Privacy Policy
1.Your rights in relation to privacy
We understand the importance of protecting the privacy of an individual's personal information.
This policy statement sets out how Dennis Family Corporation Pty Ltd ABN 15 089 081 667 and its
related entities set out below (we/our/us/Group) aim to protect the privacy of your personal
information, your rights in relation to your personal information managed by us and the way we
collect, hold, use and disclose your personal information.

For the purposes of this policy, reference to the Group includes the following entities:
(a) Dennis Family Corporation Pty Ltd;
(b) Dennis Personnel Pty Ltd;
(c) Ranfurlie Asset Management Pty Limited; and
(d) any other related bodies corporate (as defined under the Corporations Act 2001) of the
above entities.

In handling your personal information (including credit-related personal information), we are
committed to preserving your privacy in accordance with the Privacy Act 1988 (Cth) (Privacy Act),
the Australian Privacy Principles and all other applicable privacy laws. This policy may be updated
from time to time.

To the extent that we handle your credit-related personal information, we will also comply with the
Credit Reporting Code. This policy statement addresses the following:
1. What kinds of personal information do we collect?
2. Who do we collect personal information from?
3. How do we collect your personal information?
4. Why do we need your personal information?
5. To whom do we disclose your personal information?
6. Overseas disclosures
7. Direct marketing
8. Security of your personal information
9. Third party links
10. Electronic contracts
11. Can you access and correct the personal information that we hold about you?
12. Right to refuse access or correction
13. Web site cookies
14. Wi-Fi services
15. Bluetooth Surveillance
16. CCTV surveillance
17. Privacy complaints
18. Changes to this policy

1.1 What kinds of personal information do we collect?
Personal information is information or an opinion about an identified, or reasonably
identifiable, individual. During the provision of our products and services, we may collect
and hold your personal information.

Generally, the kinds of personal information we collect and hold include:
• your contact and identification information such as your name, previous names and
change of name documentation, address, previous addresses, telephone number,
email address, e-signature and date of birth;
• banking, financial, loan and trading information including information about your
assets, tax assessments, rental contracts, occupation, employers and previous
employers, income, account balances and activities, and transactions with us or
third parties;
• property and title information including information about land values;
• credit information, being credit-related personal information lawfully created and
accessible within the Australian credit reporting system including:
• identification information including viewing, or obtaining copies of, your driver’s
licence, Medicare card, passport, birth certificate or extract, citizenship certificate or
evidence of permanent residence, marriage certificate or other evidence of your
relationship status and ATM cards;
oconsumer credit liability information including:

• information about existing and previous credit providers and credit accounts;
• the types of consumer credit provided;
• the day on which the accounts were entered into, terminated or otherwise ceased to be in force;
• the terms and conditions of the consumer credit relating to the repayment of the credit or otherwise prescribed by law; 
• the maximum amount of credit available under the consumer credit; 
• repayment history information, being information about whether you have or met your monthly payment obligations with respect to consumer credit; 
  
• information about defaults; 
  
• information regarding whether another entity has sought credit-related personal information about you from a credit reporting body;
• information about the types of credit, and the amounts of credit, you have sought from a credit provider;
• information about court proceedings related to credit provided to you or for which you have applied;
• personal insolvency information and other publicly available information relating to your credit worthiness;
• a credit provider’s reasonable belief that you have committed a serious credit infringement; and
• any other information lawfully obtainable within the Australian credit reporting system;
• personal information of actual or prospective tenant of premises or kiosk licensees including:

Retailers and licensees: names, addresses, dates of birth, contacts and insurance details, job descriptions, business details, trading history, financial capacity and private and business assets and liabilities. For retailer or licensee personnel / staff, it includes name, job position, contact details and any other information required for registering retailer personnel for centre services, such as retailer carparking, entry passes and keys, for which
we collect number plate details.

