual whose personal information we may handle from time to time.  

Any reference to us assuming an obligation under the Privacy Act, the Health Records Act, or other privacy legislation can be interpreted as a reference to us also procuring our subcontractors to undertake a reciprocal obligation to the extent relevant.

Types of information collected

We only collect personal information to the extent that this is reasonably necessary for one or more of our functions or activities.  

This includes but is not limited to the following kinds of information:

(a) your name;
(b) the name of your employer;
(c) your job title;
(d) your age, gender, and date of birth;
(e) your home address and email address;
(f) your home, work and/or mobile telephone number; 
(g) where applicable, images and video footage of you, including images and video footage collected by security cameras (for security and law enforcement purposes only); and
(f) where applicable, health information, to the extent such information is collected in connection with your use of our wellness centre and related facilities.

Method of Collection

Our preference is to collect personal information about an individual direct from that individual unless it is unreasonable or impracticable for us to do so.

Information will generally be collected from the following sources:

(a) your employer; and
(b) any information you have provided us, whether online, over the telephone or in paper form; 
(c) your use of our website or digital services; 
(d) to the extent applicable and permitted by law, via images and video collected by security cameras (for security and law enforcement purposes only;
(e) where applicable, health service providers whose services you engage in connection with the wellness portal and related facilities provided by us or our contractors; and
(f) information you provide through your use of our websites, including the wellness portal and related facilities.

Purposes of collection, use and disclosure

We may use and disclose your personal information for the primary purpose for which we collected your personal information, for reasonably (or directly if the personal information is sensitive information, including health information) related secondary purposes within your reasonable expectations and where we are required or authorised by law. These purposes include, but are not limited to:

(a) communicating with you regarding the 101 Collins premises and any services we provide, or may provide, to you or to tenants of the premises generally;
(b) dealings with your employer; 
(c) verifying your identity;
(d) improving our products or services or businesses;
(e) addressing any issues or complaints that we or you have regarding our relationship;
(f) sending to you news and information about our activities, events and general promotional material which we believe may be useful to you, by email, post or other medium;
(g) where you are an employment candidate, assessing your suitability for employment;
(h) facilitating operational and administrative requirements in relation to our business and the facilities;
(i) for the wellness portal and wellness centre, facilitating use of the health services we (or our contractors) offer;
(j) where applicable, allowing you full access to our wellness portal, wellness centre, end of trip facilities and related facilities; and
(k) transferring that information to a new or replacement provider in the event of an assignment, sale, merger or similar transaction of our business or any of our assets.

We may also collect personal information for purposes related or ancillary to the primary purpose of collection, including promoting such services and market research. 

We may disclose personal information to the following third parties, where permitted under the Privacy Act and Health Records Act (as applicable) or to fulfil any of the purposes set out in this privacy policy or a related or ancillary purpose:

(a) where applicable, our health and wellness contractor Premium Performance Pty Ltd (which operates the 'RISE by Studio PP' wellness centre and the wellness portal); 
(b) other third party contractors, including our public relations service provider and technology platforms, to the extent necessary to fulfil the relevant purpose; and 
(c) our related bodies corporate and other businesses operated by us that relate to the premises, including the ONE end of trip facility and the RISE by Studio PP wellness centre.

We may also disclose personal information to third parties where otherwise required or permitted under the Privacy Act, the Health Records Act, or other applicable law, including where:

(a) we believe that the use or disclosure is reasonably necessary to assist a law enforcement body or an agency responsible for government or public security in the performance of their functions; or 
(b) we are required or authorised by law to disclose the information.

If you do not provide us with personal information or health information as requested, we may not be able to provide the services that you have requested or resolve your queries.

Direct marketing

We do not use sensitive information (including health information) for marketing purposes.  

We may use and disclose your personal information (other than sensitive information) to provide you with information on offers, products and services offered by us, or that we think you may be interested in, from time to time. 

If at any time you no longer wish to receive any direct marketing from us or do not want your information disclosed for direct marketing, contact us using the contact details below. Please note that even if you have requested not to receive further direct marketing communications, we may nevertheless continue to provide you with information about changes to our terms and conditions for the supply of goods or services and other factual information as permitted under the Privacy Act and Spam Act 2003 (Cth).

