VANTAGE PRIVACY POLICY

 

This Privacy Policy applies across the Vantage group of associated companies, including in relation our portfolio of properties that we manage and represent (Property and Properties), and the Vantage developments, Vantage fitouts or Vantage asset services business units.

 

For the purpose of this Privacy Policy, the Vantage group of associated companies is comprised of the following companies:

• Vantage PI Pty Ltd ACN 152 624 587;
• Vantage Property Investments Pty Ltd ACN 006 939 831;
• Vantage PI Management Pty Ltd ACN 006 245 914;
• Vantage Fitouts Pty Ltd ACN 158 934 895;
• Vantage Design Group Pty Ltd ACN 636 259 231;
• Vantage Property Holdings Pty Ltd ACN 622 582 254; and
• the special purpose vehicles that own the Properties (SPVs),

(together and separately (as applicable), Vantage, we us, our).

 

We have developed this Privacy Policy to inform you of how we manage the personal information that we collect about you.

 

By providing personal information to us, you are taken to have read, and consent to the collection, use disclosure and handling of your personal information in accordance with this Privacy Policy.

 

1. What personal information we collect about you and how we collect it

Personal information has the meaning given to that term in the Privacy Act 1988 (Cth) (Privacy Act) and includes information or an opinion (whether true or not) about an identified individual, or an individual who is reasonably identifiable.

We aim to collect personal information only if it is reasonably necessary to providing the service, product or information you have requested from us.

 

In the course of providing you with products and services, Vantage collects personal information in a variety of ways. Unless it is unreasonable or impracticable to do so, we collect your personal information from you directly, including by using cookies on our website.

In some cases however, we will collect information about you from a third party. For example, if you are an investor or potential investor in a Property, we may collect personal information about you from your lawyer, accountant or financial advisor.

 

If you supply goods or services to Vantage, or are a tenant at a Property (or you are an employee of a supplier or tenant) we may also collect personal information about you from your employer.

 

At the time of collection, or as soon as practicable after we have collected it, we will take such steps as are reasonable in the circumstances to notify you of the collection and of matters relevant to the collection, unless it is obvious from the circumstances that you would know or would expect us to have the information.

 

Vantage may collect personal information about you when you:

• are an investor or potential investor in a Property;
• engage with our business or its employees in relation to your investment or potential investment;
• engage us to provide services to your organisation or with a view to engaging us to provide  services;
• visit our website, www.vantagepi.com.au , www.vantagefitouts.com.au and www.vantagedesign.com.au;
• ask to be placed on one of our mailing lists; or
• supply goods or services to us.

 

In general, you can assume that we may collect the following personal information about you:

• name;
• address;
• email address;
• telephone number and other contact details;
• details about you to assist in managing our relationship with you; and
• details of the Properties or services we have provided to you or that you have enquired about, including any additional information necessary to deliver our services to you and respond to your enquiries.

 

If you are an investor or potential investor:

• we may also collect your date of birth, tax file number, your residency status for tax purposes, your banking details (that you provide to us) and whether you are a politically exposed person as per Chapter 1 of the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) (AML/CTF Act). We may also undertake identification checks; and

• and are subject to the United States Foreign Account Tax Compliance Act (FATCA), we may also collect additional information about you. We will notify you of this requirement at this time.

 

For each visitor to our Websites, we may also collect the following non-personally identifiable information:

• browser type, version and language;
• operating system;
• pages viewed while browsing the Websites; and
• page access times and referring website address.

 

2. How We Use Cookies

We may use cookies on some areas of our Websites. A cookie is a small file saved on your computer’s hard drive. When you return to our Websites, the data saved in the cookie is sent back to the website. We use cookies to gauge visitor traffic, trends and to help us serve you more efficiently if you revisit the Websites. The cookies we use in no way give us access to your computer or any information about you, other than the information you choose to share with us. You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of our Websites.

 

3. Purpose of collection

We collect personal information primarily to:

• contact you for business purposes and manage our relationship with your or your organisation;
• provide you with the goods, services and information that you request from us;
• provide you with information about Vantage’s Properties and services; and
• suggest Vantage products and services to you.

 

If you are an investor in a Property, Vantage also collects your personal information to establish and support the ongoing administration of the investments in the SPV in which you are an investor.

 

If it is reasonable to expect that we would use or disclose your personal information for purposes which are related to the above primary purposes, we may also use or disclose your personal information to:

• assist you with enquiries or complaints;
• develop and improve our client service and relationships;
• promote, advertise and market any of our products and services, including to invite you to seminars or events hosted by Vantage;
• comply with our legal obligations (including to comply with any law or any lawful request of a law enforcement agency or government authority), resolve any disputes that we may have with any of our clients and enforce our agreements with third parties such as your employer.

