Precinct Properties Privacy Policy

Updated 1 August 2023

1. Background

1.1. This Privacy Policy sets out how we collect, use, store and disclose your information. When we refer to "Precinct", "we", "us" or "our" in this Privacy Policy, we mean Precinct Properties New Zealand Limited and its related companies.

1.2. We take our obligations in relation to your information seriously and we are committed to protecting your information and ensuring we comply with all relevant privacy laws, including the Privacy Act 1993.

1.3. By using our services, you agree to this Privacy Policy. If you do not agree, you may not be able to access Precinct's services.

1.4. Precinct may change this Privacy Policy from time to time, for example, if we offer new services or where we need to change how we use your information in order to improve our services. We will tell you about changes by posting a notification about the updated Privacy Policy and when the changes will take effect. By continuing to use our services after notification of any changes, you agree to any changes to the Privacy Policy.

2. What information do we collect about you?

2.1. We collect your information for lawful purposes connected to our functions or activities, for purposes directly related to this or where you have agreed we can do so. Information we may collect includes:

2.1.1. your name, gender, date of birth, contact details or information;

2.1.2. credit card details and proof of identity or age, for example, when you use online ordering food and beverage services, including via our apps;

2.1.3. your image in public spaces at Precinct properties (via CCTV);

2.1.4. public social media account or page details;

2.1.5. vehicle licence number, and vehicle location and movements on our properties and in public areas to which we have visibility;

2.1.6. information about your use of our properties or services or of retailers operating in our properties;

2.1.7. information about your engagement with marketing, promotions or offers available at Precinct properties (whether offered by us or a retailer operating at Precinct properties);

2.1.8. location and movements of people in our public spaces before, during and after entry into Precinct properties (including live locations) - we collect this on an aggregated basis so that we are not able to identify you specifically. This information helps us understand how people move through our properties so we better tailor our services and premises;

2.1.9. your communications with us (which may include recordings of telephone conversations, emails and other written communications);

2.1.10. analytics information including your IP address, internet usage and website activity; and

2.1.11. any other information you provide to us from time to time.

3. How do we collect your information?

3.1. We collect information from you, including information you provide via mobile apps, website, telephone, by email, via our social media platforms or when you enter our promotions. Please be aware that we may collect some of your information through CCTV cameras, which we use for general security purposes. We may also collect your information from anyone you have authorised, retailers operating in our centres, from other third parties where that information is publicly available or where it is otherwise permitted by the Privacy Act.

3.2. We use cookies (and other tools which perform similar functions, like beacons, local storage and universal tokens) to gather and store information about your use of our services. These tools do not identify you directly but the information collected will be linked to a unique user identifier code that is assigned to you. This allows us to use the information collected by the tools to understand more about your viewing habits and interests, and helps us to deliver our services to you.

3.3. If you give us any information about anyone else, you must have their consent to give us the information before you do so.

3.4. We may use a third party application to collect personal information from you in order to understand your location and shopping behaviour at Precinct properties. You authorise such collection and use, which will be in accordance with this Privacy Policy.

4. How do we use your information?

4.1. We use your information only for purposes you have agreed to, for purposes directly related to our functions or activities or where we are authorised to under the Privacy Act.

4.2. We may use your information for the following reasons:

4.2.1. to manage health and safety within our properties, including pedestrian traffic flows;

4.2.2. to provide our services to you including our centre maps and directories, wireless service and parking services;

4.2.3. to help us offer, manage, improve and promote our services and operations and those of retailers operating at Precinct properties;

4.2.4. to understand and analyse how you engage with services, products, offers, events or other benefits offered by us or retailers operating at Precinct properties;

4.2.5. to notify you of services, products, offers, events or other benefits offered by us, retailers operating at our properties or our business partners that we think may be of interest to you;

4.2.6. to conduct market research and to contact you with market, research or survey communications;

4.2.7. to process transactions and administer accounts you have with us or retailers operating at our properties;

4.2.8. for the prevention, detection, investigation and analysis of incidents and offences in and around our properties and for general security purposes;

4.2.9. track traffic patterns to and from and across our sites such as the pages you visit, the time you spend on each page, the date and time of your visit, and referring pages (pages you came from or go to); and

4.2.10. ensure appropriate advertising is being shown, based on this data and limit the frequency of display for certain ad formats; and

4.2.11. any other purposes you agree to.

4.3. We may also use third parties (including Google, Meta and other digital tag and tracking providers) to capture, track and analyse our user information and help us manage and optimise business decisions, including marketing communications. These companies take information about visits to our sites to assist us with analysing the site's performance and the effectiveness of advertising so we can optimise our services for users, retailers and advertisers.

5. Marketing communications

5.1. You consent to us, retailers at our properties or our business partners, sending you information connected with the above collection and use purposes via email or text message when you provide us with your email address and/or mobile phone number. You may be sent other information we think you may be interested in and which may market and promote our products and services, or the products and services of retailers operating in our properties or those of our business partners. The messages you receive from Precinct will have instructions for how you can remove yourself from our mailing list.

5.2. Email marketing will only be sent to your email address if you have given your consent. You may unsubscribe to any email marketing message at any time by following the unsubscribe instructions contained in the message.

6. Who do we give your information to?

6.1. We will only disclose your information where you have authorised such disclosure, where disclosure is connected to one of our functions or activities or where we are able to under the Privacy Act.

6.2. Examples where we may disclose your information are:

6.2.1. to service providers in order to provide our services to you;

6.2.2. to retailers at Precinct properties or our business partners for promotional, marketing, publicity, research and profiling purposes to the extent permitted by law. Where we do this, your information is aggregated with that of other visitors to our properties, so retailers and business partners will not be able to identify you;

6.2.3. to law enforcement agencies for the purposes of prevention, detection, investigation and analysis of incidents or offences in and around our centres (including law enforcement agencies having live-feed access to our CCTV cameras);

6.2.4. to meet our legal obligations;

6.2.5. in order for us to sell any of our assets and parts of our business; and

6.2.6. for legal or auditing purposes.

6.3. Where we share your information, we will take reasonable steps to prevent the unauthorised use or disclosure of your information.

7. How do we store your information?

7.1. We take reasonable steps to ensure that your information is protected against loss, unauthorised access and other misuse. We adopt policies and procedures to protect your information, and we review these regularly.

8. How can you control cookies and the cookie information we collect?

8.1. Most browsers accept cookies automatically but you can choose to refuse cookies by turning them off in your browser and/or deleting them from your hard drive. You do not need to have cookies turned on to use our websites, but you may need them for customisable areas of sites we may develop in the future. If your cookies are turned off we will not have any control over the frequency of display of certain ad formats. This could affect your browsing experience. Additionally, you can consider utilizing your browsers “Private Browsing” feature to prevent cookies being stored long term. Modern web browsers offer private browsing features such as "Incognito Mode" in Chrome or "Private Browsing" in Safari.

9. Access to, correction, modification and deletion of your information

9.1. We take reasonable steps to ensure that the information we hold about you is accurate. You have the right at any stage to request us to provide you with access to your information. We will respond to any request by you to correct or access your information as soon as practicable following receipt of such request, but there are exceptions under the Privacy Act where we may not be able to do so. We will tell you if that is the case.

9.2. If you have any questions or requests for your information, please contact us at companysecretary@precinct.co.nz. If you would like more information about privacy in general, please refer to the Privacy Commissioner’s website: www.privacy.org.