[ISPT Pty Ltd and AWPF Management No 2 Pty Ltd C/O JLL, ABN: 37 002 851 925] (“World Square”, “us,” “our” or “we”) understands and appreciates that your privacy is very important to you and that you have a right to control your personal information. We understand that providing personal information is an act of trust and we take that seriously. World Square is bound by the Australian privacy laws including the Australian Privacy Principles (“APPs”) set out in the Privacy Act 1968 (Cth), as well as the relevant privacy-related legislation in all other jurisdictions in which we operate including the European Union (“EU”) General Data Protection Regulation (“GDPR”) where we process personal data relating to identifiable EU residents and as applicable, the California Consumer Privacy Act (“CCPA”) where personally identifiable information of California residents is processed. This Privacy Policy explains how we will deal with your personal information as you interact with us. By accessing or use this website and providing your personal information to us, you agree to the collection, use and disclosure of your personal information in the manner described in this Privacy Policy.

Collection and use of personal information

Personal information is any information that can be used to personally identify you. We will collect personal information from you to carry on our business functions and according to this Privacy Policy. This includes providing you with products and services that you have requested or inquired about, or letting you know about other products, services, or opportunities that you might be interested in.

What personal information do we collect and hold?

We will collect personally identifiable information from you when you knowingly provide it to us. The type of personal information we may collect from you include:

• Your name;
• Mailing or street address;
• Email address;
• Telephone number;
• Age or birth date; or
• Profession, occupation or job title.

We may also collect data from you indirectly through your use of this website for statistical purposes including:

• Your server’s IP;
• The pages you accessed, and any documents downloaded from this website;
• The type of browser and operating system you are using; and
• The date and time of your visit.

If you have invested in a managed investment scheme, we are required to collect additional personal and sensitive information under the Income Tax Assessment Act 1997 (Cth) and Anti Money Laundering and Counter Terrorism Financing Act 2006 (Cth) (“AML/CTF Act”).

How do we collect your personal information?

We collect your personal information directly from you unless it is unreasonable or impracticable to do so. When collecting personal information from you, we may collect in ways including through your access and use of our websites during conversations between you and our representatives when you become a tenant or owner of one of our properties or when you complete an application.

In some situations, we may collect information about you from third parties such as your legal or personal representative, your financial adviser, or publicly available sources of information. Where necessary, we will only collect your information from third parties with your consent and use it for the purpose we told you that we collected it.

What happens if we can’t collect your personal information?

You are not obligated to provide your personal information however failure to provide us with the personal information described above, the following may occur:

• We may not be able to provide the requested products or services to you;
• We may not be able to provide you with information about products and services that you may want; or
• For investment clients, failure to provide a tax file number may result in a higher rate of tax being applied and failure to provide information under the AML/CTF Act may result in us not being able to process your request.

Disclosure of personal information

In line with modern business practices and to assist you with your requirements we may disclose your personal information to:

• Our employees, related bodies corporate, contractors or service providers for the purposes of operation of our business, fulfilling requests by you, and to otherwise provide products and services to you including, without limitation: companies involved in maintaining, reviewing and developing our business systems, and infrastructure;
• Organisations involved in providing, managing or administering your product or service such as third party suppliers and contractors employed to provide building maintenance services;
• Your financial adviser;
• Those people who are your authorised legal or personal representatives;
• Government or regulatory bodies as required or authorised by law; or
• Any other company or person with your express consent.

We have engaged Skyfii Group Pty Ltd (ACN 165 152 241) (“Skyfii”) to provide us with analytical services in relation to consumer behaviour. Skyfii assists physical venues by using data to measure, predict and improve consumer behaviour. Information will be provided to Skyfii only to the extent necessary for the purposes of providing these services. Any information provided to Skyfii will be handled in accordance to Skyfii’s privacy policy at http://skyfii.io/privacy-policy/.

We will generally not allow access from or transfer your personal information outside of Australia, however, it may be necessary from time to time to utilise overseas services in order to provide the website. For instance, our service providers, like email platforms, data storage and cloud storage facilities, or CRM systems, may hold data about you on servers located overseas. Generally, your personal information will never leave our effective control, and the third parties will not have access to the information for their own purposes unless provided for elsewhere under this Privacy Policy. If we do disclose the information to the third parties for their own purposes and they are located overseas, we will only disclose to these overseas entities if we have taken reasonable steps to ensure that they will not breach the Australian privacy laws in relation to your information.