 

If you are an investor or potential investor, this includes our obligations arising under the AML/CTF Act or AML/CTF Rules, the Corporations Act 2001 (Cth) and generally in relation to Vantage PI Pty Ltd’s AFSL and ASIC requirements, requirements from our financiers and tax/audit requirements; and

• inform you of developments at Vantage and other services that we can provide.

 

We may use information collected through our Websites for the purpose of gauging visitor traffic, trends and delivering personalised content to you while you are at our Websites.

 

Where possible, we will provide you with a choice to opt-out of any of the above and any of our marketing communications. We will respect your request to decline to receive these marketing communications.

 

4. Sharing of your personal information

We may disclose your personal information to:

• external providers of services that we may use to operate our business and manage our business systems (for example, this may include file storage service providers, database and mailing service providers, marketing service providers, couriers and/or freight service providers, printers, call centres, providers of payment processing and identity verification services and IT technicians who may need access when providing on-site support (although it is our practice for them to work under supervision) and other professional service providers as required from time to time);
• our professional advisors and agents; or
• our existing or potential business partners.

 

We may disclose your personal information to these third parties so that they can assist us with providing the best possible service to you.

In addition to these disclosures:

• if you are an investor, we may also disclose your personal information to the Australian Tax Office and the Australian Securities and Investments Commission, AUSTRAC, our external accountant, financiers and international governments with which Australian has a tax treaty;
• if you supply goods or services to Vantage, we may disclose your personal information to tenants in our Properties; and
• if you are a tenant in a Property or a supplier to Vantage, (or you are an employee of a supplier or tenant) we may also disclose your information to suppliers or other third parties that assist us in managing the Property including to CBRE Group Inc.

 

Those people or companies will be permitted to access only the personal information they need to deliver the service to Vantage or to you. Vantage takes reasonable steps to ensure that these organisations are bound by confidentiality and privacy obligations in relation to the protection of your personal information.

 

If you are an investor that is subject to FATCA, we may share your personal information with the United States Internal Revenue Services (IRS). If you are a tenant in a Property or a supplier to Vantage, by disclosing personal information to CBRE Group Inc, we may also disclose your personal information to the United States. When you provide us with your personal information you give us your consent to disclose your personal information outside of Australia for the purposes described above and acknowledge that we are not required to ensure that overseas recipients handle that personal information in compliance with the Privacy Act.

 

We are not otherwise likely to disclose information to overseas recipients unless it is with your consent, or the disclosure is required or authorised by law (including any tax treaty with an overseas government to which Australia is a party).

 

The privacy and collection practices of entities to which we disclose personal information are governed by their own privacy policies and collection notices.

 

We will not otherwise disclose information about you unless the disclosure:

• is required or authorised by law; or
• you have consented to our disclosing the information about you.

 

5. Quality of your personal information

We aim to ensure that your personal information is accurate, complete and up to date. To assist us in this, you need to provide true, accurate, current and complete information about yourself as requested and properly update the information to us to keep it true, accurate, current and complete.

 

If you believe that the information we hold is inaccurate or incomplete, please contact us and we will use all reasonable efforts to correct the information.

 

If we do not believe the information to be incorrect, we will take reasonable steps to add a statement to the information claiming that you believe the information is inaccurate, incomplete or out of date.

 

6. Securing your personal information

We may hold your personal information in electronic or hard copy form. We will take reasonable precautions to protect your personal information from misuse, interference and loss, as well as from unauthorised access, modification or disclosure. We use a number of physical, administrative, personnel and technical measures to protect your personal information.

We take reasonable steps to destroy or permanently de-identify personal information if it is no longer needed.

 

7. Changes to this Privacy Policy

Vantage reserves the right to make amendments to this Privacy Policy at any time for any reason. We will publish any updated Privacy Policy on our Websites.

 

8. Accessing and correcting your personal information

You have a right to request access to, or the correction of, your personal information that we hold about you, subject to exceptions allowed by law. You may be required to put your request in writing for security reasons.

We will give you access to, or correct, your personal information unless there is a lawful reason for refusing your request for access or correction. If we refuse your request we will give you a written notice explaining our reasons for that refusal and how you may complain about that refusal.

 

9. Change in control of Vantage

If we sell or otherwise transfer part or the whole of Vantage or our business to another organisation (including in the course of a transaction like a sale, merger or acquisition or as part of a dissolution, liquidation, administration, receivership or other form of insolvency), you agree that your personal information that is collected by Vantage may be disclosed to a third party, prospective buyer, transferee or insolvency practitioner and that this is reasonable to enable that party to continue or manage the business.

