Privacy Policy. The Central Equity Group understands how highly people value the protection of their privacy.

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1 Privacy Plicy The Central Equity Grup understands hw highly peple value the prtectin f their privacy. Fr that reasn, the Central Equity Grup takes particular care in dealing with any persnal and sensitive infrmatin prvided t r cllected by it frm yu. We will nt sell yur persnal r sensitive infrmatin. We will ensure that yur persnal and sensitive infrmatin is stred in a secure envirnment. Unsubscribing frm ur marketing s is an easy, autmated prcess. We cmply with the Australian Privacy Principles (APPs) as cntained in the Privacy Act 1988 (Cth) (Privacy Act). We cmply with the Spam Act 2003 (Cth) and CAN-SPAM Act 2003 (USA). When yu visit us nline, we use bth first party and third party ckies t imprve yur brwsing experience and t assist ur marketing effrts. This privacy plicy has been develped in accrdance with the Australian Privacy Act as at May 2015 and explains the Central Equity Grup s practices fr the cllectin, use, disclsure, strage and destructin f yur persnal and sensitive infrmatin. If yu require further infrmatin abut ur privacy practices, please feel free t cntact us by t r by phning the Privacy Officer n Online Access Access t the Central Equity Grup websites (Sites) is cnditinal n yur acceptance f the terms f this privacy statement. By yur use f the Sites and the prvisin f yur infrmatin t us, yu cnsent t the cllectin, strage, use and disseminatin f yur persnal infrmatin in accrdance with this privacy statement and as therwise permitted under the Privacy Act. We may at any time vary the terms f this privacy statement, and yu shuld check this privacy statement regularly s that yu are aware f any variatins made. Yu will be deemed t have cnsented t such variatins by yur cntinued use f the Sites fllwing such changes being made.

2 2. What infrmatin we cllect and hld The kinds f persnal and sensitive infrmatin we cllect and hld frm yu r abut yu depend n which Central Equity Grup entity yu are dealing with, the transactin yu have entered int with us, and the services yu have engaged us t prvide r are interested in. The infrmatin that we cllect is necessary fr and related t the peratin f ur prperty develpment, prperty management, real estate and accmmdatin businesses. When yu brwse ur website r cntact us electrnically, we may recrd yur IP address, brwser type, dmain names, access times, referring website addresses, gegraphical tagging, ckies and statistical data. The kinds f persnal and sensitive infrmatin that we may cllect frm yu r abut yu (depending n which Central Equity entity yu are dealing with) include: yur name, address, phne, fax and mbile numbers, address, date f birth, gender, identificatin details and dcuments, bank accunt and credit card details (where relevant). We may als cllect details f yur ccupatin, emplyment histry, residential histry, incme details and insurance plicies (where relevant). We may als cllect ther persnal r sensitive infrmatin, depending n whether (fr example) yu are a vendr r purchaser f prperty, a landlrd r a tenant, r a guest. Even if yu are nt a client f urs, r even if we nly have limited cntact with yu, we may still cllect, hld, use and disclse sme persnal infrmatin abut yu (fr example, if yu are a guarantr t a prperty transactin, r if yu are put frward as an emergency r next-f-kin cntact). We may cllect sensitive infrmatin frm yu r abut yu where there is a legal requirement t d s, r where we are therwise permitted by law. In all ther situatins, we will specifically request yur cnsent. 3. Hw we cllect and hld infrmatin We aim t cllect persnal and sensitive infrmatin directly frm yu, unless it is unreasnable r impractical fr us t d s. Fr example, we cllect persnal and sensitive infrmatin frm yu r abut yu frm letters, s, nline and paper-based applicatin frms, cntracts and ther dcumentatin submitted t us n any f ur Sites, and whether in persn, by , by fax, by mail r ver the telephne. Hwever, in sme instances we may receive persnal and/r sensitive infrmatin abut yu frm third parties, such as assciated businesses, Gvernment departments and agencies, lcal Cuncils, insurers, banks, slicitrs, real estate agents, financial planners and accuntants. We may als receive persnal and sensitive infrmatin abut yu frm yur family members, authrised third parties and publicly available surces. Yu can be annymus r use a pseudnym when dealing with us, unless the use f yur true identity is a legal requirement, r it is impracticable fr us t deal with yu n such a basis.

3 4. Why we cllect, hld, use and disclse infrmatin We cllect, hld, use and disclse persnal and sensitive infrmatin frm yu r abut yu where it is reasnably necessary fr us t carry ut ur range f business functins and activities. Fr example, we cllect, hld, use and disclse yur persnal and sensitive infrmatin as necessary t cmplete the sale r purchase f yur prperty, r t manage the tenancy f yur prperty, r t prvide requested accmmdatin services. As well as fr fulfilling any requests yu may make t us, the infrmatin we cllect may be used fr related purpses that yu wuld reasnably expect, such as ur wn internal administrative and accunting functins, ur prfessinal and legal bligatins (including reprting bligatins), t keep yu infrmed abut new prjects, prducts, service fferings and initiatives, t invite yu t functins and events, t keep yu updated with relevant prperty infrmatin, nging newsletter cmmunicatins, cnducting feedback requests, the peratin f ur website prtals, statistical cllatin, website traffic analysis and als t assist the Central Equity Grup in its marketing research and imprving the services that the Central Equity Grup prvides. The entities within the Central Equity Grup necessarily wrk very clsely with ther businesses, such as law firms, accuntants, real estate agents, prperty valuers, financial planners, insurers, prperty managers, building cntractrs, maintenance cntractrs, bking agencies, banks and tenancy database peratrs. We may disclse yur persnal and sensitive infrmatin t these third parties where it is reasnably necessary fr them t assist us t prvide ur services t yu, r t enable them t prvide related service fferings that yu have requested. T assist us in the cnduct and maintenance f ur business, we may share the infrmatin we cllect with the ther entities in the Central Equity Grup, fr purpses including the seamless prvisin f ur services and t enable them t prvide related service fferings. We will als share yur persnal and sensitive infrmatin with ther third parties where required r permitted by law. We will nt prvide yur persnal infrmatin t ther parties simply t enable thse parties t target yu fr marketing, research r any ther purpses. If, at any time, we wish t share yur persnal infrmatin with ther parties, in circumstances ther than thse described abve, we will seek yur cnsent befre ding s. Where yu are a prspective emplyee r cntractr f any entity within the Central Equity Grup, we will cllect, use, hld and disclse certain persnal and sensitive infrmatin fr purpses related t yur prspective recruitment r engagement. In sme cases, ur recruitment activities may be managed by a third party recruitment agency. If certain persnal and sensitive infrmatin is nt prvided t us, r yu d nt agree t its cllectin, use r disclsure as set ut in this privacy statement, then we may nt be able t prvide yu with all f the functins and services that we ffer.

