PRIVACY POLICY

Minett Prime Square Privacy Policy

This Privacy Policy applies to Minett Prime Square Pty Ltd ACN 633 084 250 (MPS, we, us, our).

MPS is committed to maintaining the privacy of your personal information. We have developed this Privacy Policy to inform you of how we manage your personal information.

By providing personal information to us, you are taken to have read, and consented to the collection, use disclosure and handling of your personal information in accordance with this Privacy Policy. 

1           How we collect your personal information

Personal information has the meaning given to that term in the Privacy Act 1988 (Cth) (Privacy Act) and includes information or an opinion (whether true or not) about an identified individual, or an individual who is reasonably identifiable. 

In general, we collect personal information about prospective and actual clients, suppliers, contractors and consultants of MPS, and any person who applies to become an employee or contractor of MPS. This includes employees or officers of MPS’s corporate clients, contractors and suppliers. 

We aim to collect personal information only if it is reasonably necessary to providing the service, product or information you have requested from us. 

In the course of providing you with products and services, MPS collects personal information in a variety of ways. Unless it is unreasonable or impracticable to do so, we collect your personal information from you directly. 

In some cases however, we may collect personal information from:

·            your employer or colleagues (if you are an employee or officer of a corporate customer, contractor or supplier to MPS);

·            other businesses involved in our business, including our business partners and third parties that refer or introduce you to us (including your lawyer, accountant or other advisor); and

·            publicly available sources of information such as the Australian Securities & Investments Commission (ASIC) and the Australian Business Register (ABR); 

·            credit reporting bodies (including Equifax);

·            Monomeath Capital Partners Pty Ltd (MCP) (another company in our group) and related bodies corporate (as that term is defined in the Corporations Act 2001 (Cth)) ofMPS; or

·            Gatehouse Hospitality Pty Ltd and its subsidiaries (Gatehouse).

At the time of collection, or as soon as practicable after we have collected it, we will take such steps as are reasonable in the circumstances to notify you of the collection and of matters relevant to the collection, unless it is obvious from the circumstances that you would know or would expect us to have the information.

MPS may collect personal information about you when you:

·            are a client or potential client of MPS;

·            engage with us in the course of receiving products or services from us or enquiring about our products or services;

·            visit our website, www.minettprimesquare.com (Website); 

·            subscribe to receive newsletters or information from us; 

·            apply as a candidate for a position of employment with us; or

·            supply goods or services to us.

2           What personal information we collect about you

The kinds of personal information we collect and hold about you will depend on the services we provide you with or if the law requires us to collect it. 

In general, you can assume that we may collect the following personal information about you:

·            name;

·            address;

·            email address;

·            telephone number and other contact details; 

·            details about you to assist in managing our relationship with you; and

·            details of the services or information we have provided to you or that you have enquired about, including any additional information necessary to deliver our services to you and respond to your enquiries.

If you are a prospective employee, we may collect details about your employment history and other details about you to assist with the recruitment process. We may collect this information from you directly, or from a recruiter. 

If you are an employee or officer of a corporate customer, supplier or contractor, we may collect personal information about the business that you represent.

For each visitor to our Website, we may also collect the following non-personally identifiable information using Google analytics: 

·            browser type, version and language;

·            operating system;

·            pages viewed while browsing the Websites; and

·            page access times and referring website address. 

3           How We Use Cookies 

We may use cookies on some areas of our Website. A cookie is a small file saved on your computer’s hard drive. When you return to our Website, the data saved in the cookie is sent back to the website. We use cookies to gauge visitor traffic, trends and to help us serve you more efficiently if you revisit the Websites. The cookies we use in no way give us access to your computer or any information about you, other than the information you choose to share with us. You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of our Website.

4           Purpose of collection

We collect personal information primarily to: 

·            contact you for business purposes and manage our relationship with your or your business;

·            provide you with the services and information that you request from us; 

·            provide you with information about MPS’s services and suggest our services to you; 

·            comply with our legal obligations (including to comply with any law or any lawful request of a law enforcement agency or government authority); and

·            otherwise manage our relationship with you.

If it is reasonable to expect that we would use or disclose your personal information for purposes which are related to the above primary purposes, we may also use or disclose your personal information to:

·            assist you with enquiries or complaints;

·            develop and improve our client service and relationships;

·            promote, advertise and market any of our products and services, including to invite you to seminars or events hosted by MPS; 

·            telling you about other suppliers, with whom we have arrangements, that supply goods or services that may be of interest to you; and

·            resolve any disputes that we may have with any of our clients and enforce our agreements with third parties such as your employer;

·            inform you of developments at MPS and other services that we can provide.

