PRIVACY POLICY

1 Our Policy Statement

This Privacy Policy (“Policy”) explains how Stockland Corporation Limited, our related bodies corporate and trusts (together, “Stockland”, “we”, “our” or “us”) collect, stores, use, disclose and manage your personal information, including specifically, the collection and handling of personal information collected by and through the Stockland Marketplace, and any related Stockland websites and apps that are operated by Stockland.

2 Purpose

Stockland is a diversified property group and our key business activities include:
- property development;
- investment in and leasing of retail town centres, workplace and logistics property;
- investment in residential communities;
- investment in, operation and leasing of retirement living communities;
- real estate agency services; and
- funds management including in relation to unlisted property funds.

Stockland also operates the Stockland Marketplace at https://marketplace.stockland.com.au and any related Stockland websites or apps. By providing personal information to us, you consent to our collection, use, storage, disclosure and management of your personal information in accordance with the Privacy Act 1988 (Cth) ("Privacy Act") and this Policy.

3 What personal information do we collect?

The types of personal information Stockland collects about you depends on the nature of your interactions with us. In this Policy, “personal information” has the meaning given to it in the Privacy Act and includes any information or opinion, whether true or not, about an identified individual or an individual who is reasonably identifiable. We may collect the following types of personal information:
- information to verify your identity including your name, date of birth, gender, address, email address and telephone number;
- financial information including bank accounts, debit or credit card details, your income and credit-worthiness;
- details of your employment history, and other information provided as part of our recruitment process;
- your preference of our products, services, facilities and lifestyle activities;
- information about you and your family and any characteristics, preferences or requirements that are relevant to the products and services that we may provide to you;
- your image and/or voice and other personal information (such as your car licence plate) collected via CCTV surveillance systems installed in our residential and retirement living communities, workplace and logistics and retail town centre premises;
- your device ID, device type, geo-location information, IP address, browsing information and any personal information that you may provide to us directly or indirectly via our websites, Wi-Fi services, mobile applications; and
- any other personal information that may be required in order to facilitate your dealings with us. In relation to the Stockland Marketplace, we may also collect the following types of personal information:
- for customers on the Stockland Marketplace:
* information relating to your Stockland Marketplace account and orders on the Stockland Marketplace, including (but not limited to), your username and password; shipping and billing information, transaction details relating to your use or purchase of the products;
* your user profile information, including images you may have uploaded to the Site;
* your preferences of Retailers on the Stockland Marketplace and any preferences relating to goods, products and services;
- for retailers on the Stockland Marketplace:
* information relating to your Stockland Marketplace account and offering of goods or products on the Stockland Marketplace, including (but not limited to), the name of the organisation you are employed by or associated with, billing and transaction details relating to your sale of a product;
* contact information if a customer needs to reach out to you with an enquiry relating to a product;
* user profile information, including any images you may have uploaded on the Site.

4 Do we collect sensitive information?

In some cases we may also collect ‘sensitive information’, for example if you are involved in an accident we may collect medical information and incident reports. CCTV footage may contain sensitive information, and as such its use and release is governed by additional policies, this is covered in more detail in the section dealing with access to personal information.

5 How is personal information collected?

We will generally collect personal information:
- from you directly, when you communicate and interact with us and any of our websites;
- from you indirectly, anytime you communicate or interact with us, whether this is by phone, email, face to face meeting, online or social media interaction;
- when you sign-up for a Stockland Marketplace account;
- when you make an order or purchase on the Stockland Marketplace or offer products for sale on the Stockland Marketplace;
- when you use our websites (including the Stockland Marketplace), applications or our Wi-Fi services;
- when you sign-up to receive marketing content, such as newsletters, mailing lists or other promotional content or offers;
- your participation in our surveys, competitions, loyalty programs or promotions;
- when you visit our residential and retirement living communities, workplace and logistics, retail town centres or carparks through our CCTV systems; and
- through our recruitment process when you apply for a position with us. We may also collect your personal information from third parties such as:
- marketing agencies, data collection and research organisations;
- retailers on our Stockland Marketplace who you may have ordered products from, in order to assist you and the Retailer in completing the order;
- medical professionals (for example if you are involved in an accident);
- credit reporting bodies, law enforcement and government entities; and
- other individuals (for example employment references).