 

10. Complaints

If you have a complaint about our collection, use or disclosure of your personal information, or you wish to make a complaint about a breach of the APPs, please contact our Privacy Officer at the details set out below.

In your complaint, please set out the details of your complaint and your contact details. Our Privacy Officer will contact you to acknowledge your request and ask for any other applicable information. Our Privacy Officer will then investigate the issue and advise you in writing of the outcome.

You can also make a complaint to the Office of the Australian Information Commissioner. Further information is available at www.oaic.gov.au.

 

11. Contacting us

If you have any questions about this Privacy Policy or our privacy practices, would like to make a complaint or request access to or correction of your personal information, please contact us by any of the following means.

 

Our contact details in respect of any issues in relation to privacy are:

Telephone 03 9820 0200

Email  info@vantagepi.com.au

Post PO Box 33347, Melbourne  VIC  3004

 

 

 

 

VANTAGE COLLECTION NOTICE – Non-Investors (suppliers and tenants)

 

This Collection Notice sets out the matters described in Australian Privacy Principle (APP) 5.2 (as part of the Privacy Act 1988 (Cth)) as they relate to the Vantage group of associated companies, when we collect personal information about you.

For the purpose of this Collection Notice, the Vantage group of associated companies is comprised of the following companies:

• Vantage PI Pty Ltd ACN 152 624 587;
• Vantage Property Investments Pty Ltd ACN 006 939 831;
• Vantage PI Management Pty Ltd ACN 006 245 914;
• Vantage Fitouts Pty Ltd ACN 158 934 895;
• Vantage Design Group Pty Ltd ACN 636 259 231;Vantage Design Group Pty Ltd ACN 636 259 231;
• Vantage Property Holdings Pty Ltd ACN 622 582 254; and

• the special purpose vehicles that own the properties that we manage and represent (Property or Properties),

(together and separately (as applicable), Vantage, we us, our).

If you are an investor or potential investors in a Property, please see our investor specific Collection Notice.

 

1 Purpose of Collection

We collect personal information primarily to:

• contact you for business purposes and manage our relationship with your or your organisation;
• provide you with the goods, services and information that you request from us;
• provide you with information about Vantage’s Properties and services; and
• suggest Vantage products and services to you.

 

If it is reasonable to expect that we would use or disclose your personal information for purposes which are related to the above primary purposes, we may also use or disclose your personal information to:

• assist you with enquiries or complaints;
• develop and improve our client service and relationships;
• promote, advertise and market any of our products and services, including to invite you to seminars or events hosted by Vantage;
• comply with our legal obligations (including to comply with any law or any lawful request of a law enforcement agency or government authority), resolve any disputes that we may have with any of our clients and enforce our agreements with third parties such as your employer;
• inform you of developments at Vantage and other services that we can provide.

 

We may use information collected through our Websites (defined below) for the purpose of gauging visitor traffic, trends and delivering personalised content to you while you are at our Websites.

Where possible, we will provide you with a choice to opt-out of any of the above and any of our marketing communications. We will respect your request to decline to receive these marketing communications.

 

2 Type of personal information collected and consequences if personal information is not collected

In general, you can assume that we may collect the following personal information about you:

• name;
• address;
• email address;
• telephone number and other contact details;
• details about you to assist in managing our relationship with you; and
• details of the Properties or services we have provided to you or that you have enquired about, including any additional information necessary to deliver our services to you and respond to your enquiries.

 

For each visitor to our Websites, we may also collect the following non-personally identifiable information:

• browser type, version and language;
• operating system;
• pages viewed while browsing the Websites; and
• page access times and referring website address.

 

If you do not provide the necessary personal information, we may not be able to provide you or your employer with the goods, services or information that you have requested from us.

 

3 How we collect personal information

In the course of providing you with products and services, Vantage collects personal information in a variety of ways. Unless it is unreasonable or impracticable to do so, we collect your personal information from you directly, including by using cookies on our Websites.

In some cases however, we will collect information about you from a third party. For example, if you supply goods or services to Vantage, or are a tenant at a Property (or you are an employee of a supplier or tenant) we may also collect personal information about you from your employer.

 

At the time of collection, or as soon as practicable after we have collected it, we will take such steps as are reasonable in the circumstances to notify you of the collection and of any matters relevant to the collection, unless it is obvious from the circumstances that you would know or would expect us to have the information.