Guarantors: name, job position, contact details and all other information on
your business experience, trading history, financial capacity, as well as
personal and business assets and liabilities.
• your vehicle’s license plate number when attending our retail locations;
• credit eligibility information which is information about you, including the 

Information set out above, that we obtain from a credit reporting body together
with information we derive from such information based on our own analysis. This
may include an internally generated assessment, which reflects your suitability for
a loan arrangement;
• insurance information;
• information including your photographic or video image collected via various
methods, including by our CCTV surveillance systems;
• if you are a prospective employee, your employment history, academic results,
personal interests and other information you may provide as part of the
recruitment process;
• sensitive information including health information and criminal record information
where you are applying for a position with us and it is relevant to the recruitment
process through which you must progress or where you have consented to such
collection;
• information related to the Australian Government Department of Home Affairs,
• your opinion or preferences regarding our products or services;
• information concerning your online presence and the websites you access as
provided to us through your use of our websites and your use of our Wi-Fi services;
• information concerning your location and movement as provided to us through
your use of Bluetooth surveillance; and
• other personal information required for our functions and activities and to enable
you to deal with us.

In some circumstances, we may also hold other personal information provided by you or a
credit reporting body.

1.2 Who do we collect personal information from?
• individuals who are our clients/customers (including lessees) or prospective
clients/customers;
• family members and guarantors of individuals who are our clients/customers;
• individuals who are representatives of our corporate clients and staff members of
our retailers or licensee clients; and
• our prospective and current employees, contractors and consultants. 

1.3 How do we collect your personal information?
Generally, we collect your personal information (including credit-related personal
information) directly from you, through the completion of a manual or online form, an
interaction or exchange in person or by way of telephone, facsimile, email, post or through
the use of our website, including but not limited to when you:
• make enquiries about our products or services;
• ask to be placed on our mailing lists;
• complete a form;
• use any of our various websites;
• utilise our Wi-Fi services or by Bluetooth surveillance;
• meet with any of our staff;
• become a client, debtor, lessee or licensee; or
• apply for a job with us.

There may be occasions when we collect your personal information from other sources
including but not limited to:
• an information services provider;
• organisations undertaking verification of identity services on our behalf;
• a publicly maintained record or other publicly available sources of information
including social media and similar websites;
• the Land Titles Office and other property registers;
• relevant State and Territory Valuers General;
• real estate agents;
• ASIC;
• Australian Federal Police;
• Department of Health;
• local road regulator;
•Medical/allied health providers;
•Australian Government Department of Home Affairs;
•the Insolvency and Trustee Services of Australia;
•credit reporting bodies to assist us in determining whether we will provide leasing
or other property related services to you or to an entity you represent or for which
you are a director or guarantor;
• if for recruitment purposes, an external recruitment or background screening
services provider; or
• third party providers which collate information which may otherwise be available
through a generally available publication. In particular, we collect information from
a third party provider, which collates information from real estate agents, property
registers and relevant Valuers General, for the purpose of identifying comparable
land values.

Generally, we only collect your personal information from sources other than you if it is
unreasonable or impracticable to collect your personal information from you.
1.4 Why do we need your personal information?
We collect, hold, use and disclose your personal information where it is reasonably
necessary for the purposes of:
• providing our products and services to you including:
obuilding and construction of residential homes and townhomes, as part of
our residential communities;
ocompleting land and property sales;
oascertaining comparable land values;
oleasing and property management; and
ooperation of retail centres;

• enabling our contractors to provide products and services to you including:
• building and construction of residential homes and townhomes, as part of
• our residential communities;
• completing land and property sales; and
• ascertaining comparable land values;
• enabling our contractors’ subcontractors to assist our contractors to provide products and services to you;
• enabling our contractors to engage in direct marketing with you;
• complying with our legal obligations:
• under the Anti-Money Laundering and Counter Terrorism Finance Act 2006; and
• under the National Consumer Credit Protection Act 2009 including the responsible lending guidelines, and the National Consumer Credit Regulations 2010; and
• carrying out our business functions including:
• recruitment processes for potential employment;
• management of claims such as workers compensation, public liability or any
• ther form of insurance claims;
• coordination of staff travel arrangements;
• personalizing and customizing your customer experience;
• engaging you as a contractor or consultant;
• tracking when you visit our offices, retail centres and land sale offices;
• tracking your customer sales experience;
• distributing promotional materials;
• market research;
• conducting customer profiling, device tracking and traffic management;
• offer mobility equipment for hire within our shopping centres;
• monitor car park usage and help you locate your vehicle;
• accounting, billing and other internal administrative purposes;
• identifying and informing you of products and services that may be of interest to you;
• managing and enhancing our services, including managing security and safety requirements at all our sites;
• providing, as part of our business, data to third parties;
• protecting the security of our property, buildings, and assets, including building perimeters, entrances, exits, reception and corridors;
• verifying alarm and access control system conditions;
• investigating any complaints about or made by you, or if there is any reason to suspect that you are in breach of any of our terms and conditions or that you have engaged in any unlawful activity;
• to assist law enforcement agencies, for example, in connection with the detection, investigation or prosecution of an offence; and
• any other legal requirements.