6 What happens if Stockland cannot collect personal information?

You are not required to provide personal information to us and may browse our websites and the Stockland Marketplace anonymously. If you wish to deal with us anonymously or you decide not to provide us with the personal information described above, we may not be able to provide or tailor our products, services or information to you, either to the same standard or at all. For example, certain functions of our website may not function properly if you disable cookies, or you will not be able to make orders to purchase products on the Stockland Marketplace.

7 Why do we collect, store, use and disclose personal information?

We may collect, hold, use and disclose your personal information for the following purposes:
- to provide and market our products and services;
- to provide and market the products and services offered by Retailers on the Stockland Marketplace;
- to assist you with, and facilitate, the sale transactions for products offered, and purchased, on the Stockland Marketplace;
- to communicate with you or respond to your enquiries or feedback;
- to do business with you;
- for the general management and conduct of our business;
- to comply with our legal obligations;
- to investigate incidents (including potential incidents) which occur on or at our premises or on relation to any of our websites;
- to consider the suitability of prospective employees;
- for security and risk management purposes; and
- to help us manage, develop and enhance our services, including our Stockland Marketplace, websites, Wi-Fi networks and applications. We will not use or disclose your personal information for any purpose other than the purpose for which it was collected (or a related purpose) unless you have consented to that purpose or we are permitted to do so by law.

8 To whom does Stockland disclose personal information?

We may disclose your personal information (including in some circumstances, your sensitive information) where you have consented to the disclosure and/or for the purposes for which it was collected or related purposes (as described above) to:
- affiliate retailers in retail town centres;
- retailers on the Stockland Marketplace;
- social media channels on which we have a presence such as Facebook, Twitter and Instagram, generally in these cases we limit disclosure of your personal information to your first name and surname;
- regulatory authorities, police or government agencies or bodies where required by law;
- related parties, entities and trusts of Stockland; and
- other companies, service providers and individuals who assist us in providing our services or managing our operations. If any Stockland entity is sold to a third party, we may transfer any personal information we hold about you to that third party. We may also disclose personal information on a confidential basis to prospective purchasers of a Stockland entity. Where we have disclosed personal information to a third party acting on our behalf, we request that those third parties do not use the personal information for their own purposes and that they comply with the Privacy Act and this Policy.

9 CCTV at Stockland sites and shopping centres

We use CCTV surveillance systems to monitor and record activities at Stockland properties and premises (including our workplace and logistics and retail town centre premises, and residential communities and retirement living communities), the main purpose of this is to maintain a safe and secure environment for our employees, customers and visitors to our premises. This means we may use your personal information gathered from CCTV for security and risk management, loss prevention, incident investigation purposes and other purposes set out in this Policy, or as permitted by the law. We also use the data collected from our CCTV surveillance systems to maintain or improve our properties, premises and services, we may do this by:
- collecting and analysing customer behaviour;
- monitoring patterns of foot traffic; and
- analysing shopper demographics and browsing habits. When used for these purposes the data is aggregated anonymously. We do not identify individuals for these uses. We securely discard the data collected from our CCTV surveillance systems when it is no longer required for business or legal purposes.

10 Free Wi-Fi service

We offer a free Wi-Fi network service at certain Stockland premises, including our shopping centres. If you are carrying a Wi-Fi enabled device within range of one of our Wi-Fi networks, we may pick up certain data that is transmitted from your device whether or not you join our Wi-Fi network, including:
- your device ID, device type, IP address and MAC address;
- geo-location information and any movement of your device throughout our premises;
- any other information which you may voluntarily provide to us while accessing our Wi-Fi networks, for example, your name, email address, the details of the websites or mobile applications whilst you are connected to our network; We may also link this type of information to your provided personal information if we hold a common identifier such as your unique device identifier. In each case, we will only use information or data collected via our free Wi-Fi network service in accordance with, and for the purposes set out in this Policy, or as permitted by the law. If you do not want this information collected, you can disable Wi-Fi and Bluetooth on your device/should not sign into the Wi-Fi network.

