Privacy Policy

River Precinct Pty Ltd, trading as River Precinct Management (“River Precinct”, “we”, “us” or “our”), respects the privacy of individuals whose personal information we collect, hold, use or disclose.

We are committed to managing personal information responsibly, transparently and securely.

Where applicable, we handle personal information in accordance with the Privacy Act 1988 (Cth), the Australian Privacy Principles (APPs) and other applicable Australian laws and regulatory requirements.

This Privacy Policy explains how River Precinct manages personal information in connection with our business, including our:

• building management and caretaking services;
• leasing and property management services;
• owner and investor communications;
• Body Corporate and committee dealings;
• contractor and supplier relationships;
• property and building operations;
• website and online enquiries;
• employment and recruitment activities; and
• other related business activities.

This Privacy Policy should be read together with any specific privacy collection notice provided when we collect personal information from you.

River Precinct Pty Ltd, trading as River Precinct Management.

Head Office: 82 Boundary Street, Brisbane City QLD 4000, Australia.

Email: hello@river-precinct.com.au. Telephone: 0494 618 977.

Personal information is information or an opinion about an identified individual, or an individual who is reasonably identifiable.

Depending on the circumstances, this may include information such as a person's name, residential address, email address, telephone number, identification information, financial information, employment details or information concerning their dealings with a property.

Some information may be considered sensitive information under Australian privacy law and is subject to additional protections.

We will only collect sensitive information where permitted by law and where it is reasonably necessary for our functions or activities, including where the individual has provided the required consent or collection is otherwise authorised or required by law.

The types of personal information River Precinct may collect and hold depend upon our relationship with you and the services being provided. This may include:

River Precinct seeks to limit the collection of personal information to information reasonably necessary for our business functions and activities.

Where reasonable and practicable, River Precinct collects personal information directly from the individual concerned.

We may collect personal information when you:

• contact us by telephone or email;
• submit an enquiry through our website;
• apply for or enter into a tenancy;
• engage us to manage a property;
• communicate with our onsite management team;
• attend or access a property under our management;
• submit a maintenance request;
• provide instructions as an owner or authorised representative;
• deal with us as a Body Corporate committee member or representative;
• engage with us as a contractor, supplier or professional adviser;
• apply for employment with River Precinct; or
• otherwise provide information to us.

We may also lawfully receive personal information from third parties where appropriate. These may include:

• property owners;
• authorised representatives;
• prospective or existing tenants;
• Body Corporates;
• Body Corporate managers;
• building committees;
• contractors;
• previous property managers;
• referees;
• employers;
• real estate platforms;
• professional advisers;
• government bodies;
• publicly available sources; and
• other persons involved in the management of a property.

Where required, we will take reasonable steps to ensure individuals are made aware of relevant collection circumstances.

From time to time, River Precinct may receive personal information that we did not request.

Where required by applicable privacy law, we will determine whether we could lawfully have collected that information.

If we could not have lawfully collected it and we are not otherwise legally required or authorised to retain it, we will take reasonable steps to destroy or de-identify the information.

River Precinct may collect, hold, use and disclose personal information where reasonably necessary for our business activities, including to:

• provide building management and caretaking services;
• provide leasing and property management services;
• manage relationships with owners and investors;
• process leasing enquiries and applications;
• manage tenancies;
• communicate with tenants, owners, committees, contractors and other relevant parties;
• manage rent, invoices, payments and accounts;
• arrange property inspections;
• manage maintenance and repairs;
• engage and manage contractors;
• manage building access and security;
• maintain building, property and access records;
• support Body Corporate or committee requirements;
• administer building projects and major works;
• respond to enquiries, requests and complaints;
• manage incidents and emergencies;
• comply with contractual obligations;
• protect people, property and assets;
• maintain appropriate business and legal records;
• operate and improve our website and systems;
• manage recruitment and employment;
• prevent or investigate suspected fraud, misuse or unlawful activity;
• manage disputes or legal matters;
• comply with Australian laws, court or tribunal orders and regulatory requirements; and
• perform other functions reasonably related to our business.

We generally only use or disclose personal information for the purpose for which it was collected, a related purpose reasonably expected in the circumstances, with appropriate consent, or where otherwise permitted or required by law.

Where River Precinct provides leasing or property management services, we may need to collect more detailed information about prospective or existing tenants.

This may include information required to assess an application, establish identity, confirm capacity to meet tenancy obligations, obtain references, prepare tenancy documentation, administer a tenancy or meet legal requirements.

Information may be obtained from applicants, referees, previous property managers, employers, property owners or other authorised sources.

We will only use this information for appropriate property management, leasing, verification, administrative, legal or related purposes.

