Privacy Policy

The Cohen Group, including RSC Nominees Pty Ltd ACN 007 770 792 as trustee for the R S Cohen Family Trust and its related entities, (‘we’, ‘our’, ‘us’) is committed to protecting the personal information that we collect and hold about you. This Privacy Policy (Policy) sets out how we collect, use, hold, and share your personal information with reference to the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth) (Privacy Act). This Policy also sets out how to contact us with any queries or concerns.

By voluntarily supplying us with your personal information, you are agreeing to be bound by this Policy. While we may update our Policy from time to time, the most recent version of this Policy will always be available on this website. If we change the Policy in any material way, we will post a notice on our website along with the updated Policy. We may also contact you via your contact information on file, for example by email, notification, or some other equivalent measure.

If you have any queries, concerns, or complaints about how we handle your personal information, please contact our Privacy Officer in the first instance:

Privacy Officer Contact: Ingrid Burgers
Email: Ingrid.burgers@cohengroup.com.au
Email: general@cohengroup.com.au

Postal address
Attention: Privacy Officer
Burnside Village Centre Management
PO Box 145, Glenside SA 5065

Our website contains links to other websites. When a user clicks on a link to another site, they are no longer subject to this Policy. We have no responsibility for linked websites and provide them solely for your information and convenience. We specifically disclaim responsibility for their content, privacy practices, and terms of use, and we make no endorsements, representations, or warranties about their accuracy, content, or thoroughness. Your disclosure of personal information to third party websites is at your own risk.

1. What types of information do we collect and why?

In the course of managing and leasing our retail, commercial, and industrial properties and otherwise providing our services, we collect personal and other information about our tenants, suppliers, and other individuals and how they interact with us and our services. We collect personal information through a number of mechanisms, including:

1.1 Collection from you

We collect and store information you provide directly to us (either in person, by email, by phone, or by any other direct means) in order to deliver our services. This includes:

  • Contact information: such as your name, address, email address, telephone number

  • Personal information: such as date of birth and driver’s licence details

  • Financial and credit information: such as bank account details

  • Business details: such as your Australian Business Number

1.2 Automatic

We use cookies (small text files stored on your devices that provide us with information such as your internet protocol (IP) address, server information, internet service provider, and information on how you interact with our website) and other services that allow us to understand how you use our online media. This information is not linked to you personally. Each cookie expires within 30 minutes of website inactivity by a user.

We use remarketing and other audience features which track and measure user interaction on our website and provide data to help improve services. If you would like to know more or opt out of third-party vendors’ use of cookies, please visit:
http://www.networkadvertising.org/choices/

If you opt out of third-party tracking technologies or elect to prevent the use of cookies, this may result in the loss of website functionality, restrict your use of the website, or delay/affect the way in which the website operates.

1.3 Device

If you use our services or interact with us through a mobile device, we receive technical information about your device, numbers that identify the device, and your location information. This information is not associated with you.

1.4 Communications

When you communicate with us, we collect information such as your contact details (such as email address or phone number). We also engage third-party services that provide us with information about how you interact with some communications we distribute.

You can elect not to receive communications from us by contacting our Privacy Officer.

1.5 Digital platforms

If you access our services by connecting a social media login (such as Facebook or Google), we collect information derived, associated, or connected with that platform where permitted by the platform’s terms of service. Any information we collect from social media, or other online platforms, is collected in accordance with that platform’s terms and conditions.

1.6 Through other sources

Where necessary, we also collect your information from publicly available records. We will only do this where it is unreasonable or impractical to collect this information from you and it is necessary to provide our services.

If you have previously applied for a position with us, we may have received your personal information from third parties such as recruiters or external websites. We use the information we receive to contact you about any potential opportunities or to evaluate your candidacy.

1.7 Information you provide about someone else

If you provide us with personal information about someone else, you must ensure that you are authorised to disclose that information to us and that, without us taking any further steps required by applicable privacy laws, we may collect, store, use, and disclose such information for the purposes described in this Policy.

Where we request you to do so, you must assist us with any requests by the individual to access or update the personal information you have collected from them and provided to us. If you are someone who does not have a relationship with us but believe that one of our customers has entered your personal information into our servers, you will need to contact that customer for any questions you have about your personal information (including where you want to access, correct, amend, or request that we delete your personal information).

1.8 Sensitive Information

We collect information considered to be sensitive information in the Privacy Act. We will only collect this information directly from you or where we have consent to collect the information from a third party.

You have the option of not identifying yourself or interacting with us using a pseudonym. However, this may not be practicable when engaging our services. You can choose not to provide your personal information, but it may mean that we are unable to provide you with our services.

