1. Privacy Act

Harbour Town Centre Management (HTCM) is subject to the National Privacy Principles contained in the Privacy Act 1988 (Cth) (Act)

This Policy is intended to provide a general overview of our policies for the handling of your personal information. Your personal information is any information about you from which your identity may be reasonably ascertained. Examples of the kinds of personal information we hold are set out in clause 5.

This Policy is intended to cover most personal information handled by us, but is not exhaustive. If you have any questions about our management of your personal information, please contact us for further information by email us at privacy@harbourtown.com.auThis e-mail address is being protected from spambots. You need JavaScript enabled to view it or by phone on (08) 8355 1144.

2. How we Collect, Hold, Use and Disclose Personal Information

2.1 Collection

We will limit the personal information we collect to information that is necessary for the management of a HTCM centre and for the provision of products and services requested by you. We generally collect personal information directly from you, including from applications for membership, entry into competitions, surveys, mailing lists and registration forms and through communication with you.

We will attempt to make you aware of the purposes for the collection of your personal information and any consequences for you if you fail to provide any information that is requested by us. In some cases, where personal information is not provided, we will not be able to provide you with products or services, including but not limited to entry into promotions or competitions.

2.2 Storage

We handle all personal information carefully.  Storage of your information may be undertaken by a third party at an off-site location specifically authorised by us for that purpose, or it may be stored by us in a secure location. We ensure that your personal information is stored securely, and have implemented policies and procedures designed to ensure that your personal information is not misplaced or misused, and that unauthorised access to, modification of, or disclosure of your personal information does not occur.

Security measures we may employ from time to time include:

• password protection of information stored in computer records;
• restricted access to certain information, to ensure that only authorised individuals are able to view this information, and only for authorised purposes;
• network and computer security;
• physical document security, including locked offices, filing cabinets and archives; and
• secure destruction of the information on the database every 3-5 years to ensure that your personal information will not be stored indefinitely.

We may refuse to provide you with further information about our security procedures if doing so may compromise those procedures.

2.3 Use and Disclosure

We will generally only use or disclose your personal information for the purpose for which we collected it, with your consent and/or for related purposes we consider are within your reasonable expectations. We do not otherwise disclose your information to other organisations for any purpose, including marketing or promotional purposes without your consent. We will disclose your information to the third party storage facility for the sole purpose of secure storage of your information.

We will seek your consent prior to using or disclosing your personal information for another purpose (unless the use or disclosure in the particular circumstances is required or authorised by law).

3. Access to Personal Information

Please contact us if you wish to obtain access to your personal information using the contact details provided in this Policy. We may require that you provide us with sufficient identification before allowing you to access the personal information we hold about you to avoid a breach of your privacy. If we are required or authorised by law to do so, we may refuse to provide you with access to this information.

We may charge a reasonable fee for you to access your personal information we hold. If so, we will advise the amount of that fee once we have assessed your request for access, and may require payment prior to allowing you to access your personal information. We will not charge a fee for you to lodge a request for access.

We may provide you with access to your personal information in any of a number of ways, including by providing you with a hard copy of the information, or by allowing you to view our records. If you satisfy us that any personal information we hold about you is not accurate, complete and up-to-date, we will amend our records accordingly. Please let us know if any of your personal details change.

4. Credit checks

If you are seeking to become a tenant of a HTCM managed centre, for the purpose of processing  and assessing your application for tenancy HTCM may need to disclose certain information to a credit reporting agency in order to enable them to conduct a credit check. This information may include personal identifying details such as your name, date of birth, current and previous addresses, driver's license number and employer.

By consenting to a credit check, you authorise HTCM to obtain information about your credit worthiness, credit history or credit capacity from a credit reporting agency and to use this information for the purpose of assessing your tenancy application.

5. Information Transferred Overseas

Generally, we do not transfer personal information outside of Australia. We may do so, however, if you have given your permission for this to occur or if we are otherwise legally entitled or required to do so.

6. Online Privacy

This section of our Privacy Policy deals specifically with our "online services" including any services which are provided by us via the Internet. This may include email, our website at www.harbourtown.com.au and any other promotional websites that may operate from time to time.

6.1 Automatic Server Logs

Our web server automatically collects various items of information when you use our web site, including:

• your IP (Internet Protocol) address;
• information about the operating system and Internet browser software you are currently using; and
• the data that you download from our websites(s) and when you download it.

Although, in some circumstances, it may be possible to identify you from this information, we do not attempt to do so, and only use this information for statistical analysis, system administration, and similar purposes. This information is not disclosed to any other party.

6.2 Cookies

Our websites may use cookies to make it easier for you to load the pages on future occasions. Information stored in cookies is not used by us for the purpose of tracking your use of these web sites.

6.3 Email and Feedback Forms

We may collect personal information from you (such as your name, email address, and any other personal information you provide) if you send us email or if you submit information to us using a message or feedback form. We will use this personal information to contact you to respond to your message, and for other related purposes we consider are within your reasonable expectations or for which you have consented.

6.4 Security

If you provide any personal information to us via our online services (including email) or if we provide information to you by these means, the privacy, security and integrity of this information cannot be guaranteed during its transmission unless we have indicated otherwise.

Once we receive personal information, we will take reasonable steps to store it so that unauthorised access, modification, disclosure, misuse and loss are prevented.

6.5 Other Online Services

If any of our online services (including any email messages we send to you) provide links to other online services that are not operated by us, we are not responsible for the content of those other services and do not (unless we specify otherwise) endorse the privacy practices of the organisations that operate those other services.

7. Alterations

We reserve the right to amend this Privacy Policy at any time.

8. Complaints, Concerns or Further Information

If you believe that a breach of your privacy has occurred or have any other concerns surrounding privacy, we encourage you to contact us to discuss your concerns using the details provided. We are also able to provide further information in some instances about the ways we manage your personal information should you contact us with your request for such information.

9. Contact Information

The Privacy Officer
Harbour Town Centre Management Pty Ltd
727 Tapleys Hill Road
WEST BEACH SA 5950

08 8355 1144;

privacy@harbourtown.com.auThis e-mail address is being protected from spambots. You need JavaScript enabled to view it

This policy is with effect from 9^th December 2009.