Who We Are
What is 'Personal Information'?
Personal information means information or an opinion about an individual or an individual who is reasonably identifiable, regardless of whether the information or opinion is accurate or recorded in a material form. Personal information is 'sensitive information', including your race, political or religious beliefs, sexual preferences, criminal convictions, membership of professional or trade associations or unions or health information. We will not collect your sensitive information without first asking for your consent.
The Kinds of Personal Information We Collect and Hold
The kinds of personal information we collect and hold about you will depend on our dealings with you. In general terms, the types of information we collect include:
- Identity: your name, date of birth, and government-related identifiers required to identify you (such as your driver's licence or passport number)
- Contact details: your home address, phone number, email address
- Images: your image may be collected by CCTV footage if you visit our properties or car parks (which may contain your licence plate details)
- Financial information: income, asset and liability information, financial statements, bank account information
- Tax information: tax file number and tax-related information (whether in Australia or overseas)
- Employment applications: information related to your application if you apply for a job with us
- Professional advisors: details of your financial, accounting or legal advisors
- Service Information: any information about you concerning our products, services, promotions or marketing preferences
How We Collect Your Personal Information
The above information may be collected from various sources, depending on your dealings with us. We will generally collect your personal information directly from you, but we may also collect your personal information from:
- Our forms: we collect your personal information from applications, seminar or website forms in respect of any of our products or services
- Our properties: we collect your personal information when you visit Vertical Property premises when you provide it to us to comply with COVID-19-related requirements
- Other members of the Vertical Property Group: your personal information may be collected from other members in the Vertical Property Group for administration, maintenance, or to provide you with products or services you may be interested in
- Our services: we may collect information from your use of our services or attend any of the Vertical Property premises (such as Vertical Property Place or visitor meetings), including our membership and seminar programs
- Lease arrangements: your personal information may be collected if you are a tenant, guarantor or representative of a corporate tenant connected to a lease of a Vertical Property property (both during negotiations and during the term of the lease)
- CCTV: images may be collected through CCTV
- Service providers: we may collect personal information if you work for a company that supplies goods or services to us
- Our apps: we may collect personal information provided through our apps, including our Customer mobile app
- Third parties: When we collect your personal information from a third party (e.g. a broker, financial advisor or accountant, or our agents or service providers), we will take reasonable steps to inform you of some issues, which will include our identity and contact details.
How We Hold Your Personal Information
We may hold your personal information in electronic or hard copy (paper) form.
We retain your personal information in:
- Our computer systems and databases, and our physical files
- Secured servers or in storage located in controlled, access-restricted environments
- Vertical Property's security holder and unit holder registers are maintained internally or by our external service providers for personal information collected regarding investments. This information is used to carry out registry functions, including facilitating distribution payments and corporate communications such as financial results and annual and half-yearly reports. We require external service providers to comply with the requirements of the Privacy Act and the APPs in handling the personal information of our investors.
- In certain circumstances, personal information may be held on behalf of us in hard copy or electronic forms by our service providers (such as offsite document storage providers or electronic data storage providers)
Notification of Collection of Personal Information
Why We Collect Personal Information
The purposes for which we collect, use and disclose your personal information depend on your dealings with us. These purposes may differ for tenants, investors, visitors, contractors, customer service providers and job applicants:
- Products and services: to assess, maintain, administer and provide you with the products or services you have applied for
- Memberships: to provide you with access to our memberships, including discounts, rewards and members services through the program
- Our lease arrangements: Vertical Property uses personal information for purposes including evaluating whether to grant leases and enter into agreements with prospective tenants, documenting these leases and contracts, performing its obligations under leases and agreements with tenants, managing relationships with tenants and monitoring properties
- Investments: to process, establish and administer your investment in a fund
- Comply with the law: comply with the laws that apply to the product or service you have with us, including anti-money laundering and counter-terrorism financing laws, taxation laws and the Foreign Account Tax Compliance Act (FATCA) or Common Reporting Standards (CRS) and respond to any regulator or legal enforcement investigations or enquiries.
- Customer service: to provide, administer, improve and personalise our services, process payments, identify you, communicate with you concerning our services and respond to your enquiries
- Vendor relationships: to manage the supply of goods and services with our suppliers
- Employment applications: collected from unsuccessful job applicants or their agents may be retained if a more appropriate opportunity becomes available. The unsuccessful applicant will be advised that they can contact Vertical Property to request Vertical Property not have the applicant's information.
