1. Application

This Privacy Policy (“Policy”) applies in relation to the retail and commercial properties identified on www.qicre.com (“QIC Real Estate”), including the domain www.qicre.com and any centre-specific websites related to that domain (such as www.watergardens.qicre.com) (“Websites”) and any Mobile Applications (“Applications”) operated by QIC Real Estate. QIC’s corporate Privacy Policy is available at www.qic.com.au/privacy-policy.

QIC Real Estate and Websites are owned by QIC Limited ACN 130 539 123, its related bodies corporate, and its joint venture partners, and managed by QICP Pty Ltd ACN 075 744 151. These entities are collectively referred to as “QIC” throughout this Policy.   


2. Objective

This Policy sets out how QIC handles personal information in connection with QIC Real Estate and its Websites and Applications. This includes personal information relating to customers, prospective customers, suppliers, tenants and, where applicable, their guarantors, retailers, visitors to our premises, and users of our Websites and Applications (collectively referred to as “you”).

We are committed to protecting your privacy, in compliance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (“APPs”).


3. What is personal information?

“Personal information” refers to information or an opinion about an individual, where that individual is identified or reasonably identifiable.

“Sensitive information” is a subcategory of personal information which is strictly regulated. Sensitive information includes information about your racial or ethnic origin, your religious, philosophical or political beliefs, your trade union membership or associations, your sexual preferences and orientation, or your genetic, biometric or health information.


4. Your privacy is important to us

QIC respects your privacy and we are committed to being transparent about our privacy practices and security. This Policy explains how we handle your personal information by setting out:


  • what personal information we collect and why;


  • disclosure of personal information;
  • storage and retention of personal information; and
  • protection of personal information.

The Policy also describes how you can:

  • access or correct personal information;
  • opt out of communications;
  • make a complaint; and
  • contact us.


5. What personal information we collect and why 

QIC collects personal information in order to conduct its business operations and deliver products and services. Your Personal information may be collected by or on behalf of QIC, or third-party suppliers who provide services, including digital platform services, to QIC and its customers.

Where you provide information to us in different ways, or where we already hold information about you, we may connect your information for use for one or more of the purposes listed in this Policy. If this occurs, the relevant information will be treated in the same manner as the personal information to which it has been linked.

This section identifies the kinds of personal information we collect, and the reasons why personal information is collected. We will inform you at or before the time of collection (or as soon as possible afterwards) of the purposes for collection, to whom your data might be disclosed and any other relevant details that will help you to ensure we are protecting your privacy. In some instances, we may direct you to this Policy for this information.

The Australian privacy regime provides the option of not identifying yourself, or of using a pseudonym when dealing with us unless we are required or authorised by law or a court/tribunal to identify you, or it is impracticable to deal with you anonymously or by a pseudonym.

5.1 QIC Real Estate

QIC collects information at QIC Real Estate in a number of different ways:

  • Competitions and newsletters: You may provide us with your contact details and other details about you including your interests and gender in connection with competitions or signing up to email or mobile newsletters (either in person or online) or your details may be provided to QIC Real Estate by third parties where you have consented to this information being shared with us for this purpose. Your name and email address are automatically entered into QIC’s database when you enter competitions. QIC collects these details to contact competition winners, to inform you about events, activities and promotions, and to better target and personalise your shopping experience (where applicable You can opt out from receiving promotional material at any time.
  • Equipment hire: When you hire mobility aids or other equipment from QIC, you provide QIC with certain information, including contact information. QIC collects this information to ensure that there is a record of the hirer.
  • Surveillance: During your visit to QIC Real Estate and its car parks, your activity may be captured using video and audio surveillance including CCTV. When you enter QIC Real Estate and its car parks, your personal information, car licence plate details and images may be collected by a third-party contractor who is contracted to QIC, and QIC may also collect your personal information and images from third parties (for example, the police or retailers). In the unlikely event of a security incident in QIC Real Estate or its car parks, this information may also be collected by a third-party contractor contracted to QIC using a body-worn camera (which records both audio and video). Video and audio surveillance will not be used in toilets, bathrooms or any area in which surveillance would not be reasonably expected. This information may be used by QIC in connection with the management and security of QIC Real Estate. This information may be provided to law enforcement and government bodies, QIC staff and subcontractors, third parties who provide QIC with services or who QIC has otherwise partnered with from time to time, insurers, and retailers for those purposes. Retailers and other third parties may operate their own surveillance systems which collect personal information for their own purposes. These purposes will be covered by those parties’ privacy policies.
  • Promotional photos and videos: QIC may conduct, or may permit third parties to conduct, photography and filming at QIC Real Estate. QIC will provide clear signage around areas where photography and/or filming may occur (“Signed Area”). By entering into a Signed Area, you consent to QIC or its third-party contractors collecting information about you by filming you or taking your photograph. If you do not wish to be filmed or photographed, you must not enter a Signed Area. QIC or the relevant third party may also request that individuals who are filmed or photographed sign a release form.
  • Ticketless parking facilities: When you park in a car park which uses a ticketless parking system or car locator functionality, you consent to provide us with your car licence plate details and, in some circumstances, other information including your name, email address and telephone number. These details are used for measuring and analysing car parking dwell times and attendee behaviour in order to improve QIC Real Estate, for the purposes of providing and managing car parking and related services at QIC Real Estate, marketing purposes, and to assist you to locate your car including via online and mobile applications. Your credit card details may also be collected when you enter a ticketless parking facility for the purpose of calculating and processing your payment when you exit that ticketless parking facility.
  • Credit card and bank account details: Along with ticketless parking facilities, in other certain circumstances, QIC or its third-party contractors may also collect and hold your credit card or bank account details for the purpose of processing payments from or to you.
  • Wi-Fi: When you logon to Wi-Fi provided in QIC Real Estate or access third party applications utilising QIC’s infrastructure (including Bluetooth beacon networks), you provide QIC with certain information, including your contact details and location as well as your interests and on-site movements. QIC collects these details to inform you about events, activities and promotions, and to better target and personalise shopping experiences (where applicable). You can opt out from receiving promotional material at any time.
  • Gift cards: When you purchase, redeem or are provided with a gift card (either in physical or digital form), you may provide QIC with your contact details and, potentially, identity documentation. These details are used for card fulfilment purposes, to contact you about events, activities and promotions, and to fulfil anti-money laundering or other legal obligations where relevant.

QIC Real Estate may also collect your personal information when you contact us using any method including via email, phone, post or an online form in order to process or assist with your query.


5.2 Websites and Mobile Applications

We may collect information from you via our online services, such as our Websites and Applications. This includes information you provide when signing up to services offered or creating a profile which may include your name, contact information, date of birth, gender location and interests. Our Websites and Mobile Applications may also collect information using “cookies”, which are small data files placed on your computer or mobile device when you visit a website. Most browsers enable you to disable cookies in your browser settings. You can configure your browser to accept all cookies, reject all cookies, or notify you when a cookie is sent. (Each browser is different, so check the Help menu of your browser to learn how to change your cookie preferences).

If you disable the use of cookies on your web browser or remove or reject specific cookies from QIC Websites or linked sites, then you may not be able to gain access to all of the content and facilities on those Websites.

The information we collect from you when you use QIC Websites and Applications may include:

  • the fully qualified domain name from which you accessed our Websites, or alternatively, your IP address;
  • device ID number (MAC address);
  • the date and time you accessed each page on our Websites;
  • the URL of any webpage from which you accessed our Websites or on which you were using our in-centre Wi-Fi, and the details of any mobile apps you have accessed from a device using in-Centre Wi-Fi;
  • device data including usage, demographics (for example, language settings), type of device, operating system and browser, and location and proximity of your wireless device in-centre, centre arrival and departure time, and other data which users consent to us collecting from time to time; and
  • publicly accessible social media posts and any personal information you allow us to collect by linking your account on our Websites with a third-party social-networking site, including but not limited to Facebook, Twitter, or Google+.

We collect this information (and may use or hold this information) for the following purposes:

  • to identify web page and store preferences;
  • to improve our Websites, applications or in-centre experiences;
  • for the purposes of and incidental to your use of in-centre Wi-Fi services (if applicable), our mobile apps, online services and gift card services;
  • to measure shopper numbers, characteristics and demographics, and analyse shopper behaviour in order to continuously improve our centres and for use otherwise in connection with our business;
  • to send to you special deals and discounts, surveys and other marketing materials based on your location or known web usage;
    to fulfil our legal obligations and comply with requests from law enforcement, including where law enforcement, government agencies and/or regulatory authorities are conducting an enquiry and/or investigation; and
  • for other purposes for which you, either expressly or impliedly, provide your consent.


5.3 Suppliers

If you, or a company you work for, supplies goods or services to QIC, QIC may collect personal information about you in connection with the provision of those goods or services, either directly from you or from that company. This information may include your name, date of birth, contact information, and any other information you provide, or which is provided on your behalf, as part of our induction and compliance processes. This information will be used for the purposes of managing the provision of those goods or services.