We do not require individuals to provide information that is not reasonably necessary for the relevant purpose.

Where River Precinct acts for a property owner, we may collect and hold information including ownership details, instructions, correspondence, banking or payment information, property records, leasing information and financial information relating to the management of the property.

We may use this information to manage the property, undertake leasing activities, communicate with the owner, issue statements, arrange works, administer payments, meet legal obligations and provide our services.

Where River Precinct provides onsite building management or caretaking services, information may be collected in connection with the safe and effective operation of the building. This may include information relating to:

• access permissions;
• keys;
• electronic access devices;
• contractors;
• authorised visitors;
• building incidents;
• maintenance matters; and
• security events.

Where a building operates CCTV or other security systems, images or recordings may be collected in accordance with applicable laws, building policies and legitimate security or property management purposes.

Access to such information will be restricted to persons who reasonably require it for authorised purposes.

River Precinct does not adopt Australian government-related identifiers as its own identifiers except where permitted by law.

Where government-issued identification information is collected for legitimate identity verification or legal purposes, we seek to handle it only for authorised purposes and with appropriate security.

Where lawful and practicable, individuals may interact with River Precinct without identifying themselves or may use a pseudonym.

However, identification may be required where it is impracticable for River Precinct to deal with an individual anonymously or where identification is required or authorised by law.

For example, identification may reasonably be required for:

• tenancy applications;
• building access permissions;
• formal owner instructions;
• financial or payment matters;
• property transactions; or
• legal and regulatory requirements.

River Precinct may disclose personal information where reasonably necessary to carry out our business or meet legal requirements. Depending on the circumstances, recipients may include:

• property owners or their authorised representatives;
• Body Corporate committees;
• Body Corporate managers;
• building managers or authorised onsite staff;
• contractors and tradespeople;
• maintenance and service providers;
• real estate advertising and leasing platforms;
• professional advisers, including lawyers, accountants and consultants;
• insurers and insurance advisers;
• payment and financial service providers;
• technology, software, cloud, communications and data-storage providers;
• security and access-control providers;
• government departments;
• regulators;
• courts and tribunals;
• emergency services;
• law-enforcement agencies where lawfully required; and
• other persons where disclosure is authorised or required by law or appropriately consented to.

We seek to limit disclosures to information reasonably necessary for the relevant purpose.

River Precinct may engage third-party providers to assist us with:

• technology;
• website hosting;
• communications;
• property management systems;
• electronic records;
• payments;
• accounting;
• maintenance administration;
• cloud storage; and
• other business functions.

Where these providers handle personal information on our behalf, River Precinct seeks to select appropriate providers and take reasonable steps to protect the information consistent with applicable legal obligations.

Some technology, software, cloud-hosting or communications providers used by River Precinct may store, process or provide access to information from locations outside Australia.

Where personal information is disclosed to an overseas recipient and Australian privacy requirements apply, River Precinct will take reasonable steps as required by law in relation to that disclosure.

Where it is practicable to identify countries in which overseas recipients are likely to be located, River Precinct will identify those countries in this Privacy Policy.

When an individual uses the River Precinct website, certain technical information may be collected automatically. This may include:

• IP address;
• browser type;
• device information;
• approximate location;
• pages accessed;
• time spent on the website;
• referring website; and
• other technical information.

River Precinct may use cookies or similar technologies to:

• operate the website;
• remember preferences;
• maintain website security;
• understand website usage;
• measure website performance; and
• improve our digital services.

Where third-party analytics, advertising or tracking technologies are introduced, River Precinct will update its privacy disclosures and implement any consent mechanisms required by applicable law.

Users may be able to control certain cookies through their browser settings. Disabling some cookies may affect website functionality.

River Precinct may occasionally communicate with individuals about our services, property opportunities, business updates or information reasonably relevant to an existing business relationship.

We will only send direct marketing communications where permitted by applicable law. Where required, consent will be obtained.

Electronic commercial communications sent by or on behalf of River Precinct will identify the sender and provide a clear and functional means to unsubscribe.

Individuals may ask us at any time not to send further direct marketing communications. River Precinct will take reasonable steps to honour those requests within the period required by applicable law.

Our website may contain links to third-party websites, social media platforms or external services.

River Precinct does not control the privacy practices of external websites and is not responsible for how those third parties handle personal information.

Individuals should review the privacy policies of those services before providing personal information to them.

Information posted publicly to social media or other public platforms may be visible to other users and should not be treated as private.

River Precinct takes reasonable steps to ensure that personal information we collect is accurate, up to date and complete, and that information used or disclosed is relevant and sufficiently accurate for its intended purpose.

Individuals are encouraged to notify us if their personal information changes or if they become aware that information we hold is inaccurate.

