1. Our commitment to protect your privacy
The laws of certain countries require us to provide you with additional information about our processing activities and we have included a separate appendix to deal with these. As well as this document, please refer to the appendix if it applies to you.
2. The Personal Data we collect
We may collect and process some or all of the following Personal Data about you:
- Information about you - Your personal information such as your name, gender, date of birth, nationality, contact details, photographs and other images;
- Your payment details - Account and billing information;
- Our interactions with you - A record of any interactions and correspondence between us such as any interactions you have with our team members and any interactions with us or posts that refer to us on social media;
- Survey information - Your responses to customer surveys conducted by us or on our behalf;
- Your use of our website, apps and social media platforms - Details of your visits to our website, your use of social media platforms and our mobile applications and other information collected through cookies and other tracking technology including information that you look at. We may also collect information about you that is publicly available online, including your social media profiles.
3. What happens if we cannot collect Personal Data
Certain Personal Data (particularly payment details and contact information) are required for many of our products and services and if you fail to supply such Personal Data as requested for specific services, we may be unable to deliver you the products and services in full or provide you with information about these products or services.
If you do not provide us with Personal Data we may not be able to tailor the content of our websites to your preferences and your experience of our websites may not be as enjoyable or useful.
4. How we collect Personal Data
We may collect some Personal Data from you directly:
- through your access and use of our website;
- during conversations between you and our representatives; or
- when you make an enquiry, complete an application or purchase order.
We will collect other Personal Data from third parties including credit reporting agencies, law enforcement agencies and other Governmental agencies.
5. Why we collect and use your Personal Data
When you share information with us, you help us make our services to you better. Here are some of the ways we may use your Personal Data:
- To provide our products or services to you - To provide our products or services that we provide to you.
- To provide customer support - For customer support purposes such as responding to your enquiries and requests or providing assistance to you.
- For marketing purposes - For providing you with marketing communications including to provide updates concerning Goodman, as explained in more detail in Section 7 below.
- To improve our products and services - For the purposes of improving our products and services for the benefit of our customers generally, including to confirm that our websites and web pages (including social media pages) function correctly and in accordance with your preferences and circumstances.
- For legal and administrative purposes - For legal and administrative purposes such as verifying and processing payment, screening against fraud, screening against money laundering and other criminal or unlawful activities, accounting, billing and audit purposes, developing, maintaining and testing our systems, for complaints handling and for understanding, exercising, enforcing or protecting our legal rights and those of others.
6. Who we share your Personal Data with
In certain circumstances, we may disclose your Personal Data to third parties as described below:
- Our service providers and members of the Goodman Group who process personal data on our behalf for the purposes described in Section 5 above - We will permit our third party service providers, including agents, contractors and other Goodman Group companies, to use your Personal Data on our behalf for the purposes described above. Examples of such third parties include operators of our IT systems, web hosting providers, share registry providers, custodians and professional advisors.
- Our third party partners, for marketing purposes - We may disclose your Personal Data to third parties so they can provide marketing services or conduct marketing or social interaction activities on our behalf such as campaigns, market research, customer surveys and data analytics to help us improve and tailor our marketing activities, products and services.
- Government and regulatory bodies and other individuals, bodies and organisations - We may disclose your Personal Data to governments and regulatory authorities and bodies and to other individuals, bodies and organisations such as dispute resolution, prosecution and law enforcement bodies, legal advisers, organisations which conduct credit, fraud checks, and other individuals, bodies and organisations for the purposes of complying with our legal obligations. We may also disclose your Personal Data to such individuals, bodies and organisations for reasons of safety and security, to enable us to provide our products and services to you and otherwise for legal and administrative purposes.
We may use Personal Data for marketing and promotional purposes, including:
- for sending or showing you updates on latest news, offers and promotions in connection with our products and services (and the products and services of our group companies and third parties).
- for tailoring and tracking your interactions with internet banner advertisement and links from third party websites to our website.
