In this Policy, ‘we’, ‘us’, or ‘our’ refers to the Colliers Real Estate Managed Property, Highbury Shopping Centre website.
We are committed to comply and protect your information in accordance with the privacy principles set out in The Privacy Act 2020 which define the rules pertaining to the collection, storage, security, accuracy, use and disclosure of personal information. It also encompasses individual’s rights to access and correct their personal information. It will be collected for lawful purposes connected with a function or activity carried out by the property.
Providing your personal information or using collection of information through use of services or entry into competitions, you agree to this.
1. Collection of information
Personal information is collected, where applicable, to inform of upcoming events, activities, promotions and ensure full enjoyment of the property by staff, retailers, contractors, sponsors and customers alike.
Where CCTV cameras are operational within the centre or on the property, recordings are the property of the centre and we retain all rights to record and store camera footage. This is to maintain safety and security of the property and its occupants.
We will only use this information for the purposes for which it is intended and collected. In relation to information you have supplied and authorised, you may unsubscribe at any time by following the unsubscribe instructions contained in the message.
Collection can be by way of (inclusive but not limited to):
- Website registration and the collection of information through the required fields through the online form.
- Use of mobile applications and third-party applications within the centre including those that utilise the centre’s infrastructure, including Bluetooth beacon networks and Wifi logins.
- Centre competitions where your details are entered into the database as a competition entry requirement.
- Services hire for mobility aids or other equipment from the centre for records of the hirer
- The purchase, redemption and online activity from centre gift cards.
- Our retailers operating within the centre
- Carpark information, where the centre carpark is under video/camera surveillance. Personal information, car licence plate details and images may be collected directly or from third parties relating to the management and security of the premises and visitors to the property.
- Website traffic and behaviour through use of the centre’s website, including content accessed and services utilised, through use of log files or cookies.
Aggregated information is generated automatically by our online systems. This includes statistical tracking information used for analysis to enable us to analyse traffic, behaviour and patterns for the purpose of improving the centre’s website. Such information is inclusive of, but not limited to the numbers of visitors and visits to the website, time, date, pages and navigation of visit, location based on IP address country of origin, systems users access the site and leads from other sites. It does not individually identify users and is used for statistical purposes only.
Whilst logged in we may collect visitor’s data and information. We own this information and use it to verify visitor behaviour to make improvements.
This includes information pertaining to/collected from:
- Devices connected to or indefinable by centre infrastructure (such as Centre WiFi networks or blue tooth transmitter (beacon) infrastructure) where we or third-party providers automatically collect key statistical data from your devise across location, usage, type of devise, movement around centre and consented data from signing in to access.
- Measured consumer data, passively collected from centre technologies to provide visitor information. audience measurement information collected passively using in centre technologies such as SmartScreen Advertising Units which utilise image processing software to aggregate data such as shopper numbers and demographics. These technologies do not identify individual shoppers, or record or retain images of individual shoppers.
- URLs and Mobile Apps which are accessed leading to the centre website or accessed through the centre WiFi can be collected
- Publicly accessible social media and networking posts. This includes any personal information you allow us to collect by linking your account on our website with a third-party social-networking site including but not limited to Facebook, Twitter, or Google+;
Collection and analysis of this information is used for marketing and communications to provide a better service, more desirable activations and promotions for visitors; statistical visitor information to owners, potential retailers and management teams.
2. Use of information
We use your personal information for the purposes of:
- Identifying visitor’s use and patterns to understand service requirements, mapping journeys and best meeting needs.
- Verifying visitor’s use of our website, to conduct address verification and to enrich your profile and search ability.
- Improving our website to provide information on the centre, it’s retailers or related companies, that may be of interest.
- Communicating marketing, promotional and publicity activity including direct marketing and marketing research.
- Presenting advertising and information that is most relevant to you and your interests.
- Analysis in aggregate form (identifiable characteristics removed so that you will remain anonymous).
- Enforcing our contractual rights.
- Complying with our financial, regulatory and other legal obligations.
- In all circumstances we will take all reasonable steps to ensure that our use of your personal information is compliant with all applicable New Zealand Legislation.
- Any other purpose which is stated to you at the time of collection or that you otherwise authorise.
