JLL and LaSalle Investment Management
Date of Implementation: from 25 May 2018
1 Background
JLL and LaSalle Investment Management and their Australian related bodies corporate (we, our, us) recognise the importance of protecting the privacy and the rights of individuals in relation to their personal information. This document is our Australian privacy policy and it tells you how our Australian entities collect and manage your personal information.
We respect your rights to privacy under the Privacy Act 1988 (Cth) (Act) and we comply with all of the Act's requirements in respect of the collection, management and disclosure of your personal information.
2 What is your personal information?
When used in this privacy policy, the term "personal information" has the meaning given to it in the Act. In general terms, it is any information that can be used to personally identify you. This may include your name, address, telephone number, email address, profession or occupation and images or photographs. If the information we collect personally identifies you, or you are reasonably identifiable from it, the information will be considered personal information.
3 What personal information do we collect and hold?
We may collect the following types of personal information:
• name;
• mailing or street address;
• email address;
• telephone number;
• facsimile number;
• age or birth date;
• profession, occupation or job title;
• details of the products and services you have purchased from us or which you have enquired about, together with any additional information necessary to deliver those products and services and to respond to your enquiries;
• any additional information relating to you that you provide to us directly through our websites or indirectly through use of our websites or online presence, through our representatives or otherwise; and
• information you provide to us through our service centre, customer surveys or visits by our representatives from time to time.
We may also collect some information that is not personal information because it does not identify you or anyone else. For example, we may collect anonymous answers to surveys or aggregated information about how users use our website or our computer applications.
4 How do we collect your personal information?
We collect your personal information directly from you unless it is unreasonable or impracticable to do so. When collecting personal information from you, we may collect in ways including:
• through your access and use of our website;
• during conversations between you and our representatives;
• when you complete an application or purchase order;
• when you enter competitions that we hold; or
• when you complete a form requesting articles/updates from us.
We may also collect personal information from third parties such as credit reporting agencies, law enforcement agencies and other government entities.
5 Cookies
In some cases we may also collect your personal information through the use of cookies (these being small summary files containing a unique 10 digit number). When you access our website, we may send a cookie to your computer. This enables us to recognise your computer and greet you each time you visit our website without bothering you with a request to register. It also enables us to keep track of products or services you view so that, if you consent, we can send you news about those products or services. We also use cookies to measure traffic patterns, to determine which areas of our website have been visited, and to measure transaction patterns in the aggregate. We use this to research our users' habits so that we can improve our online products and services. If you do not wish to receive cookies, you can set your browser so that your computer does not accept them.
We may log IP addresses (that is, the electronic addresses of computers connected to the internet) to analyse trends, administer our websites, track users movements, and gather broad demographic information.
6 What happens if we can't collect your personal information?
If you do not provide us with the personal information described above (including by use of computer settings which do not permit acceptance of cookies), some or all of the following may happen:
• we may not be able to provide to you products or services that you have requested, either to our usual standard or at all;
• we may not be able to provide you with information about products and services that you may want, including information about discounts, sales or special promotions; or
• we may be unable to tailor the content of our websites to your preferences and your experience of our websites may not be as enjoyable or useful.
7 For what purposes do we collect, hold, use and disclose your personal information?
We collect personal information about you so that we can perform our business activities and functions and to provide the best possible quality of customer service.
We collect, hold, use and disclose your personal information for the following purposes:
• to provide products and services to you and to send communications requested by you;
• to answer enquiries and provide information or advice about existing and new products or services;
• to provide you with access to protected areas of our websites and our computer applications ("apps");
• to assess the performance of our websites and our apps, and to improve the operation of our websites and our apps;
• to conduct business processing functions including providing personal information to our related bodies corporate, contractors, service providers or other third parties;
• for the administrative, marketing (including direct marketing), planning, product or service development, quality control and research purposes of JLL and LaSalle Investment Management, their related bodies corporate, contractors and service providers;
• to provide your updated personal information to our related bodies corporate, contractors and service providers;
• to update our records and keep your contact details up to date;
• to process and respond to any concerns or complaints you raise; and