If you lease, license, or apply to lease or license from us, to:

• determine whether to grant a lease, license or other rights to use our facilities or services;
• manage and operate our relationship, agreements, payment systems and processes and communications with you (this includes notices issued under leases and licenses);
• manage and operate the centres and its facilities in which you lease or license space from us;
• manage and monitor the performance of our centres;
• observe all emergency procedures and contact you in the event of an emergency;
• understand your interests, preferences and activities as a retailer or licensee at our centres; and
• conduct market research surveys and interviews how to improve the retailer experiences at our shopping centres and sales centres.

We may also use your personal information (including credit-related personal information)
for purposes related to the above purposes and for which you would reasonably expect us
to do so in the circumstances, or where you have consented or the use is otherwise in
accordance with law.
Where personal information (including credit-related personal information) is used or
disclosed, we take reasonable steps to ensure it is relevant to the purpose for which it is to
be used or disclosed.
You are under no obligation to provide your personal information to us. However, without
certain information from you, we may not be able to provide our products and services to
you. This includes assessing any application you make for employment or engagement as a
contractor with us.

1.5 To whom do we disclose your personal information?
We disclose your personal information (including credit-related personal information) for
the purpose for which we collect it. That is, generally, we will only disclose your personal
information for a purpose set out at paragraph 1.4 above.
This may include disclosing your personal information to third parties engaged by us to
perform administrative or other services, lenders or credit providers, mortgage insurers,
our contractors including, without limitation, building contractors, related bodies
corporate, stationery printing houses, mailing houses, professional and legal advisors, the
relevant worksafe authority, insurers, insurance brokers or people or entities considering
acquiring an interest in our business or assets.
Our disclosures of your personal information (including credit-related personal information)
to third parties are on a confidential basis or otherwise in accordance with law. We may
also disclose your personal information (including credit-related personal information) with
your consent or if disclosure is required or authorised by law.
We have a presence on some social media channels such as but not limited to Facebook,
Instagram and LinkedIn. Where possible we limit disclosure of your personal information to
your first name and surname.

1.6 Overseas disclosures
We do not disclose personal information (including credit-related personal information) to
overseas recipients. However, in the event we need to do so:
• we will only do so in order to provide our services and products and manage our
business functions; and
• before disclosing any personal information (including credit-related personal
information) to an overseas recipient, we will take reasonable steps to ensure the
overseas recipient complies with the Australian Privacy Principles or is bound by a
substantially similar privacy scheme, unless you consent to the overseas disclosure
or it is otherwise required or permitted by law.

1.7 Direct marketing
We may use and disclose your personal information in order to inform you of our products,
services, offers (including offers of employment or engagement) and promotions that may
be of interest to you and the products, services, offers and promotions of our contractors
and third party service providers.
In order to inform you of such products, services, offers and promotions, such
communications may be sent to you by email, SMS or other form of electronic
communication.
In the event you do not wish to receive such communications from us or our third party
service providers, you can opt-out by contacting us via the contact details set out in
paragraph 1.17 or through any opt-out mechanism contained in a marketing
communication to you.

1.8 Security of your personal information
We take reasonable technical and organisational measures to ensure that the personal
information (including credit-related personal information) we hold is protected from
misuse, interference and loss and from unauthorised access, modification or disclosure. We
hold personal information in both hard copy and electronic forms in secure databases on
secure premises, accessible only by those who have a legitimate business purpose and
reason for accessing it. The secure databases are operated either by us or by our external
service providers and we have implemented a range of security measures, including strict
confidentiality agreements, passwords, firewalls and encryption to restrict access.
We will destroy or de-identify personal information in circumstances where it is no longer
required, unless we are otherwise required or authorised by law to retain the personal
information.
You should be aware that the internet is not a secure environment. Although we will use
reasonable endeavours to protect your personal information, we cannot guarantee the
security of personal information that is being transferred via the internet. If you use the
internet to send us personal information, including your email address, it is sent at your
own risk. Once we have received your personal information, we will use strict processes and
security measures to prevent unauthorized access.
If we engage external service providers to assist us to fulfil our functions and activities, we
will also require them to implement appropriate measures to protect any personal
information that is provided to them. 