2. How do we use your information?

We will only use your information for the purposes for which it was collected (primary purpose) or a purpose related to that primary purpose if it would be reasonably expected by you or where we have separately obtained your consent.

We use personal information for the primary purpose of managing and leasing our retail, commercial, and industrial properties and providing ancillary services, information, and related offerings.

How we use the information we collect depends, in part, on which services you use, how you use them, and any preferences you have communicated to us. If you would like to restrict how your personal information is handled beyond what is outlined in this Policy, please contact our Privacy Officer.

2.1 Internal Group Transfers

The Cohen Group comprises a large group of companies and as such we may provide your information to other entities within the Cohen Group. Within Australia, this transfer of information is compliant with s 13B of the Privacy Act. Transfers are subject to the security information obtained in paragraph 3 below.

2.2 Disclosure of personal information to third parties

We may disclose your information to third parties who assist us in providing, managing, and administering our services. We will also disclose your personal information where such disclosure is required by law.

We may disclose your personal information to third parties that:

  • Manage and enhance our customer database

  • Manage and assist with our compliance and safety procedures for contractors or other third parties on our premises, including Rapid Global

  • Process information for payment verification and security purposes, including Eftsure

  • Provide free and secure Wi-Fi on our premises, including Purple

  • Assess your interest in our services, including Purple, Eftsure, and Rapid Global

  • Conduct customer research or satisfaction surveys, including Purple, Eftsure, and Rapid Global

  • Send marketing information to you on our behalf

  • Other purposes related to the above

We will not sell or license your information to third parties or otherwise disclose your personal information. In certain circumstances, we may be required to disclose your personal information without your consent in order to comply with any court orders, subpoenas, or other legal process or investigation, including by tax authorities, if such disclosure is required by law. Where possible and appropriate, we will notify you if we are required by law to disclose your personal information.

3. How do we store and secure the information we collect?

We store your personal information electronically in a secure database on our systems.

3.1 Security and management of personal information

We will take reasonable steps to protect the personal information we hold from misuse, loss, and unauthorised or accidental access, modification, disclosure, destruction, or other action which prevents or otherwise hinders our access to your personal information on a temporary or permanent basis. We do this by:

  • Putting in place physical, electronic, and procedural safeguards in line with industry standards

  • Requiring any third-party providers to have acceptable security measures to keep personal information secure

  • Limiting access to the information we collect about you

  • Imposing confidentiality requirements on our employees

  • Only providing access to personal information once proper identification has been given

While we take all steps reasonable in the circumstances to protect your information, in the unlikely event of a data breach we will notify you in accordance with our obligations under the Privacy Act.

Where there is a risk of serious harm arising from the breach, we will notify you and any relevant authorities.

We will only keep your personal information for as long as we require it for the purpose for which it was collected. However, we may also be required to keep some of your personal information for specified periods of time, for example under certain laws relating to companies, money laundering, and financial reporting legislation. If we no longer require your personal information, and are not legally required to retain it, we will take reasonable steps to destroy or de-identify the personal information.

3.2 Sending information overseas

We store personal information overseas using Microsoft servers. We also engage certain third-party services to process information which are located overseas. This includes Purple, our public Wi-Fi provider, located in the United Kingdom, and Eftsure, located in Dallas, Texas and Auckland, New Zealand.

We always take steps to ensure that where your personal information is sent overseas, it is handled in accordance with the Privacy Act.

4. How to access and control your information?

4.1 Accessing the information we hold about you

Under the APPs you may be able to obtain a copy of the personal information that we hold about you. To make a request to access this information, please contact us in writing. We will require you to verify your identity and specify what information you wish to access. If eligible, we will grant you access to the information within 30 days.

We may charge a fee to cover the costs of verifying your application, and retrieving, reviewing, and copying any material requested.

4.2 Updating your personal information

We endeavour to ensure that the personal information we hold about you is accurate, complete, and up to date. Please contact us at the details above if you believe that the information we hold about you requires correction or is out of date.

We endeavour to process any request within 30 days and will provide written reasons if your request is rejected, as well as providing details for making a complaint about the refusal if necessary.

5. Complaints

If you are concerned that we have not complied with your legal rights or the applicable privacy laws, contact our Privacy Officer in the first instance. Please contact our Privacy Officer (contact details above) with a thorough description of your concerns and a response will be provided within a reasonable period. All complaints must be in writing.

When processing a complaint, we will require you to provide us with information to confirm your identity before processing a request related to information we may hold about you.

We expect our procedures will deal fairly and promptly with your complaint. However, if you remain dissatisfied, you can also contact the Office of the Australian Information Commissioner as follows:

Director of Compliance
Office of the Australian Information Commissioner
GPO Box 5218
Sydney NSW 2001

For more information on privacy, see the Australian Information Commissioner’s website.