River Precinct takes reasonable technical, physical and organisational measures to protect personal information from:

• misuse;
• interference;
• loss;
• unauthorised access;
• unauthorised modification; and
• unauthorised disclosure.

Depending on the information and systems involved, protective measures may include:

• controlled system access;
• authentication controls;
• passwords;
• access permissions;
• staff procedures;
• secure storage;
• appropriate backups;
• system monitoring; and
• security controls implemented by technology providers.

No electronic transmission or storage system can be guaranteed to be completely secure.

Where River Precinct becomes aware of a suspected security incident, we will take appropriate steps to investigate, contain and respond to the matter.

River Precinct retains personal information only for as long as it is reasonably required for our business activities, legal obligations, contractual obligations, dispute management or legitimate record-keeping requirements.

Retention periods may differ depending on the type of information and the purpose for which it is held.

Where personal information is no longer required for a lawful purpose and River Precinct is not required by law, court order or tribunal order to retain it, we will take reasonable steps to destroy the information or ensure it is appropriately de-identified.

River Precinct takes privacy and information-security incidents seriously.

If we become aware of a suspected data breach, we will take reasonable steps to investigate and assess the circumstances.

Where the Notifiable Data Breaches Scheme applies and a breach meets the legal threshold for an eligible data breach, River Precinct will notify affected individuals and the Office of the Australian Information Commissioner where required by law.

River Precinct may use technology and automated tools to assist with administrative functions, workflow management, communications, record management and data processing.

River Precinct does not intend technology to replace appropriate professional judgement where a decision could materially affect an individual's rights or interests.

Where River Precinct uses a computer program to make, or substantially assist in making, decisions using personal information and Australian privacy law requires disclosure of those arrangements, this Privacy Policy will be updated accordingly.

Subject to applicable law, individuals may request access to personal information River Precinct holds about them.

Requests may be made using the contact details provided in this Privacy Policy.

River Precinct may need to verify the identity of the person making the request before providing access.

In some circumstances, access may be refused or limited where permitted by law. Where required, River Precinct will provide appropriate reasons or notification where access is refused.

Individuals may ask River Precinct to correct personal information that they believe is:

• inaccurate;
• out of date;
• incomplete;
• irrelevant; or
• misleading.

River Precinct will take reasonable steps to consider correction requests in accordance with applicable law.

Where appropriate and required, River Precinct may also take reasonable steps to notify relevant third parties of a correction.

If you believe River Precinct has mishandled your personal information or has not complied with applicable privacy requirements, you may make a privacy complaint.

Privacy complaints should preferably be made in writing and include sufficient information for River Precinct to understand and investigate the matter.

Contact: Privacy Officer, River Precinct Management, 82 Boundary Street, Brisbane City QLD 4000, Australia. Email: hello@river-precinct.com.au. Telephone: 0494 618 977.

River Precinct will acknowledge and assess privacy complaints and will seek to respond within a reasonable period. Where appropriate, we will investigate the complaint, explain our findings and advise of any action taken.

If you are not satisfied with our response and applicable Australian privacy law provides a right to escalate the matter, you may be entitled to contact the Office of the Australian Information Commissioner.

River Precinct's corporate website is not specifically directed at children.

However, information concerning minors may occasionally be relevant to property management, tenancy, occupancy, access, emergency or building-management matters.

Where River Precinct handles information concerning minors, we seek to do so only where reasonably necessary and with appropriate regard to the circumstances, applicable laws and the interests of the individual concerned.

Nothing in this Privacy Policy prevents River Precinct from collecting, holding, using or disclosing information where required or authorised by Australian law, a court or tribunal order, or another legally permitted circumstance. This may include circumstances involving:

• health or safety;
• suspected unlawful activity;
• legal proceedings;
• law enforcement;
• regulatory requirements;
• emergencies; or
• other circumstances permitted by applicable law.

If River Precinct undergoes a corporate restructure, sale, acquisition, merger, transfer of management rights, transfer of business assets or similar transaction, personal information may form part of relevant business records.

Any handling of personal information in those circumstances will remain subject to applicable legal obligations.

River Precinct may update this Privacy Policy from time to time to reflect changes to:

• our services;
• our systems;
• our privacy practices;
• technology providers;
• business operations;
• legal obligations; or
• applicable privacy legislation.

The current version will be published on the River Precinct Management website together with the date on which it was last updated.

We encourage users to review this Privacy Policy periodically.

For privacy enquiries, access or correction requests, complaints or questions concerning this Privacy Policy, contact:

River Precinct Management — River Precinct Pty Ltd, 82 Boundary Street, Brisbane City QLD 4000, Australia.

E: hello@river-precinct.com.au. T: 0494 618 977.