5.4 Sensitive Information

Except as outlined in this Policy, we do not collect sensitive information unless required by law or where you consent for us to do so (and in any event, only where it is relevant). We will not collect sensitive information about you where this is expressly prohibited by applicable law.


5.5 Unsolicited Information

If we receive personal information about you, whether received directly from you or on your behalf, that we did not ask for and where it is unlawful for us to collect this information, we will, if it is lawful and reasonable to do so de-identify or destroy that personal information. Any unsolicited information we collect about you will only be used for the purposes for which it was provided.


5.6 Anonymised data

QIC may collect or create anonymised data, such as foot traffic data and information about customer demographics, interests and behaviours. Anonymised data is not personal information and does not identify you. QIC may use anonymised data for the purposes listed in this Policy, as well as to inform our promotional and marketing strategies, and for research and profiling purposes.

Any research, statistical analysis or profiling we perform may be compiled and analysed on an aggregate basis, and we may share this aggregate data with our affiliates, agents and business partners. We may also disclose aggregated information in order to describe our services to current and prospective business partners, and to other third parties for other lawful purposes.


5.7 Cookies

A 'cookie' is a packet of information placed on a user's computer by a website for record keeping purposes. Cookies are generally used by our website to:

  • Enhance browsing experience - if you log into our secure areas on our websites, we will use cookies to save your preferences and remember your user settings.
  • Manage advertising - cookies are sometimes used to collect anonymous information about the page you visit and the type of software you are using.
  • Monitor traffic - we use anonymous information to track how people are using the QIC site. This may include time of visit, pages visited and some system information about the type of computer you are using.

You can configure your browser to accept all cookies, reject all cookies, or notify you when a cookie is sent. (Each browser is different, so check the Help menu of your browser to learn how to change your cookie preferences).

If you disable the use of cookies on your web browser or remove or reject specific cookies from QIC websites or linked sites, then you may not be able to gain access to all the content and facilities on those websites.


5.8 Do Not Track Signals

Some web browsers incorporate a “Do Not Track” (“DNT”) feature that signals to web services that a visitor does not want to have their online activity tracked. DNT is not a standardised feature in browsers and not all web browsers offer DNT options, which prevents QIC guaranteeing support of the feature to users. As such, while respecting users’ privacy and their ability to request that data not be collected, or deleted on request, we and many other website operators do not, as standard, respond to DNT signals.


5.9 Links

Our Websites may contain links to websites operated by third parties. Unless expressly stated otherwise, we are not responsible for the privacy practices of, or any content on, or security of those linked websites, and have no control over or rights in those linked websites. The privacy policies that apply to those other websites may differ substantially from this Policy, so we encourage individuals to read them before using those websites.


6. Disclosure of Personal Information

We understand how important it is to keep your personal information private, so we only disclose personal information we have about you when:

  • you consent to the disclosure; or
  • where there is a lawful basis; or
  • we use it for the purposes for which we collected it; or
  • disclosure is required or authorised by law.

To the extent permitted by law, we may disclose information about you to:

  • QIC’s entities including those outside of Australia;
  • our agents and contractors and other trusted partners QIC engages from time to time;
  • our insurers and insurance brokers;
  • our joint venture and commercial partners;
  • third party suppliers and service providers, including providers for the operation of our Websites and/or our business, or in connection with providing our products and services to you;
  • our professional advisors including our insurers, lawyers, and accountants;
  • law enforcement, government agencies and/or regulatory authorities as part of our legal obligations, or in response to requests for information from law enforcement, government agencies and/or regulatory authorities in the course of enquiries and/or investigations; or as otherwise permitted by law.

We may disclose your personal information to law enforcement, government agencies and/or regulatory authorities in response to requests made in the course of enquires and/or investigations.

In certain circumstances, we may disclose your personal information overseas. We will not send your personal information outside Australia unless it is authorised by law and we can be satisfied that the recipient of the personal information has adequate data protection arrangements in place. The countries to which we usually transfer information are the United States of America, the United Kingdom, Ireland, Denmark, Sweden, Finland, and Singapore.

We do not sell personal information to other organisations for marketing purposes. Any data sharing will be in compliance with local privacy laws and governed by our strict standards and policies and, where appropriate, confidentiality and other agreements to ensure your information is secure and treated with the utmost care and respect.  


7. Storage and retention of personal information

We also take reasonable steps to securely destroy or de-identify personal information where we no longer need it for the purpose for which we collected it and where it is not required by or under an Australian law, or court/tribunal order to retain that information. We keep personal information in physical and electronic records, at our premises and the premises of our service providers, which may include processing or storage in the cloud, which may mean in practice that this information is stored outside Australia. Where this occurs, we take steps to protect the security and integrity of personal information.