- Safety and security: to maintain the safety and security of Property and individuals working at or visiting our properties. This includes COVID-19 contact tracing as required by the relevant state legislation.
- App services: to provide you with the services in our Tenant mobile app, which allows access to local and building information and services
- Marketing and analytics: to send you direct marketing communications and information about our services, primarily by email. We may also use your personal information to analyse program usage, improve our product, service and membership content and product offers, and conduct advertising and promotions. You can opt out of receiving direct marketing communications from us.
Who We May Disclose Your Personal Information To
For the purposes stated above, we may disclose your personal information to:
- Financial institutions for payment processing
- Our contractors and any third-party service providers who assist us in the operation of the business and the provision of our services, including those that provide customer, registry, administration, external dispute resolution services, archival, marketing, advertising, electronic mailing houses, and information technology services
- Our professional advisers (including legal, accounting firms, auditors and other advisors) on a confidential basis
- Advisers and dealer groups
- Other entities within the Vertical Property Group
- We may provide images of individuals collected by CCTV to tenants, law enforcement bodies and insurers to ensure the security of our properties and investigate unlawful conduct.
- We may also disclose personal information related to COVID-19 contact tracing on request to government bodies.
Depending on the type of service or product we provide to you, your personal information may be disclosed to our contractors and unaffiliated service providers located in other overseas jurisdictions such as the United States, Europe and the Asia Pacific region.
We will take reasonable steps to protect your personal information from misuse, interference and loss, unauthorised access, modification or disclosure. We use 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 as long as necessary to collect it. We will also take reasonable steps to destroy or permanently de-identify personal information if it is no longer needed for the purposes stated under
Personal information is stored on secured servers or in controlled, access-restricted environments. Our employees (including senior management) know their obligations and the importance of good information handling and security obligations. They are required to maintain the confidentiality of any personal information held by us.
For personal information held on behalf of us in hard copy or electronic form by our service providers (such as offsite document storage providers or electronic data storage providers), we enter into agreements with such service providers which impose confidentiality and privacy obligations on the service provider.
Data Breach Notification
We will report certain data breaches (known as Notifiable Data Breaches) to you if you are affected by the breach and to the OAIC.
A notifiable data breach may occur where our personal information is lost or subjected to unauthorised access or disclosure.
To be a notifiable data breach, the data breach must, depending on the circumstances, be one that may or is likely to result in serious harm to you.
We have procedures to ensure that any identified or suspected data breaches are dealt with promptly, appropriately and escalated accordingly.
When you visit our website, we and our contractors may collect information about you which may include personal information (which will be or is de-identified) such as:
- The date and time you visited our website
- The pages you viewed and how long you viewed those pages
- General location information
- Information about the type of device you used to visit our website
- The IP address automatically assigned by your Internet Service Provider to the device you used to visit our website
We use this information (i) to personalise the content of the website for you (e.g. make it easier to log in, maintain a shopping basket for your orders and access information about your account) and (ii) for system administration preparation of statistics on the use of our website and to improve our website's content. This information may also be used for targeted advertising based on your online behavioural profile.
We access to aggregate, non-personalised statistics on our coverage in social media.
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 it contains inaccurate information, or you can ask us to remove it from our records.
We 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 make the requested changes.
We will seek to respond to requests for access to or correction of personal information within 30 days of the date of the request.
If we refuse any request for access to or correction of personal information we hold, we will provide you with written reasons for that refusal.
If you wish to obtain access or to request changes to your personal information, you can contact our Privacy Officer at *protected email* or call us at 92790111.
Vertical Property may recover reasonable costs associated with providing you with access to your personal information.
Complaints and Questions
Suppose you have questions about how we handle your personal information or a complaint about Vertical Property's information handling practices; in that case, you can contact the Privacy Officer at *protected email* or 92790111.
In particular, if you wish to complain about how we have handled your personal information, you should provide a written complaint to our Privacy Officer.
We will acknowledge receipt of your complaint within 48 hours and investigate and respond within 30 days of receiving your complaint. If you are unsatisfied with the decision, you can contact us to discuss your concerns. If the complaint remains unresolved, you have the option of notifying the Australian Financial Complaints Authority.
You can also contact the Office of the Australian Information Commissioner if your complaint is about your privacy.
This policy will be reviewed annually (or more regularly if there are changes to the legal or regulatory framework which applies to this policy) to ensure it is renewed and updated appropriately. We will notify any changes by posting an updated version of the policy.