1.9 Third party links
In the event that our website contains links to websites that are operated by third parties,
such links are provided as a convenience to you and should not in any way be interpreted
as an endorsement of any company, content or product that may be linked. Any access to
a third party website that is linked to our website is at your own risk and we have no control
over and are not responsible for the accuracy, validity or ownership of any content of a
linked site and the privacy practices of those linked websites.

1.10 Electronic contracts
We use electronic contracts (e-contracts) to facilitate transactions with you and to enable
us to provide our products and services to you. This also includes any offer of employment
or engagement with us. Under this policy, you consent to us using e-contracts in your
dealings with us. We handle personal information (including credit-related personal
information) collected by e-contracts in the same way we handle all other personal
information as set out in this privacy policy.

1.11 Can you access and correct the personal information that we hold about you?
We take reasonable steps to ensure personal information (including credit-related personal
information) we collect, hold, use and disclose is accurate, up-to-date, complete, relevant
and not misleading.
Under the Privacy Act, you have a right to access and seek correction of your personal
information that is collected and held by us.
If at any time you would like to access or seek correction of the personal information
(including credit-related personal information) that we hold about you, or you would like
more information on our approach to privacy, please contact our Privacy Compliance
Officer via the contact details set out in paragraph 1.17.
We will grant access to your personal information to the extent required or authorised by
the Privacy Act or other law and take reasonable steps to correct personal information
(including credit-related personal information) where necessary and appropriate.
Where necessary to resolve a request for correction of your credit-related personal
information, we may also consult with other relevant entities, including but not limited to
any relevant credit reporting body.

To obtain access to your personal information (including credit-related personal
information):
• you will need to provide proof of identity. This is necessary to ensure that personal
information is provided only to the correct individuals and that the privacy of others
is protected;
• we request that you be reasonably specific about the information you require; and
• we may charge you a reasonable administration fee, which reflects the cost to us,
for providing access in accordance with your request.

In the event we correct personal information that we have previously disclosed to another
entity, you may request us to notify that other entity of the correction. In these
circumstances, we will take reasonable steps to notify the other entity of the correction
unless it would be impracticable or unlawful to do so.
We will endeavour to respond to your request to access or correct your personal
information within 30 days from your request.

1.12 Right to refuse access or correction
We reserve our right to refuse your request to access or correct your personal information
if we consider your request to be frivolous or vexatious or if we are otherwise legally
entitled to do so.
If we refuse your request to access or correct your personal information, we will provide
you with written reasons for the refusal and details of complaint mechanisms. We will also
take reasonable steps to provide you with access in a manner that meets your and the needs
of the Group.
Google Analytics:
By accessing our websites, you consent to the collection and processing of your personal
(non-identifiable) information or data for the above purposes, including the association of such information or data with the visitation information Google Analytics collects from our
websites.

1.13 Web site cookies
We make limited use of ‘cookies’ technology on our website. We use cookies which can
record information about your visit to our website, to improve the functionality of our
website and enable us to better understand your needs. The ‘cookies’ store a log file which
is retained for technical and statistical purposes only.
We also make use of third party cookies, for example, those that are sent by advertisers on
websites that you visit. Third party cookies are used on our website to enable remarketing
and reporting of user demographics and user interests.
The information collected is not personal information and, to the extent any personal
information is collected, it is de-identified prior to being analysed for technical and statistical
purposes. Cookies are a feature of your Internet browser that you can disable at any time,
but this may mean that you are not able to use the full functionality of our website.