- We may also use Personal Data to analyse our customers’ preferences and market trends and derive insights, which we may use to tailor the types of products and offers that we present to you.
We may communicate marketing and promotions to you by post, telephone, or online (including by email or through your mobile device or via online banner advertisement) and, as appropriate and where required, we will ask you for your consent, or otherwise provide you with the opportunity to choose not to receive marketing, at the time we collect your data.
We will provide an option to unsubscribe or opt out of further communication on any direct marketing communication sent to you. You may also opt out by contacting us as set out in Section 9 below.
Please note that if you choose to unsubscribe or opt out of marketing communication, we will still send you communications about [the services/product] and any other services that we provide to you.
8. Transmission, storage and security of your Personal Data
No data transmission over the Internet, a website, mobile application or via email or other message service can be guaranteed to be secure from intrusion. However, we maintain commercially reasonable physical, electronic and procedural safeguards to protect your Personal Data in accordance with the requirements of data protection legislation.
All Personal Data we collect about you is stored on our or our subcontractors’ secure servers. We comply with our security policies and standards when accessing or using this information and restrict access to your Personal Data to those persons who need to use it for the purpose(s) for which it was collected. You are responsible for keeping any information that we send to you confidential and for complying with any other security procedures that we notify you of. In particular, where we have given you (or where you have chosen) a password which enables you to access certain parts of our website or mobile applications, we ask you not to share a password with anyone.
Exporting your Personal Data
Your Personal Data may be transferred outside the country in which you are located, including to countries with a lower level of data protection than in the country in which you are located.
We will retain your Personal Data for as long as is necessary for the processing purpose(s) for which it was collected and any other permitted linked purpose (for example where we are required to retain personal data for longer than the purpose for which we originally collected it in order to comply with certain regulatory requirements). Our retention periods are based on business needs and your information that is no longer needed is either irreversibly anonymised (and the anonymised information will be retained) or securely destroyed.
9. Your rights and contacting us
You have the right (subject to various exceptions and in accordance with data protection legislation in your country) to access certain Personal Data held about you and correct any inaccuracies. We may charge a reasonable fee for the processing of any data access request in accordance with data protection legislation in your country. You also have the right to raise a complaint about our processing with the data protection regulator in your jurisdiction.
Right to opt out of direct marketing
You have the right to ask us not to process your Personal Data for direct marketing purposes. You can exercise your right to prevent such processing by indicating that you do not consent to direct marketing at the point at which we collect your Personal Data. You can also exercise the right at any time after we have collected and used your Personal data for direct marketing purposes by following the opt-out instructions contained in the relevant communications.
We will take reasonable steps to try and guarantee that your Personal Data is accurate. To help us do this, please notify us of any changes to your Personal Data.
Please contact us using the details set out below:
Level 17, 60 Castlereagh Street, Sydney NSW 2000 + 61 2 9230 7223
For any privacy queries in the following regions please contact:
New Zealand: privacy.NZ@goodman.com
United Kingdom/Continental Europe: privacy.UKCE@goodman.com
United States: privacy.US@goodman.com
Greater China: privacy.HK@goodman.com
We log IP addresses (that is, the electronic addresses of a computer connected to the internet) to analyse trends, administer the website, track users movements and gather broad demographic information.
11. Links to other sites
This website contains links to other sites that are operated by third party companies with different privacy practices. You should remain alert when you leave our site and read the privacy statements of other websites. We have no control over Personal Data that you submit to or receive from these third parties.
This Appendix applies if you are based in the European Economic Area (the EEA) during your interactions with us.
