Privacy Policy

PRIVACY POLICY

This website and associated applications, including the 1 Denison mobile application, are operated by Winten Property Group (“Winten”, “we”, “us” or “our”). The 1 Denison mobile application is a white-label platform provided by VTS & CBRE Property and is subject to a separate privacy policy, which is available to registered users within the application. We acknowledge the importance of protecting your privacy and recognise that the provision of personal information is an act of trust. This Privacy Policy sets out how we collect, hold, use and disclose your personal information.

By using our website, applications or services, you agree to the terms of this Privacy Policy.

Legal Framework

This Privacy Policy is prepared in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs), which govern how personal information is handled in Australia.

Where relevant, we also comply with applicable state legislation relating to security, surveillance and workplace safety.

We take reasonable steps to ensure that our handling of personal information is consistent with these laws, including requirements relating to transparency, security and individuals’ rights to access and correct their information.

Defined Terms

In this Privacy Policy:

  • Personal information means information or an opinion about an identified individual, or an individual who is reasonably identifiable.
  • Sensitive information has the meaning given under the Privacy Act.
  • We, us, our refers to Winten Property Group and its related entities.
  • Building means 1 Denison Street, North Sydney, including all associated facilities.
  • Services include building operations, tenancy management, concierge services, membership programs, wellness and end-of-trip facilities, and digital platforms (including the 1 Denison app).
  • Access control systems are systems used to control or monitor access to the building (including card or mobile access).
  • You / your means any individual whose personal information we collect, including tenants, visitors, contractors, customers and service providers.

Why we collect personal information

The purposes for which we use personal information depend on the dealings you may have with us, and these purposes may differ for tenants, visitors, customers, service providers and job applicants.

Types of Personal Information We Collect

We may collect the following types of personal information, depending on your interaction with us:

  • Identification and contact information (such as name, email address, phone number and contact details through web or email forms)
  • Access and security information (including access card records, entry times, CCTV footage and visitor logs, if you are an employee at 1 Denison)
  • Location information (including where access or services are requested within the Building)
  • Transaction and payment information (including purchase history or payment details, when using the CBRE building app to purchase)
  • Usage and interaction data (including how you interact with our website, applications or services)
  • Membership and service information (including participation in concierge, wellness or building programs)

We only collect personal information that is reasonably necessary for our functions or activities.

Tenants and prospective tenants

We collect personal information from individual tenants and guarantors, and representatives of corporate tenants, during negotiations for, and during the terms of, leases for properties we own or operate.

We use personal information for purposes including evaluating whether to grant leases and/or enter into agreements with prospective tenants, documenting these leases and/or agreements, performing our obligations under leases and/or agreements with tenants, managing relationships with tenants and monitoring properties.

We also collect personal information from staff and visitors of tenants in connection with the control of access to buildings we own or operate, as described in more detail below.

Customers and membership programs

If you are a customer of ours (including a buyer of an apartment or other property from us), we may use your personal information to provide, administer, improve and personalise our services, process payments, identify you, communicate with you in relation to our services and respond to your enquiries.

We collect personal information from customers and corporate representatives during contract negotiations and during the term of our contracts with them.

We may conduct membership programs for the use of facilities owned or operated by us, such as concierge services, wellness facilities or end-of-trip facilities. If you join any of our membership programs, we may use your personal information to provide you with rewards, discounts and access to unique member services through the program.

We may also use your personal information to analyse usage of the program, improve our membership content and product offers, and conduct advertising and promotions.

If you give us credit card details, we may use them to process transactions agreed with you and may store them for use in subsequent transactions without needing them to be re-entered.

We collect and store transaction information for transactions conducted with us, including purchases made on our Website or via any application we support. The history of such purchases is maintained by us to facilitate a possible future refund, as well as to comply with necessary regulations such as applicable anti-money laundering and anti-terrorism laws.

Service providers

If you, or a company you work for, supply goods or services to us, we may collect your personal information in connection with the provision of these goods or services. We may use your personal information for purposes associated with managing the supply of these goods and services.

Job applicants

We collect personal information of job applicants for the purpose of assessing and, if successful, engaging applicants.

We may store information provided by unsuccessful applicants for the purposes of future recruitment. If you do not agree with this information being retained, please contact our Privacy Officer (details below).