 

In general, we collect personal information about the following people:

• tenants of the Properties; and
• suppliers of goods and services to Vantage and our Properties, and employees of suppliers.

 

Vantage may collect personal information about you when you:

• engage us to provide services to your organisation or with a view to engaging us to provide  services;
• visit our websites, www.vantagepi.com.au , www.vantagefitouts.com.au and www.vantagedesign.com.au
• ask to be placed on one of our mailing lists; or
• supply goods or services to us.

 

4 Sharing of your personal information

We may disclose your personal information to:

• external providers of services that we may use to operate our business and manage our business systems (for example, this may include file storage service providers, database and mailing service providers, marketing service providers, couriers and/or freight service providers, printers, call centres, providers of payment processing and identity verification services and IT technicians who may need access when providing on-site support (although it is our practice for them to work under supervision) and other professional service providers as required from time to time);
• our professional advisors and agents; or
• our existing or potential business partners.

 

We may disclose your personal information to these third parties so that they can assist us with providing the best possible service to you.

In addition to these disclosures:

• if you supply goods or services to Vantage, we may disclose your personal information to tenants in our Properties; and
• if you or are a tenant in a Property or a supplier to Vantage (or you are an employee of a supplier or tenant) we may also disclose your information to suppliers or other third parties that assist us in managing the Property, including to CBRE Group Inc.

 

Those people or companies will be permitted to access only the personal information they need to deliver the service to Vantage or to you.

Vantage takes reasonable steps to ensure that these organisations are bound by confidentiality and privacy obligations in relation to the protection of your personal information.

 

If you are a tenant in a Property or a supplier to Vantage, by disclosing personal information to CBRE Group Inc, we may also disclose your personal information to the United States. When you provide us with your personal information you give us your consent to disclose your personal information outside of Australia for the purposes described above and acknowledge that we are not required to ensure that overseas recipients handle that personal information in compliance with the Privacy Act. We are not otherwise likely to disclose information to overseas recipients unless it is with your consent, or the disclosure is required or authorised by law.

 

The privacy and collection practices of entities to which we disclose personal information are governed by their own privacy policies and collection notices.

We will not otherwise disclose information about you unless the disclosure:

• is required or authorised by law; or

• you have consented to our disclosing the information about you.

 

5 Privacy Policy

Vantage understands that you value your privacy and wish to have your personal information kept secure. For these reasons, we place a high priority on the security of the personal information that we hold. Vantage has developed a Privacy Policy to inform you of how we manage your personal information and maintain its integrity and security.

Vantage’s Privacy Policy is available for you to access on our Websites and can be accessed here.

 

Our Privacy Policy contains information about how you may access the personal information that we hold about you and seek the correction of such information, if you believe it to be incorrect.

 

The Privacy Policy also contains information about how you may complain about a breach of the APPs and how we will deal with such a complaint.

 

6 Contact Us

Our contact details in respect of any issues in relation to privacy are:

Telephone 03 9820 0200

Email  info@vantagepi.com.au

Post PO Box 33347, Melbourne VIC 3004

 

 

 

VANTAGE COLLECTION NOTICE - Investors/Potential Investors

 

This Collection Notice sets out the matters described in Australian Privacy Principle (APP) 5.2 (as part of the Privacy Act 1988 (Cth)) as they relate to the Vantage group of associated companies, when we collect personal information about investors or potential investors (Investor) in the special purpose vehicles (SPVs) that own the properties that we manage and represent (Property or Properties).

 

For the purpose of this Collection Notice, the Vantage group of associated companies is comprised of the following companies:

• Vantage PI Pty Ltd ACN 152 624 587;
• Vantage Property Investments Pty Ltd ACN 006 939 831;
• Vantage PI Management Pty Ltd ACN 006 245 914;
• Vantage Fitouts Pty Ltd ACN 158 934 895;
• Vantage Design Group Pty Ltd ACN 636 259 231;
• Vantage Property Holdings Pty Ltd ACN 622 582 254; and
• the SPVs that own the Properties (Property or Properties),

(together and separately (as applicable), Vantage, we us, our).

If you are not an investor or potential investors in a Property, please see our investor specific Collection Notice.

 

1 Purpose of Collection

We collect your personal information primarily to:

• establish and support the ongoing administration of the investments in the SPV in which you are an investor;
• contact you for business purposes and manage our relationship with your;
• provide you with information about Vantage’s Properties and services; and
• suggest Vantage products and services to you.

