Privacy Policy

This privacy policy (Privacy Policy) sets out how Vinta handles your personal information in accordance with its obligations under the Privacy Act 1988 (Cth) (Privacy Act).
This Privacy Policy complies with all requirements of the Privacy Act in relation to the collection, management and disclosure of your personal information.
“Vinta” as referred to in this Privacy Policy includes Vinta Investment Management Pty Ltd ACN 102 283 474 and each of its related bodies corporate (as defined in the Corporations Act 2001) and we also refer to these entities in this Privacy Policy as “we” or “us”. Where used in this Privacy Policy, “personal information” has the same meaning as in the Privacy Act.
What kinds of personal information are collected?
The kinds of personal information which Vinta may collect about you depends on your relationship with Vinta or the products, services or information that you request or which Vinta provides to you. This personal information may include:

your name, residential or mailing address, email address, phone number, fax number and date of birth;
your tax file number and ABN;
financial and trading information including your credit card, debit card and bank account details;
your retailing experience;
your gender;
your profession, occupation or job title;
your membership of professional associations or bodies;
information relating to your identity such as driver’s licence and passport details;
information relating to your income/credit status;
your employment history, education, qualifications, professional experience and entitlement to work, if you apply for a job with us;
your superannuation fund(s);
details of products and services we have provided to you;
details of insurances you hold;
information you provide to us through our website, other on-line facilities, our representatives or customer surveys;
if you invest with us, information relating to you and your investments;
your photo or image including taken via our security cameras;
employee background, health and medical information;
if you are involved in an accident, health and medical information, witness statements, incident reports, CCTV footage and details of your accident;
your social media account ID, IP address and profile photo;
your guest preferences and personalised data such as your interests and food and beverage preferences; and
nominated beneficiaries.

Vinta generally only collects sensitive information (as defined in the Privacy Act) if it is reasonably necessary for, or directly related to, our functions or activities and you consent to that collection or its collection by us is authorised by law.
How is personal information collected?
Vinta collects your personal information when you:

complete an application form including to work for us or lease or licence property from us;
request certain information from our website or other on-line facilities;
communicate with us via email, post or fax, or otherwise connect with us or visit our websites, social media pages or mobile applications;
log on to our Wi-Fi in our properties or click on our other on-line media;
purchase or redeem gift or loyalty cards;
enrol or participate in surveys, questionnaires, competitions, customer programmes, clubs or our promotions;
enter into contractual arrangements with us;
participate in our induction procedures;
contact or speak with us in relation to services or products we provide or things that may have happened in any of our properties;
enter our properties and car parks (including completing our visitor registers);
are involved in an accident or incident involving us; and
authorise your representatives to provide it to us.

Vinta may also, with your consent or if we are authorised by law, collect your personal information from public or other sources if it is unreasonable or impractical to obtain it directly from you.
Vinta’s website uses cookies. Cookies are small data files that are placed on your hard drive that collect information, including browsing information, each time you access Vinta’s website. Information collected through cookies is used by Vinta to operate the website efficiently and to track the patterns of behaviour of visitors to the website. You can change your browser settings to notify you when you receive a cookie or to disable cookies. If you disable cookies, Vinta’s website may not work properly.
Why is personal information collected, held, used or disclosed?
Vinta collects, holds, uses and discloses your personal information in order to:

learn of your likely preferences so we may promote our goods and services to you so they will be of most interest to you;
assist in investigating and processing your complaints and enquiries;
inform you of updates concerning our products and services;
assess the performance of our websites, social media pages or mobile applications and to improve their performance;
conduct business processing functions including providing personal information to other companies, contractors or service providers of Vinta;
assist in our marketing (including direct marketing), planning, product or service development, quality control or research purposes;
provide your updated personal information to our contractors and service providers in order for us to provide our products and services to you;
update our records and keep your contact details up to date;
establish, administer and facilitate any investment you may have in a Vinta fund (including monitoring, auditing and evaluating the fund);
send you information and communications requested or authorised by you;
process payments from you and transfer money to you;
promote goods and services to you and facilitate related companies of Vinta promoting goods and services to you;
conduct research to improve our services and comply with our legal obligations;
confirm you are complying with your legal obligations to us;
confirm your eligibility (including your age), if purchasing restricted goods or services;
provide employee-related services;
carry out risk management and other activities, including incident investigation, claims management and litigation;
manage the security of our properties;
carry out data analysis, audits, security and fraud monitoring and prevention (including with the use of closed-circuit television, card keys, and other security systems);
identify usage trends to determine the effectiveness of our promotional campaigns, operate and expand our business activities, develop new goods and services and enhance, improve or modify our goods and services;
enforce our terms and conditions;
protect our operations;
protect the rights, privacy, safety or property of Vinta, you or others;
assess the suitability and ongoing performance of our employees, tenants, licensees, suppliers and contractors; and
comply with any law, rule, regulation, lawful and binding determination, decision or direction of a regulator or act in co-operation with any government authority.