4 5. Security f yur infrmatin We ensure that ur staff invlved in the cllectin, use and strage f yur persnal and sensitive infrmatin are fully aware f and are trained t cmply with the requirements f this privacy statement and the Privacy Act. We have physical, electrnic and prcedural safeguards in place t ensure that yur persnal and sensitive infrmatin is stred in a secure envirnment. We have established security prcedures aimed at ensuring that the persnal and sensitive infrmatin prvided t us is prtected frm misuse, interference r lss, and frm unauthrised access, mdificatin r disclsure. If yu reasnably believe that there has been unauthrised use r disclsure f yur persnal r sensitive infrmatin, please cntact us at We will retain yur persnal and sensitive infrmatin whilst it is required fr any f ur business functins, r fr any ther lawful purpse (including mandatry data retentin perids). We use secure methds t destry r permanently de-identify yur persnal infrmatin when it is n lnger needed. We take reasnable steps nt t disclse yur persnal infrmatin t verseas recipients unless: it is necessary t cmplete the transactin yu have entered int; and we have btained yur cnsent (which may be implied); r we believe that the verseas recipient is required t deal with yur persnal infrmatin by enfrceable laws which are similar t the requirements under the APPs; r we frm the pinin that the disclsure will lessen r prevent a serius threat t the life, health r safety f an individual r t public safety; r we are taking apprpriate actin in relatin t suspected unlawful activity r serius miscnduct; r it is therwise permitted by law. Sme f ur administrative, marketing and IT cmputer systems and platfrms are hsted by service prviders lcated verseas. Currently, these hsting service prviders are lcated in USA, UK, Singapre and Thailand. Hwever, frm time t time, as ur IT systems require, changes may be made and this may affect the lcatin f hsting services. 6. Unsubscribe Prcess Where applicable, ur frms, whether nline r therwise, give yu the pprtunity t pt-in fr mre infrmatin abut ur prperties, services and events. Shuld yu pt-in and later change yur mind, yu can easily unsubscribe by clicking a link included at the bttm f ur s. This is an autmatic prcess and will take effect immediately. Alternatively, yu may always cntact ur Privacy Officer t be unsubscribed.

5 7. Ckies If yu are visiting ne f ur Sites, please nte that ur Sites use bth first party and third party ckies, tags and tracking settings t stre infrmatin that help give yu a better brwsing experience and assist us with ur web design, marketing and advertising effrts. Subject t yur web brwser s settings, we cllect infrmatin that is sent t us autmatically by yur web brwser when yu access ur Sites by help f a ckie. A ckie is a small text file that is placed n yur cmputer's hard disk by a web server. Ckies supprt the functinality f ur Sites and als help us t understand yur use f ur Sites, i.e. which pages yu visit, which links yu use, hw lng yu stay n each page and string infrmatin s that frms can be pre-filled r skipped. Mdern web brwsers make it easy t clear individual ckies frm yur cmputer. Cnsult yur web brwser s help files fr mre inf. Please keep in mind that withut ckies, we cannt give yu an ptimised website experience and sme functinality may be disabled. 8. Access t and crrectin f infrmatin If yu wish t knw what persnal infrmatin we have cllected abut yu, yu can simply send us an t and we will, subject t any exemptins allwed under the Privacy Act, prvide that infrmatin r an utline f that infrmatin (as apprpriate) as sn as practicable. If yu wish t amend r delete the infrmatin prvided t us, yu can send an t the same address and we will take all reasnable steps t fulfil such a request. If we d nt agree t prvide yu access r t crrect the infrmatin as requested, we will give yu written reasns why. T assist us t keep ur recrds up-t-date, please ntify us f any changes t yur persnal infrmatin. 9. Feedback We mnitr ur practices fr the cllectin and use f persnal infrmatin t ensure that thse practices cntinue t meet ur bligatins under the Privacy Act. We are grateful fr any feedback yu may have in relatin t ur privacy practices. Please any cmments, questins r cmplaints yu may have in relatin t ur privacy plicy r practices t We will respnd t any cmments, questins r cmplaints as sn as we can and in accrdance with the relevant prvisins f the APPs.

6 10. Definitins In this Plicy: Persnal infrmatin means infrmatin r an pinin abut an identified individual, r abut an individual wh is reasnably identifiable. Central Equity Grup means: Central Equity Limited and its subsidiaries; Melburne Inner City Management Pty Ltd and its subsidiaries; Melburne Shrt Stay Apartments Pty Ltd and its subsidiaries; and any ther related entity frm time t time. 11. Cntact Privacy Officer Central Equity Limited 32 Pwer Street, Suthbank Vic 3006, Australia Telephne: Free Call: Fax: Plicy Last Updated Sept 2015

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