We may use information collected through our Website for the purpose of gauging visitor traffic, trends and delivering personalised content to you while you are at our Website.  

5           Sharing of your personal information

We may disclose your personal information with other organisations or people for any of the purposes described above.

This may include to:

·            external providers of services that we may use to operate our business and manage our business systems (for example, this may include file storage service providers, database and mailing service providers, marketing service providers, couriers and/or freight service providers, printers, call centres, providers of payment processing and identity verification services and IT technicians who may need access when providing on-site support (although it is our practice for them to work under supervision) and other professional service providers as required from time to time);

·            our professional advisors and agents; 

·            our existing or potential business partners; or

·            MCP, Gatehouse or related bodies corporate (as that term is defined in the Corporations Act 2001 (Cth)) of MPS

If you are a client or potential client, we may also disclose your personal information to:

·            your representative or any person acting on your behalf (for example, lawyers, settlement agents, accountants or real estate agents); 

·            referrers that referred your business to us; and

·            government or regulatory bodies as required or authorised by law.  In some instances, these bodies may share the information with relevant foreign authorities.

We may disclose your personal information to these third parties so that they can assist us with providing the best possible service to you.

Those third parties will be permitted to access only the personal information they need to deliver the service to MPS or to you. 

Unless you are located overseas or the services we provide to you are related to an overseas asset or project, we are not likely to disclose information to overseas recipients unless it is with your consent, or the disclosure is required or authorised by law. 

The privacy and collection practices of entities to which we disclose personal information are governed by their own privacy policies and collection notices.

We will not otherwise disclose information about you unless the disclosure:

·            is required or authorised by law; or

·            you have consented to our disclosing the information about you.

6           Quality of your personal information

We aim to ensure that your personal information is accurate, complete and up to date. To assist us in this, you need to provide true, accurate, current and complete information about yourself as requested and properly update the information to us to keep it true, accurate, current and complete.  

If you believe that the information we hold is inaccurate or incomplete, please contact us and we will use all reasonable efforts to correct the information. 

If we do not believe the information to be incorrect, we will take reasonable steps to add a statement to the information claiming that you believe the information is inaccurate, incomplete or out of date.

7           Securing your personal information

We will take reasonable precautions to protect your personal information from misuse, interference and loss, as well as from unauthorised access, modification or disclosure. 

We will retain your personal information as required by law, and then take reasonable steps to destroy or permanently de-identify personal information if it is no longer needed. 

8           Changes to this Privacy Policy

MPS reserves the right to make amendments to this Privacy Policy at any time for any reason. We will publish any updated Privacy Policy on our Website. 

9           Accessing and correcting your personal information

You have a right to request access to, or the correction of, your personal information that we hold about you, subject to exceptions allowed by law. You may be required to put your request in writing for security reasons. 

We will give you access to, or correct, your personal information unless there is a lawful reason for refusing your request for access or correction. If we refuse your request we will give you a written notice explaining our reasons for that refusal and how you may complain about that refusal. 

10         Change in control of MPS

If we sell or otherwise transfer part or the whole of (or control of) MPS or our business to another organisation (including in the course of a transaction like a sale, merger or acquisition or as part of a dissolution, liquidation, administration, receivership or other form of insolvency), you agree that your personal information that is collected by MPS may be disclosed to a third party, prospective buyer, transferee or insolvency practitioner and that this is reasonable to enable that party to continue or manage the business

11         Complaints

If you have a complaint about our collection, use or disclosure of your personal information, or you wish to make a complaint about a breach of the APPs, please contact our Privacy Officer at the details set out below. 

In your complaint, please set out the details of your complaint and your contact details. Our Privacy Officer will contact you to acknowledge your request and ask for any other applicable information. Our Privacy Officer will then investigate the issue and advise you in writing of the outcome.

You can also make a complaint to the Office of the Australian Information Commissioner. Further information is available at www.oaic.gov.au.

12         Contacting us

If you have any questions about this Privacy Policy or our privacy practices, would like to make a complaint or request access to or correction of your personal information, please contact us by any of the following means.

Our contact details in respect of any issues in relation to privacy are:

Email          hello@minettprimesquare.com

Post            Level 10/60 Albert Road, South Melbourne  VIC  3205