11 Direct marketing communications

We and/or our third party service providers may send you direct marketing communications and information about:
- products, services, discounts, competitions and special promotions that we consider may be of interest to you;
- offers or promotions based on how you use our products and services;
- third party products and services (including offers and discounts we may have negotiated for our customers) we think may interest you. For example, if we are selling residential land, we may promote the services of one or more builders or, on the Stockland Marketplace, we may promote the products or offers being advertised by the retailers. These communications may be sent in various forms, including by telephone, post, fax, email, SMS or any other form of electronic communication, in accordance with the Privacy Act and the Spam Act 2003 (Cth). By providing us your contact details you consent to Stockland and/or third party service providers we engage, sending you the direct marketing messages described above.

12 Opting-out of other or all marketing communications

You may opt-out of any or all, direct marketing communications at any time by contacting the sender using the details set out in the communication (for example an unsubscribe link), or in the case of Stockland, by contacting our Privacy Officer using the contact details below. In some situations, for example if we are providing services or products to you, we may still be required to make certain communications to you in connection with providing those services or products to you or as required by law. For example, if you make a purchase on the Stockland Marketplace, we will still need to send you communications relating to your order (such sending you your confirmation order invoice and receipt or information about how to collect your purchase).

13 Do we disclose personal information outside Australia?

We may disclose your personal information to the following overseas recipients:
- to related entities;
- to other companies, service providers and individuals who assist us in providing services or perform functions on our behalf such as hosting and data storage providers; and
- where we are required or authorised by law to do so. The countries in which the recipients are likely to be located include Singapore, United States, Canada, Japan and India. We will take reasonable steps to ensure that any overseas recipient does not use the personal information for their own purpose, and complies with the Privacy Act and this Policy.

14 De-Identified or Aggregate Information

Stockland may anonymise or de-identify your personal information that we have collected or which we hold so that you cannot be individually identified. Stockland may use this de-identified or aggregated information for customer insights, strategy, research or analysis purposes (e.g. to monitor website traffic), and share this with our affiliates, partners or the retailers. For example, we may provide de-identified demographic information about users and Customers on the Stockland Marketplace as to the types of users that are viewing their advertisements and you agree that we may use the information we have collected from you in this aggregated or de-identified form in this manner.

15 Cookies

Cookies are pieces of information that a website transfers to your device to store and sometimes track information about your use of the website. We use cookies to distinguish you from other users in order to better serve you when you revisit our websites or the Stockland Marketplace. You can set your browser to notify you when you receive cookies, providing you with the opportunity to either accept or reject it, you can also refuse all cookies by turning them off in your browser. However if you do this, certain parts of our websites or Stockland Marketplace may not function properly. We handle personal information collected by cookies in the same way that we handle all other personal information as described in this Policy.

16 Security of Information

We may hold your personal information in either electronic or hard copy form. The confidentiality and security of your information is very important to us, and we take reasonable steps to protect your personal information from misuse, interference and loss, as well as unauthorised access, modification or disclosure. We use a number of physical, administrative, personnel and technical measures to protect your personal information, and regularly test our security controls, however the open nature of the internet means there is always some risk that an unauthorised party might find ways to overcome our security measures, and it is not possible to guarantee the security of your personal information. You should also be aware that e-mail communications are not usually encrypted and should not be considered secure. Where we no longer require your personal information for business or legal reasons, we will take reasonable steps to destroy or de-identify it. Where required by applicable law, we will notify you, and the Office of the Australian Information Commissioner and/or other relevant regulatory authorities, of data breaches affecting your personal information.