CCTV

We use personal information collected through camera surveillance systems (commonly referred to as CCTV) for the purpose of maintaining the safety and security of property and individuals working at or visiting properties we own or operate. CCTV recordings in car parks may also collect licence plate details.

Visitors and building access control

We operate access control systems for buildings we own or operate to provide security for our staff, premises, tenants, and tenants’ staff, visitors and contractors.

Those access control systems include devices that govern access to buildings, including card access controllers operated by:

  • Gallagher
  • Kastle
  • HID 
  • Proxy

In the future, we may implement access control systems via a mobile phone application instead of card access controllers. This Privacy Policy will apply to any replacement system.

We collect and store personal information (including location information and CCTV images) of each person who is granted security access, including the purposes of providing or preventing access and recording times and locations where access is attempted or granted.

Marketing 

We may use your personal information to send you direct marketing communications, mostly by email. You will only receive marketing communications where you have consented or where we are permitted to do so under applicable law. You may request not to receive communications at any time by following the “unsubscribe” instructions or contacting our Privacy Officer.

How We Collect Personal Information

Only information you provide directly will be collected, such as subscribing to email notifications, requesting services, or accessing buildings via our systems. We also collect personal information through CCTV systems.

The only personal information we collect is what you tell us or what can be determined from your interaction with us, such as location information.

In addition, we may collect personal information:

  • through your use of our website, applications and digital platforms
  • from access control systems and building technologies
  • from service providers who assist us in operating our services
  • from third parties where reasonably necessary to deliver our services

In some cases, it is necessary to collect and store location data to provide services. For example, when accessing buildings via our systems.

Location data may be used to identify where access occurred or where services are requested.

Cookies & Tracking Technologies

Our website and applications may use cookies and similar technologies to enhance your experience and improve our services.

These technologies may collect information such as:

  • browser type and device information
  • pages visited and time spent on our site
  • interactions with content and features

We may use third-party analytics tools, including Firebase, to understand how users engage with our applications and services.

You can manage cookies through your browser settings. Disabling cookies may affect the functionality of our website or applications.

Disclosure of personal information

We may disclose your personal information to contractors and third-party service providers.

We may also disclose information where it is reasonably apparent you have given consent, for example, for payment processing or service delivery.

CCTV images and access records may be provided to tenants, law enforcement or insurers for security and investigative purposes.

We will not disclose personal information without consent, except as required by law.

In addition to the above, we may disclose personal information to third parties who support our operations, including IT and system providers, analytics and digital service providers, professional advisers, and contractors involved in building operations or service delivery. All third parties are required to handle personal information in accordance with applicable privacy laws

Information emails

From time to time, we may send you relevant information emails regarding services you have registered interest in.

You may unsubscribe at any time.

How we hold your personal information

We may hold your personal information in electronic or hard copy form in databases, systems and physical files.

Data Retention

We retain personal information only for as long as it is reasonably necessary to:

  • fulfil the purposes outlined in this Privacy Policy
  • comply with legal and regulatory obligations
  • resolve disputes and enforce agreements

When personal information is no longer required, we take reasonable steps to securely destroy or de-identify it.

Security

We take reasonable steps to ensure information is secure and up to date. Employees are required to maintain confidentiality.

Data analytics

We may use personal information for data analysis to improve services. This may involve third-party providers.

Our 1 Denison app uses Firebase analytics. Firebase will use personal information in accordance with its privacy policy. If you have access to our 1 Denison app, our Privacy Policy is available on your account page.

Your Privacy Rights 

You may request access to your personal information at any time.

You may also request deletion or correction of your data via the application or by contacting the Privacy Officer.

We will comply unless prevented by law.

In addition: 

  • You may request that inaccurate or incomplete information be corrected
  • You may withdraw consent to marketing communications at any time
  • We will respond to requests within a reasonable timeframe consistent with the Privacy Act

Complaints and questions

If you have questions or complaints, you may contact the Privacy Officer.

We will acknowledge complaints within 48 hours and respond within 10 days.

If unresolved, you may contact the Office of the Australian Information Commissioner (OAIC).

Contacting us

You can contact us via the website:
https://www.winten.com.au/contact/

Or via email:
privacy@winten.com.au

Further information

For more information, visit:
www.privacy.gov.au