1.14 Wi-Fi services
We offer Wi-Fi services to customers and prospective customers at certain sites, including
our sales offices, buildings and shopping centres, and land sale offices.
If you are in possession of a device that is enabled for Wi-Fi and you are within range of one
of our networks, we will automatically collect your location information and other
information about your device while you are within range of our Wi-Fi network, for example,
the type of device you hold, MAC address, signal strength, information specific to the
handset and operating system and its movement patterns. Such information is unlikely to
personally identify you, unless you connect to our Wi-Fi network.
In addition to the information referred to above, if you connect to our Wi-Fi network, we
may collect personal information from you, including your name, phone number, email
address, and details of the websites you access while you are connected to our network. This
is only in circumstances where you are inputting this information whilst using our Wi-Fi
network. We may use your personal information in aggregate form to improve our services
and make them more responsive to your needs.
If you prefer that the above information is not collected via our Wi-Fi services, simply opt out
by turning off your phone’s Wi-Fi when entering our buildings.

1.15 Bluetooth Surveillance
If you are within range of one of our networks and have Bluetooth capability on your
smartphone switched on and are in possession of a device that is enabled for Wi-Fi, we will
automatically collect your location information and other information about your device
while you are within the range of our Wi-Fi network for example, the type of device you hold,
MAC address, signal strength, information specific to the handset and operating system and
its movement patterns. Through the use of this Bluetooth surveillance, we will also be
provided with your mobile number.
One of the ways we will collect this information is through the use of Skyfii through
Bluetooth capabilities available in our carparks, offices, buildings and retail centres for the
purpose of tracking visitor flows, tracking customer sales experiences and marketing to
customers. For further details, please refer to Skyfii’s Privacy Policy:
https://www.beonic.com/privacy-policy and Terms and Conditions:
https://www.beonic.com/terms-and-conditions.
For customers already on our database, we use the information gathered via Bluetooth
surveillance for promotional marketing purposes. For those individuals not already on our
database, we will not use the information gathered through Bluetooth surveillance for
promotional marketing purposes.
One of the ways we will collect this information is through the use of Blix Traffic whereby we
install Blix sensors in our carparks, sales offices and buildings, and land sale offices for the
purpose of tracking visitor flows, tracking customer sales experiences, and marketing to
customers.
If you prefer that the above information is not collected via our Bluetooth surveillance,
simply opt out by turning off your phone’s Wi-Fi and Bluetooth capabilities when entering
our land sale offices buildings, and associated car parks.

1.16 CCTV surveillance
We use CCTV surveillance systems to record activity at our sites, including sales offices and
car parks. We collect, hold, use and disclose your personal information, including your
visual image, gathered via CCTV surveillance systems for one or more of our legitimate
purposes related to our operations, including:
• ensuring the safety and security of staff and our premises and facilities;
• protecting the security of our property, buildings, and assets, including building
perimeters, entrances, exits, reception, and corridors;
• verifying alarm and access control system conditions;
• training security staff under appropriate supervision; and
• to assist law enforcement agencies, for example, in connection with the detection,
investigation, or prosecution of an offence.

1.17 Privacy complaints
Please direct all privacy complaints or any enquiries regarding your personal information to
our Privacy Compliance Officer.
The Privacy Compliance Officer can be contacted at:
Email: privacy@denniscorp.com.au
Address: The Privacy Officer, Dennis Family Corporation, 863 High Street, Armadale, Victoria 3143.

Ph: 03 9573 1142

At all times, privacy complaints:
• will be treated seriously;
• will be dealt with promptly;
• will be dealt with in a confidential manner; and
• will not affect your existing obligations to us or affect the commercial arrangements you have with us.
In the event you have a complaint with respect to privacy, the Privacy Compliance Officer
will commence an investigation and inform you of the outcome of the investigation. If you
are dissatisfied with the outcome of the investigation, you may refer the complaint to the
Office of the Australian Information Commissioner.
Specifically, if your complaint relates to credit-related personal information and/or our
failure to comply with our obligations regarding credit-related personal information under
the Privacy Act and/or the Credit Reporting Code:
• we will acknowledge your complaint within 7 days of receipt, in writing, and
endeavour to resolve it within 30 days, unless we inform you otherwise and seek your
agreement in writing;
• we may consult with relevant third parties, such as a credit reporting body or other
credit provider, in order to sufficiently and expeditiously resolve the complaint; and
• if your complaint relates to our refusal to provide access to, or correct, your credit
related personal information, you may complain directly to the Office of the
Australian Information Commissioner.

1.18 Changes to this policy
If we decide to change this privacy policy, we will publish those changes on our website so that you
are aware of what information we collect, how we use it, and under what circumstances, if any, we
disclose it.