For EU residents, your data will almost certainly be transferred outside of the European Economic Area (“EEA”) when it is provided to us. Where your personal data is transferred by us to anyone else, we will ensure that this is only done with appropriate safeguards in place to protect personal data in compliance with applicable data protection legislation. Such measures may include (without limitation) transferring the data (i) to a third party in a country that has been identified as providing adequate protection for EEA data, or (ii) to a third party which has entered into standard contractual clauses adopted or approved by the European Commission, or (iii) to a third party in the US which is Privacy Shield certified.

Direct marketing materials

With your express consent, we may send you direct marketing, communications and information about our products and services that we consider may be of interest to you. These communications may be sent in various forms, including mail, SMS and email, in accordance with applicable marketing laws, such as the Spam Act 2003 (Cth). If you indicate a preference for a method of communication, we will endeavour to use that method whenever practical to do so. You may opt-out of receiving marketing communications from us by contacting us (see the details below) and we will then ensure that your name is removed from our mailing list.

Security, Access, Accuracy and Other Rights

We store information in different ways, including in paper and electronic form. The security of your personal information is important to us and we will take reasonable steps to protect it from misuse and loss and unauthorised access, modification or disclosure.

We will also take reasonable steps to make sure that the personal information we collect, use or disclose is accurate, complete and up-to-date. If you believe your personal information is not accurate, complete, or up to date, please contact us at the details below.

To request access to your personal information you can contact us using the information in the “Contacting Us” section below.

If the GDPR applies, EU residents also have the following additional rights:

• the right to obtain a copy of their personal data on request;
• the right to transfer their personal data to another person or entity (right of data portability);
• the right to restrict or object to processing, or withdraw consent to processing; and
• the right to lodge a complaint with a supervisory authority (see below).
• If the CCPA applies, California residents also have the following additional rights:
• the right to obtain a copy of their personal data on request including additional details regarding how information is used, collected, shared or sold in the preceding 12 months;
• the right to opt out of sale of their personal data, if applicable; and
• the right to not be discriminated against for exercising these rights.
• Please be aware that some information cannot be amended or deleted due to legal reasons. If we deny your request, we will inform you of the reasons for this decision.

Our Websites

Our websites have electronic security systems in place, including firewalls. Depending on the organisation with which you deal, other security measures may also be in place to control access to your personal information.

Cookies

A cookie is a piece of information that our web server may send to your machine when you visit our website. The cookie is stored on your machine but does not identify you or give us any information about your computer. A cookie helps us to recognise you when you re-visit our website and to co-ordinate your access to different pages on the website. With most internet browsers, you can erase cookies from your computer hard drive, block all cookies, or receive a warning before a cookie is stored. If you want to do this, refer to your browser instructions or help screen to learn more.

Links to Other Sites

You may be able to access external websites by clicking on links we have provided. If you use these links, you will leave our website and we are not responsible for any of these sites, their content or their usage of your personal information. Those other websites are not subject to our privacy standards, policies and procedures. We advise that you contact or review those websites directly to determine what security measures they have in place.

Using Government Identifiers

We will not use or disclose a government identifier (such as a tax file number) other than when required or authorised by law.

Your sensitive information

We will not collect sensitive information about you except with your specific consent and where it is necessary for our specific business functions or activities unless we are required to do so by law; the information is required for an insurance claim; or the information is necessary for the establishment, exercise or defence of a legal claim.

Access, complaints, queries and contacting us

If you wish to access or correct personal information we hold about you, if you wish to make a privacy complaint or if you have any questions about this Privacy Policy, you can contact us at:

[Email: info@worldsquare.com.au]

If you feel that we have not adequately dealt with any privacy complaint you have made, you may contact the Office of the Privacy Commissioner (Australia), the Privacy Commissioner (New Zealand) or under the GDPR or CCPA, the local regulator of your jurisdiction as applicable.

More Information

For more information about privacy legislation, you can visit the website of the Australian Information Commissioner at www.privacy.gov.au, the New Zealand Privacy Commissioner at https://www.privacy.org.nz/, the European Commission at https://ec.europa.eu/info/law/law-topic/data-protection/eu-data-protection-rules_en or the California Attorney General at https://oag.ca.gov/privacy/ccpa.

Changes

From time to time, it may be necessary for us to review and revise this Privacy Statement. We reserve the right to change our Privacy Statement at any time for any reason. If we make a change to the Privacy Statement, the revised version will be posted on this website.

Last updated June 2020