You will have the choice to elect to receive some of the above communications either on the Vinta website at www.vinta.com.au, on-line or by mail, SMS or fax in accordance with applicable laws. Should you elect to receive any of the above communications, you will also have the option to ‘opt out’ of receiving them at any time in the future by unsubscribing from communications received electronically or by contacting Vinta at info@vinta.com.au.
Vinta is also required to collect certain personal information in order to comply with its legal obligations, including under the following legislation:

Corporations Act 2001;
Income Tax Assessment Acts 1936 and 1997;
Taxation Administration Act 1953; and
Anti-Money Laundering and Counter-Terrorism Financing Act 2006.

Who is your personal information disclosed to?
Vinta does not generally disclose your personal information except as stated below.
We will disclose your personal information in specific circumstances when:

you agree to the disclosure;
we use your personal information for the purpose for which we collected it; or
disclosure is authorised or required by law.

To the extent permitted by law, we may disclose your personal information to:

our related companies;
parties to whom Vinta has outsourced any of its functions or obligations;
government agencies as part of our statutory obligations;
third parties, including agents, contractors, sub-contractors, consultants, surveyors, builders and service providers:

that provide services to Vinta or perform functions on our behalf, including custodians, registry providers, legal advisers, accountants, actuaries, insurers, website managers, IT system administrators, couriers, payment processors, debt collectors, insurers, process servers, claims management services and providers of internet, data storage and data access services;
that assist us in providing information, products, services or direct marketing to you. This may include parties located (or that store data) outside of Australia; and
to collect and process data, which may include parties that store data outside of Australia.

valuers, where Vinta is seeking to value one of its properties;
banks, mortgage insurers and credit reporting agencies in relation to financial transactions relating to its properties;
regulatory authorities where required by law;
anyone else to whom you authorise Vinta to disclose your personal information; and
anyone else required or authorised by law.

If any Vinta business, company or trust is sold or transferred to another organisation, we may transfer any personal information we hold about you to that organisation.
Is your personal information disclosed overseas?
There are circumstances where Vinta may disclose your personal information to recipients located overseas.
Some service providers that we use, including for the purpose of collecting information and processing data may store and process that data on servers located overseas, specifically in the United States of America.
Wherever reasonably possible we ensure that anyone with whom we share your personal information (or who collects and/or processes information on our behalf) is subject to the same privacy legislation as we are and/or either agrees to be bound by the standards of our privacy policy or is subject to privacy standards that are at least substantially similar to the way in which the Privacy Act protects your information.
How is your personal information held?
Vinta uses reasonable steps to protect your personal information held by us from misuse, interference and loss, and from unauthorised access, modification or disclosure by taking precautions including:

restricting access to personal information stored in Vinta’s servers;
imposing confidentiality requirements on its employees;
requiring that its contractors and agents take reasonable steps to protect personal information from misuse, interference and loss, and from unauthorised access, modification or disclosure;
implementing electronic security systems, such as firewalls;
ensuring that servers containing personal information have security measures such as password protection; and
controlling access to Vinta’s offices.

No Vinta employee is able to access your personal information unless they require it for their duties. Vinta has passwords and security access IDs in place to restrict access to your personal information to those employees who need it to perform their duties.
Accuracy of your personal information
Vinta aims to ensure that the personal information we keep about you is accurate, up to date and complete.
How can you access and correct personal information?
Subject to the exceptions set out in the Privacy Act, you have a right to access, update and seek correction of personal information that Vinta holds about you.
Vinta may recover from you reasonable costs of supplying you with access to your personal information. However, we will not charge you for the making of the request or to correct or update your personal information.
If you would like to access or correct your personal information, please contact Vinta’s Privacy Officer via the contact details listed below. Your request will be dealt with as soon as reasonably practicable. If Vinta does not provide you with the requested access to, or correction for, the information it will generally notify you of the reasons for refusal to the extent required and what the next steps for you are.
Privacy Complaints
If you believe Vinta has breached the Privacy Act or a registered code that binds us, please contact Vinta’s Privacy Officer via the contact details listed below. Vinta may request that you put your complaint in writing. Vinta will endeavour to resolve your complaint in a reasonable time frame (usually within 30 days) and may contact you in order to obtain further details in order to provide you with a full and complete response. If you are not satisfied with the manner in which Vinta has handled your complaint, you can lodge a complaint with the Office of the Australian Information Commissioner at www.oaic.gov.au.
Privacy Officer Contact Details
To access or correct your personal information, to notify Vinta of a breach of the Privacy Act or a registered code or if you have any privacy related inquiries, please contact Vinta’s Privacy Officer at PrivacyOfficer@vinta.com.au, Telephone No. (02) 9290 6000, GPO Box 5275 Sydney NSW 2000.
Links to other websites
You may find links to other websites not operated by Vinta on our website. This Privacy Policy does not apply to those websites – always check the privacy policy of other sites you enter.
Changes to our Privacy Policy
Vinta reserves the right to modify or amend the Privacy Policy at any time and will update it on the Vinta website if it has been changed. If you have any further questions about Vinta’s Privacy Policy please contact Vinta’s Privacy Officer at PrivacyOfficer@vinta.com.au, Telephone No. (02) 9290 6000, GPO Box 5275 Sydney NSW 2000.
This Privacy Policy is amended from time to time and was last updated on 29 August 2019.

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