Thank you for visiting the website of ESR Real Estate Australia Pty Ltd and its subsidiaries (together ESR, we, our or us). When you use the services of ESR or access this website (the Site), you entrust us with personal information and agree to be bound by the terms set out in this Privacy Policy, which may be updated by us from time to time.
ESR is committed to safeguarding all personal information. The following describes our current policies regarding the collection, storage, use and disclosure of your personal information.
The types of personal information we collect and process may include, but is not limited to, information about you such as your name and contact details, your payment details, records of interactions and correspondence between us such as interactions with our team members and any interactions with us or posts that refer to us on social media, your use of our Site, applications and social media platforms.
We collect your personal information to provide our products or services to you, provide customer support, for marketing purposes, to improve our products and services, for legal and administrative purposes and any related purposes which would be reasonably expected.
We may collect your personal information in the course of you accessing our Site, and any other services provided including during conversations between you and our representatives, when you make an enquiry or complete an application. We will collect personal information from third parties including credit reporting agencies, law enforcement agencies and other Governmental agencies. We will also engage third parties to collect personal information on our behalf in connection with the management of our properties.
Collection of personal information may also include information solicited or unsolicited through the use of our Site. For example, we may collect your internet protocol (IP) address each time you request a page during a visit to the Site. At times, we may also use IP addresses to collect information regarding the frequency with which users browse various parts of the Site. The Site may also use cookies and other technical methods. These technical methods may involve the transmission of information either directly to us or to another party authorised by us to collect information on our behalf. We may collect information from use of these technical methods in a form that is personally identifiable, and we may use the information to, amongst other things, track the traffic patterns on the Site and collect and analyse Site session information.
We may also collect non-personally identifiable information that does not personally identify you, including anonymous information and aggregate data. We may use this information to understand better how visitors use the Site, research our visitors’ demographics, interest, and behaviour, improve the Site, provide visitors with customised services and information, and for other similar purposes. We may combine this information with personally identifiable information. We may share this information with others, such as investors, for information or promotional purposes to the extent permitted by law.
In certain circumstances, we may disclose your personal information to third parties who process personal information on our behalf for the purposes described in this Privacy Policy, including but not limited to any contractors, agents, business partners or service providers which provides administrative, data processing, financial, computer, telecommunications, payment or securities clearing, custodial or other services authorised by ESR when carrying out customer’s instructions and/or the business of ESR. Such information is only provided in accordance with the law and our employees, agents and/or affiliates are required to treat the information confidentially and use it exclusively for the purpose for which it is provided.
We may disclose your personal information to comply with our legal obligations, to protect the safety or security of you, us, third parties, including the safety and security of tangible or intangible property that belongs to you, us or to third parties, our Site and our databases. Also, in the event that ESR, or substantially all of its assets, are acquired or merged with another entity, we reserve the right to transfer to the extent permissible at law our databases, together with any personal information and non-personal information contained in those databases. This information may be disclosed to a potential purchaser under an agreement to maintain confidentiality.
We will retain your personal data for as long as is necessary for the purpose(s) for which it was collected and any other permitted linked purpose. Our retention periods are based on business needs and your information that is no longer needed is either irreversibly anonymised (and the anonymised information will be retained) or security destroyed.
This Privacy Policy does not concern any website to which the Site may link. Should you choose to visit these third-party sites, you should review their privacy policies to ensure that you understand and are comfortable with their practices concerning your personal information. This Privacy Policy does not address our privacy practices with respect to any non-public personal information we may collect from you as an investor in us or in funds that we sponsor or manage; We address these practices in separate notices to investors or potential investors.
To the extent permitted by law, information that we collect may from time to time be stored, processed in or transferred between parties located in countries outside of Australia, including countries with a lower level of data protection than in the country in which you are located. These may include, but are not limited to, Singapore, People’s Republic of China, Japan, South Korea and India.
We will take all reasonable steps to try and guarantee that your personal information is accurate, complete and up to date. To help us do this, please notify us of any change to your personal information.
You can contact us using the contact details provided at the end of this Privacy Policy. You have the right (subject to various exceptions and in accordance with the Privacy Act) to access certain personal information held about you and correct any inaccuracies. We may need to verify your identity. Please provide as much detail as you can about the particular information you seek, in order to help us locate it. We will provide our reasons if we deny any request for access to or correction of personal information. Where we decide not to make a requested correction to your personal information and you disagree, you may ask us to make a note of your requested correction with the information.
In the event that you become aware of any misuse, interference or loss or any authorised access, modification or disclosure of personal information held by us (a “Data Breach”), please notify us immediately using the contact details provided at the end of this Privacy Policy.
If we become aware of a Data Breach, we will promptly investigate the incident, and take reasonable steps to contain and remedy the Data Breach. We will take steps to notify you as soon as practicable if we believe that the Data Breach would be likely to result in serious harm to you.
After investigating a Data Breach, we may disclose information about the incident to the Office of the Australian Information Commissioner and to law enforcement agencies about the incident in order to comply with our reporting obligations under the Privacy Act.
In the event of discrepancies of this policy between the English version and other language version(s), the English version shall prevail.
You can contact our Privacy Officer at co-sec@esr.com or +61 2 9186 4741 if you have any concerns about our handling of your personal information. We will respond to let you know who will be handling your matter and when you can expect a further response. We may request additional details from you regarding your concerns and may need to engage or consult with other parties in order to investigate and deal with your issue. We will keep records of your request and any resolution.
For information about privacy generally, or if your concerns are not resolved to your satisfaction, you may contact the Office of the Australian Information Commissioner at www.oaic.gov.au and on 1300 363 992.
ESR, 2022