 

If it is reasonable to expect that we would use or disclose your personal information for purposes which are related to the above primary purposes, we may also use or disclose your personal information to:

• assist you with enquiries or complaints;
• develop and improve our client service and relationships;
• promote, advertise and market any of our products and services, including to invite you to seminars or events hosted by Vantage;
• comply with our legal obligations (including to comply with any law or any lawful request of a law enforcement agency or government authority), resolve any disputes that we may have with any of our clients and enforce our agreements with third parties such as your employer.

 

This includes our obligations arising under the AML/CTF Act or AML/CTF Rules, the Corporations Act 2001 (Cth) and generally in relation to Vantage PI Pty Ltd’s AFSL and ASIC requirements, requirements from our financiers and tax/audit requirements; and

• inform you of developments at Vantage and other services that we can provide.

 

We may use information collected through our websites for the purpose of gauging visitor traffic, trends and delivering personalised content to you while you are at our websites.

 

Where possible, we will provide you with a choice to opt-out of any of the above and any of our marketing communications. We will respect your request to decline to receive these marketing communications.

 

2 Type of personal information collected and consequences if personal information is not collected

In general, you can assume that we may collect the following personal information about you:

• name;
• address, email address, telephone number and other contact details;
• date of birth;
• tax file number;
• your residency status for tax purposes, your banking details (that you provide to us) and whether you are a politically exposed person as per Chapter 1 of the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) (AML/CTF Act);
• details about you to assist in managing our relationship with you; and
• details of the Properties or services we have provided to you or that you have enquired about, including any additional information necessary to deliver our services to you and respond to your enquiries.

 

If you are subject to the United States Foreign Account Tax Compliance Act (FATCA), we may also collect additional information about you. We will notify you of this requirement at this time.

 

If you do not provide the necessary personal information, we may not be able to provide you with the goods, services or information that you have requested from us.

 

3 How we collect personal information

In the course of providing you with products and services, Vantage collects personal information in a variety of ways. Unless it is unreasonable or impracticable to do so, we collect your personal information from you directly, including by using cookies on our website.

In some cases however, we will collect information about you from a third party, including from your lawyer, accountant or financial advisor.

At the time of collection, or as soon as practicable after we have collected it, we will take such steps as are reasonable in the circumstances to notify you of the collection and of any matters relevant to the collection, unless it is obvious from the circumstances that you would know or would expect us to have the information.

 

4 Sharing of your personal information

We may disclose your personal information to:

• external providers of services that we may use to operate our business and manage our business systems (for example, this may include file storage service providers, database and mailing service providers, marketing service providers, couriers and/or freight service providers, printers, call centres, providers of payment processing and identity verification services and IT technicians who may need access when providing on-site support (although it is our practice for them to work under supervision) and other professional service providers as required from time to time);
• our professional advisors and agents;
• the Australian Tax Office and the Australian Securities and Investments Commission, AUSTRAC, our external accountant, financiers and international governments with which Australian has a tax treaty; and
• our existing or potential business partners.

 

We may disclose your personal information to these third parties so that they can assist us with providing the best possible service to you.

 

Those people or companies will be permitted to access only the personal information they need to deliver the service to Vantage or to you. Vantage takes reasonable steps to ensure that these organisations are bound by confidentiality and privacy obligations in relation to the protection of your personal information.

 

If you are an investor that is subject to FATCA, we may share your personal information with the United States Internal Revenue Services (IRS). When you provide us with your personal information you give us your consent to disclose your personal information outside of Australia for the purposes described above and acknowledge that we are not required to ensure that overseas recipients handle that personal information in compliance with the Privacy Act.

 

We are not otherwise likely to disclose information to overseas recipients unless it is with your consent, or the disclosure is required or authorised by law (including any tax treaty with an overseas government to which Australia is a party).

The privacy and collection practices of entities to which we disclose personal information are governed by their own privacy policies and collection notices.

 

We will not otherwise disclose information about you unless the disclosure:

• is required or authorised by law; or
• you have consented to our disclosing the information about you.

 

5 Privacy Policy

Vantage understands that you value your privacy and wish to have your personal information kept secure. For these reasons, we place a high priority on the security of the personal information that we hold. Vantage has developed a Privacy Policy to inform you of how we manage your personal information and maintain its integrity and security.

 

Vantage’s Privacy Policy is available for you to access on our website and can be accessed here .

 

Our Privacy Policy contains information about how you may access the personal information that we hold about you and seek the correction of such information, if you believe it to be incorrect.

 

The Privacy Policy also contains information about how you may complain about a breach of the APPs and how we will deal with such a complaint.

 

6 Contact Us

Our contact details in respect of any issues in relation to privacy are:

Telephone 03 9820 0200

Email  info@vantagepi.com.au

Post PO Box 33347, Melbourne VIC 3004