1. About this policy

Westminster Property Partners (“Westminster”, “we”, “us”, “our”) is committed to protecting the privacy of individuals we deal with, including visitors to this website, prospective and current clients, principals, investors and other business contacts.

This Privacy Policy explains how we collect, hold, use and disclose personal information, in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs). By using this website or providing us with your personal information, you agree to the terms of this Privacy Policy.

2. Who we are

Westminster Property Partners is a commercial property advisory operating from 2 Stawell Street, Richmond VIC 3121, Australia. Our Australian Business Number (ABN) is available on request.

3. What personal information we collect

Depending on how you interact with us, we may collect:

• Contact details — name, email address, phone number, and postal or business address.
• Enquiry details — the nature of your enquiry (for example, acquisitions, sales, leasing & management, joint ventures, advocacy, business acquisitions or sales, or mergers & takeovers) and any information you provide in a message to us.
• Client and transaction information — details relevant to an engagement, such as asset, portfolio or transaction information you share with us in the course of an advisory relationship.
• Account credentials — if you are given access to our private listings / client area, a username and password are required. Login credentials are stored in encrypted form and we do not have access to your plain-text password.
• Technical information — standard website log data such as IP address, browser type, device type, pages visited and referring URL, collected automatically when you browse the site.

We do not intentionally collect sensitive information (such as health, financial hardship or other special category information under the Privacy Act) through this website. Please do not include sensitive information in enquiry forms unless it is strictly necessary and relevant to your engagement with us.

4. How we collect personal information

We collect personal information directly from you, when you complete an enquiry form, email us, call us, or otherwise communicate with us; when you are issued login credentials for our private listings / client area; automatically, through your use of this website (see Cookies below); and from third parties where relevant to an engagement — for example, a co-advisor, financier, or other party to a transaction you have authorised to share information with us — or from publicly available sources such as property and corporate registers.

5. Why we collect, hold, use and disclose personal information

We collect and use personal information to:

• respond to and manage your enquiry;
• provide our advisory services, including acquisitions, sales, leasing & management, joint ventures, advocacy, and business acquisitions, sales, mergers and takeovers;
• administer and provide access to our private listings / client area;
• verify identity and manage login security for restricted areas of the website;
• communicate with you about matters relevant to your enquiry or engagement;
• maintain business records and comply with our legal and regulatory obligations, including under anti-money laundering and counter-terrorism financing laws where applicable to a transaction;
• improve this website and our services; and
• any other purpose disclosed to you at the time of collection, or with your consent.

We do not sell personal information to third parties.

6. Disclosure of personal information

We may disclose personal information to our personnel, contractors and professional advisers (such as lawyers or accountants) who need it to assist us in providing our services; other parties to a transaction — such as a counterparty, financier, agent or their advisers — but only where relevant to progressing an engagement you have instructed us on, or with your consent; our website hosting and IT service providers, who process information on our behalf to keep this website running and secure; regulatory bodies, law enforcement or government agencies where required or authorised by law; and a purchaser or their advisers in connection with an actual or proposed sale, merger or restructure of our business, subject to appropriate confidentiality protections.

Some of the service providers we use to operate this website — for example, our hosting and IT infrastructure providers — may store or process data outside Australia. Where this occurs, we take reasonable steps to ensure those providers protect your information consistently with the Australian Privacy Principles.

7. Cookies and website analytics

Cookies are small text files placed on your device that help websites function and, where used, help site owners understand how visitors use a site. This website currently uses only the cookies necessary for the site to function correctly — for example, cookies that keep you logged in to the private listings / client area, and cookies used by our hosting and security infrastructure such as caching and firewall services. We do not currently use third-party advertising, retargeting or analytics cookies.

If we introduce analytics, marketing or other non-essential cookies in the future, we will update this policy and, where required by law, seek your consent before they are set. Most browsers allow you to control or delete cookies through their settings; restricting cookies may affect the functionality of this website, including your ability to log in to the private listings area.

8. Direct marketing

We will only send you direct marketing communications in accordance with the Spam Act 2003 (Cth) — generally, where you have consented, or where you would reasonably expect to receive such communications given your relationship with us. You may opt out or unsubscribe at any time by contacting us using the details below.

9. Data security

We take reasonable technical and organisational steps to protect the personal information we hold from misuse, interference, loss, and unauthorised access, modification or disclosure, including restricting access to personnel who need it and using encrypted storage for account credentials. No method of transmission over the internet or electronic storage is completely secure, and we cannot guarantee absolute security.

10. Data retention

We retain personal information only for as long as reasonably necessary to fulfil the purposes for which it was collected, including to satisfy legal, accounting, or reporting requirements, after which it is securely deleted or de-identified.

11. Access and correction

You may request access to the personal information we hold about you, and ask us to correct it if it is inaccurate, out of date, incomplete, irrelevant or misleading. We will respond to reasonable requests within a reasonable timeframe. In some circumstances we may be entitled by law to refuse access or correction, in which case we will explain why.

12. Children’s privacy

This website is directed at businesses and adults and is not intended for use by children. We do not knowingly collect personal information from children.

13. Changes to this policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal obligations. The updated version will be posted on this page with a revised “last updated” date.

14. How to contact us / make a complaint

If you have a question about this policy, wish to access or correct your personal information, or wish to make a complaint about how we have handled your personal information, please contact us.

We will acknowledge your complaint and aim to resolve it within a reasonable time. If you are not satisfied with our response, you may refer your complaint to the Office of the Australian Information Commissioner (OAIC) — www.oaic.gov.au, phone 1300 363 992.