3. Sharing and Disclosure of Information
To the extent permitted by law, we may share your information to a third party relating to the management and of the centre and/or security of the premises and visitors, staff, guests and contractors to the property. In the instance where we contract marketing activity to a third-party, they would be privy to personal information but bound through contract with Highbury Shopping Centre .
This information can be passed on to law enforcement and governing bodies, centre staff, subcontractors, third parties, insurers and retailers.
Personal information will only further be shared, should we
- Have your permission to do so by agreeing to the disclosure and used for the intended purposes you agreed to.
- Receive a nomination from a friend whereby we send an email on behalf of your friend.
- Respond to a request of information when you enquire about our services, you will be added to receive further information pertaining to this.
- Be required by our contractors, enabling them to provide their service so we can complete a transaction on your behalf
- Receive a lawful request from any law enforcement agency including facilitating court proceedings or to protect our rights, the property or the safety of persons, public or government authorities, courts or regulatory agencies.
- Need to for safety, security and information assurance purposes.
- See fit to disclose for marketing review and improvements for business partners or where necessary for third parties to offer products or services that may be of interest
- Require functionality and/or SIML, for legal and auditing purposes.
In all circumstances we will take all reasonable steps to ensure that where your personal information is disclosed to third parties they only use your personal information to the extent necessary to perform their function and that their use of your personal information is compliant with all applicable New Zealand legislation. However, we are not in anyway responsible for the privacy policies of any third parties or the way in which they hold or use personal information.
4. Storage of Information
All personal information is held in a database which we take all reasonable measures and precautions to protect by a firewall and host-based security. It will have transmitted over the Internet from this database and may cross international borders, where in doing so is part of our business practises relating to the storage and transfer of data as permitted by law. Original documentation such as an entry form or any additional information to verify identity, will be destroyed.
5. Your Rights
We will take all reasonable steps to ensure personal information we hold is accurate.
You can unsubscribe from receiving any communications and removing yourself from the active database at any time, by clicking ‘unsubscribe’ at the bottom of emails newsletters.
You have the right to ask for a copy of any personal information we hold about you, and to ask for it to be updated or corrected if you think it is wrong. Following your request, we will consider if the information requires amendment. If we disagree, acting reasonably, that there are grounds for amendment, we will add a note to the personal information stating that you disagree with it.
If you would like a copy of your information, have it corrected or withdrawn, please e-mail the centre directly at firstname.lastname@example.org .
Where the use of your personal information is based on consent you have previously given, you have the right to withdraw your consent.
You should contact us immediately if you believe we have breached your privacy or have any concerns so that we can investigate it. We have a formal procedure in place in relation to investigating and dealing with privacy breaches. We aim to ensure that all complaints are investigated and dealt with within a reasonable time and will notify you of the outcome of any investigation.
If there has been a breach, we will endeavour to determine the nature of the breach and how it occurred. In order to conduct the investigation, it may be necessary to contact you to obtain further information or clarification.
If a breach has been found, we will review our processes and policies to prevent similar future breaches occurring.
We take reasonable steps to ensure that the personal information provided is kept securely and comply with all applicable New Zealand law in this regard including having in place various organisational, technical and administrative measures and systems which are designed to protect your personal information. These measures and systems aim to protect your personal information held by us against unauthorised access, destruction, loss, alteration or misuse. Whilst we take every reasonable precaution to protect your information you should contact us immediately if you have any reason to believe that any of your personal information is no longer secure or has been compromised in any way.
7. Advertising and Third-Party Links
8. Business Transactions
If ownership of the website or any of its portions changes, your user information may be transferred to the new owner, so the website can continue operations with the Privacy Policies still applicable.
10. Contact Details
11. Protection of your details
While we make every effort to guard your privacy and secure the personal data we receive, however when you provide us with information, you do so at your own risk. Due to the nature of the Internet and email systems, we are unable to guarantee the privacy and confidentiality of your personal information while it is transmitted over the Internet.
Please take measures to protect your information by always closing your browser on completion of sessions and protect your personal information and emails especially when you use a public computer.
Please contact us immediately should you be concerned that someone has gained access to your personal information or we have breached our privacy obligations or your privacy rights. We are happy to discuss any issues with you.