17 Retaining your Personal information

Stockland will retain your personal information only for as long as is needed in order to provide you with goods and services, or as long as your account on the Stockland Marketplace remains active. We will also retain and use your information as long as reasonably necessary to comply with our legal obligations, resolve disputes and enforce agreements, in accordance with applicable laws.

18 Third party links

Our websites and mobile applications (including the Stockland Marketplace) may contain links to websites owned and operated by other organisations. For example, this may include the direct websites of our retailers on the Stockland Marketplace. When you click on one of these links, you are moving away from the Stockland websites (or Stockland Marketplace)to another website. This Privacy Policy does not apply to the practices of these third parties that we do not own or control or to individuals who we do not employ or manage, even if you have accessed the websites, services or products of these third parties through our website or through the Stockland Marketplace. Unless stated otherwise, we are not responsible for the privacy practices of, or any content on, those linked websites. We encourage you to read the privacy policies and other terms that apply to those websites as they may differ from this Policy, and if you have any privacy concerns, we encourage you to contact those website providers directly.

19 Access and correction of personal information

If you wish to seek access to, correct or delete your personal information that we hold about you, please contact our Privacy Officer using the contact details set out below. Depending on the nature of your request, we may ask you to provide us further information in order to verify your identity and ask you to put in writing the information you require.

If you have signed up for an account on the Stockland Marketplace (whether as a Customer or a Retailer), you may also log into your Stockland Marketplace account to access, correct or update the personal information we hold about you on the Stockland Marketplace platform. If we disagree that there are grounds for amending your personal information, we will inform you of the reasons and add a note to the personal information stating that you disagree with it.

There may be instances where we cannot grant you access to, or are not able to delete, the personal information we hold, for example, if a legal exception applies or where granting access would interfere with the privacy of others or result in a breach of confidentiality, or where we are required to retain or cannot delete the information for legal or regulatory compliance reasons. If that happens, we will give you written reasons for refusal (if permitted by law to do so).

In the case of requesting access to CCTV footage, we have a corporate procedure, developed to conform with the Privacy Act that governs our use and release of CCTV footage. It may also be the case that we are unable to release CCTV footage if there is an investigation or legal action pending.

If you wish to update or delete the personal information that we may hold, please contact our Privacy Officer privacy@stockland.com.au. If we disagree that there are grounds for amending your personal information, we will inform you of the reasons and add a note to the personal information stating that you disagree with it.

We will not charge you for requesting access to, corrections or deletion of your personal information, however we may recover reasonable expenses associated with providing you with access to your personal information.

20 Complaints and concerns about your privacy

If you have any questions about how Stockland handles your personal information, or if you wish to make a complaint about Stockland’s information handling practices, please contact our Privacy Officer: Email: privacy@stockland.com.au Post: Privacy Officer, Stockland, Level 25,133 Castlereagh Street, Sydney NSW 2000 Our Privacy Officer will acknowledge receipt of your complaint and after we have completed our investigation, contact you (usually in writing) to advise the outcome, usually within 30 days, and invite a response to our findings. If you consider that we have been unable to satisfactorily resolve your concerns about our handling of your personal information, you can contact the Office of the Australian Information Commissioner: Email: enquiries@oaic.gov.au Phone: 1300 363 992 Post: Office of the Australian Information Commissioner GPO Box 5218 Sydney NSW 2000 Please visit the OAIC website at www.oaic.gov.au for further information.

21 Changes to Stockland's Privacy Policy

We may update our Policy from time to time to take into account new laws and technology, changes to our operations and business practices. The most current version of this Policy is on our website at www.stockland.com.au/privacy-policy and we encourage you to check periodically to ensure that you have the most up to date version of our current Policy. By continuing to use the Stockland websites and/or the Stockland Marketplace and continuing to provide your personal information to us after these changes have been published, you consent to these updates to our Privacy Policy.

Effective: 20 January 2022