We may also keep records of our interactions with you (including by telephone, video conferencing, email and online).


8. Protection of personal information 

We protect personal information with appropriate safeguards and security measures and restrict access to those who have a legitimate business purpose and reason for accessing it.

All personal information collected by QIC is held securely, whether on QIC’s physical files, in QIC’s computer systems or in a database (which may be hosted by QIC or a third party on QIC’s behalf). This information is only made available to QIC’s staff on a 'need to know' basis for the purposes outlined above, or to other people as outlined in this Policy who have agreed to treat that information confidentially. These databases are protected by a firewall as well as host-based security.

Examples of the steps QIC takes to protect the security of the personal information we hold include:

  • sophisticated system security including:
    • Network controls for all devices of the QIC network such as firewalls, Intrusion Prevention, Anti-Virus, Web Application Firewall, Advanced Threat Detection, Data Loss Prevention, system hardening, Wireless Access Controllers and secure network design;
    • Two-factor authentication for remote access functionality; and
    • Advanced password protection controls;
  • comprehensive enterprise-wide staff awareness and education on privacy topics such as data governance, cyber-security, data breaches and phishing scenario testing;
  • ongoing monitoring and oversight where regular security assessments are performed on all critical IT assets, systems and third parties; and
  • destroying information when no longer required.

If other organisations provide support services on our behalf, we require them to take appropriate technical and organisational measures to secure the privacy of the information provided to them.

QIC has established processes for detecting potential privacy breaches and providing appropriate notification of personal data breaches that may cause harm to an individual or that may result in a risk to the rights or freedoms of an individual. Where required by law, we will provide such notification without undue delay to affected individuals and/or any relevant supervisory authorities.


9. Access or correct personal information 

At QIC, decisions and actions may be taken or made on the basis of personal information in our possession and we take reasonable steps to keep personal information as accurate, complete, and up-to-date as is necessary.

Should you, or your authorised representative, want to exercise your right to access, modify, correct, or restrict your personal information, we may ask you to put such a request in writing. We may require identification to ensure the person requesting access is entitled to such access. If you, or your representative, is denied access to your information, we shall provide reasons for the denial.

If we are reasonably satisfied our records need correcting, we will make the correction as soon as possible. If we do not agree our records need correcting, we will inform you of the reason(s) and you may require us to keep a statement on our records that you believe the information is inaccurate, incomplete, misleading, irrelevant or not up-to-date.

If you wish to access or correct your personal information, please contact the Centre Manager at the relevant QIC shopping centre (by using the ‘Contact Us’ feature on the homepage of the relevant Website) or the QIC Privacy Officer, whose details appear below.


10. Opt out of communications

We will not provide you with marketing communications unless you agree to receive such communications. If you change your mind about receiving marketing communications from us, you may easily request not to receive such communications by:

  • following the instructions on the communication to opt-out or unsubscribe from further communications;
  • contacting your usual QIC contact; or
  • emailing [email protected].


11. Make a complaint

If you have any questions, concerns or complaints about the treatment of your personal information, please contact the Centre Manager at the relevant QIC shopping centre (by using the ‘Contact Us’ feature on the homepage of the relevant Website) or our Privacy Officer by emailing [email protected]. We will respond to let you know who will be handling your matter and when you can expect a further response.

If you are unsatisfied with the resolution of your concerns, you may be able to escalate your complaint to the Office of the Australian Information Commissioner (“OAIC”) on 1300 363 992 or by email to [email protected]. You can also visit their website and obtain further information relating to Australian Privacy Legislation at www.oaic.gov.au.

QIC services covered by this Privacy Policy are targeted towards persons located in Australia. The OAIC website is an Australian based website. It is not intended to provide services to residents of the European Union, United Kingdom or any other overseas jurisdiction, and its terms may not be fully consistent with the privacy regulations that apply in overseas jurisdictions. If you are a resident of an overseas jurisdiction and you choose to use the OAIC website, then you do so at your own risk, and on the terms of the website.


12. Contact us

If you have any questions or comments about this Policy, please contact the QIC Privacy Officer by emailing [email protected].


13. Changes to our Privacy Policy

This Policy was last updated on 26 March 2024 and outlines our current privacy practices. We will take reasonable steps to publicise when we make changes to this policy through the channels available to us. You should also check this page, www.qicre.com/privacy-policy, from time to time for the most recent version of the policy.