Storage of data and disclosure overseas and interstate

Typically, we will store personal information in electronic databases and systems. We do not generally send your personal information outside of Victoria. 
However, personal information may be sent offshore or interstate, including to related bodies corporate or our service providers (for example marketing agencies) where third parties with whom we may share it (including those described in this policy) are located outside of Victoria or the Commonwealth of Australia. In addition, it is possible that we or our subcontractors will utilise cloud technology in connection with providing services, which may result in offshore or interstate storage. It is not practicable for us to specify in advance the location of every service provider with whom we deal, however we will ensure that the disclosure of such information occurs in accordance with our obligations under applicable law.

Employee records 

In accordance with the Privacy Act, this policy does not apply to our acts and practices directly related to a current or former employment relationship between us and an employee, and an employee record held by us relating to the employee.

Data security

We will take such steps as are reasonable in the circumstances to protect the personal information we hold from misuse or loss and from unauthorised access, modification or disclosure. We will also take steps as are reasonable in the circumstances to destroy or de-identify personal information once we no longer need it for any purpose for which the information may be used, disclosed or retained under the 

Privacy Act. 

However, when using our website you should be aware that no data transmission over the Internet can be guaranteed as totally secure. Although we strive to protect such information, we do not warrant the security of any information that you provide us over the Internet and you do so at your own risk.

Surveillance activities

In limited respects, we operate surveillance cameras on the premises for various purposes consistent with this privacy policy, including monitoring people movement and general operational purposes, as well as the purposes of minimising and detecting unlawful activity, preventing disturbances and assisting law enforcement and our security contractors in carrying out their responsibilities. The surveillance recordings, including personal information held on those recordings, may be provided:

(a) to law enforcement bodies or an agency responsible for government or public security, to the extent that is required or authorised by applicable law; and 
(b) to security contractors, to the extent that we are required by applicable law or consider it reasonably necessary for purposes set out in this privacy policy.

Openness

From time to time, we may change our policy on how we handle personal information or the types of personal information which we hold. Any changes to our policy will be published on our website. You may obtain a copy of our current policy from our website or by contacting us on the details below. It is your responsibility to check the website from time to time in order to determine whether there have been any changes.  

Access, correction and further information

We will take such steps as are reasonable in the circumstances to ensure that the personal information which we collect remains accurate, up to date and complete. 

We will provide you with access to your personal information held by us unless we are permitted under the Privacy Act or the Health Records Act to refuse to provide you with such access. Please contact us via the details below if you:

(a) wish to have access to the personal information which we hold about you;
(b) consider that the personal information which we hold about you is not accurate, complete or up to date; or
(c) require further information on our personal information handling practices.

Contact Details: 101 Collins Street Pty. Limited, 101 Collins Street MELBOURNE VIC 3000, (03) 9650 5311 or by visiting the 101 Collins management office at the rear of 101 Collins Street, via the 101 Collins East walkway.

There is no charge for requesting access to your personal information but we may require you to meet our reasonable costs in actually providing you with access.
 
If you consider that the information which we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, we will take reasonable steps, consistent with our obligations under the Privacy Act and the Health Records Act, to correct that information if you so request.  

We will respond to all requests for access and/or correction within a reasonable time.

Changes to our privacy policy

From time to time, we may change or update parts of this privacy policy in order to maintain our compliance with applicable law and regulation or following an update to our internal practices. We will do this by updating this privacy policy on our website at https://101collins.com.au/. You may obtain a copy of our current policy from our website or by contacting us via the details above. 

You may not be directly notified of such a change so please ensure that you regularly check this privacy policy so you are fully aware of any changes or updates.

Complaints

If you have a complaint about the way in which we have handled any privacy issue, including your request for access or correction of your personal information, you should advise us via the above contact details.

If you are not satisfied with how we manage your complaint, you may contact the Office of the Australian Information Commissioner or (for health information) the Health Complaints Commissioner.

Privacy Policy – 101 Collins Street Pty Ltd