1. Why we collect your data, and who we disclose it to
|Purpose of the data processing
(the specified ground may vary depending on the specific processing activity and particular personal data being processed)
|To provide our products and services to you (4.1(a))
- Contract performance
- Legitimate interests (to allow us to provide our services)
For sensitive Personal Data
|To provide customer support (4.1(b))
- Contract performance
- Legal obligation
- Legitimate interests (to allow us to correspond with you in connection with our services)
|For marketing purposes (4.1(c))
- Legitimate interests (to allow us to inform business partners of relevant news and events)
- Consent (which can be withdrawn at any time)
|To improve our products and services (4.1(d))
- Legitimate interests (to allow us to maintain and improve the quality of our services and products)
|For legal and administrative purposes (4.1(e))
- Contract performance
- Legal obligation
- Legal claims
- Legitimate interests (to allow us to guard against fraud and other unlawful activity)
For sensitive Personal Data
- Legal claims
- Substantial public interest
2. Special categories of Personal Data
If we collect and handle sensitive Personal Data (for example medical and health data, ethnicity and race), we will typically ask you for your consent when collecting and handling this type of Personal Data, unless we are otherwise permitted to process such Personal Data under European data protection law or the laws of the EU member state in which you are based.
3. Legal grounds for use of Personal Data
The legal grounds for our use of Personal Data are as follows:
- Contract performance: where we are required to collect and handle your Personal Data in order to provide you with the services that we have contractually agreed to provide to you, e.g. contact details of a customer (tenant) of one of our properties.
- Legal obligation: where we need to use your Personal Data to comply with our legal obligations.
- Vital interests: where we need to process your Personal Data in order to protect the vital interests of you or another natural person, e.g. where you require urgent assistance.
- Public interest: where we need to process your Personal Data in order to carry out a task that is in the public interest.
- Legitimate interests: where we have a legitimate interest in using your information. We will only rely on this legal ground if we consider that our interest in using your Personal Data for the relevant purpose is not outweighed by any interests that you may have, or any prejudice that you may suffer, from the relevant use of your Personal Data.
The legal grounds for our use of the sensitive categories of Personal Data are:
- Vital interest: where we need to process your Personal Data in order to protect the vital interests of you or another natural person where you or the other person is physically or legally incapable of giving consent.
- Legal claims: where your Personal Data is necessary for us to establish, exercise of defend any legal claims.
- Substantial public interest: where we need to process your Personal Data for reasons of substantial public interest set out in EU law or the laws of the member state in which you are based.
4. Our decision-making processes
In connection with our business, we will use your Personal Data to make various decisions about you and your eligibility to access our services, to prevent abusive use of our services, to confirm security of our systems, or to detect fraud.
5. Export outside the EEA
Your Personal Data may be accessed by team members or suppliers, transferred, and/or stored outside the EEA, including to countries which may have a lower level of data protection than under EU DP law.
We must comply with specific rules when we transfer Personal Data from inside the EEA to outside the EEA. When we do this, we will use appropriate safeguards to protect any Personal Data being transferred.
We will transfer your Personal Data subject to European Commission approved contractual terms that impose different data protection obligations directly on the recipient, or as otherwise permitted under EU DP Law.
6. Retention period
Our retention periods for Personal Data are based on business needs and legal requirements. We will retain your Personal Data for as long as is necessary for the processing purpose(s) for which it was collected and any other permitted linked purpose. For example, we may retain: (i) certain transaction details and correspondence until the time limit for claims arising from the transaction with us has expired (which is typically between 6 to 10 years after the relevant transaction occurred, and in some cases much less than this); or (ii) certain data to comply with regulatory requirements regarding the retention of such data. Where Personal Data is no longer needed, we either irreversibly anonymise the data (in which case we may further retain and use the anonymised data) or securely destroy the data.
7. Your rights
- provide you with further details on how we use and process your Personal Data;
- delete Personal Data we no longer have grounds to process; and
- restrict how we process your Personal Data whilst we consider an inquiry you have raised.
Please note that we will not charge a fee when we deal with your requests in the exercise of the above rights.
In addition, under certain conditions, you have the right to:
- where processing is based on consent, withdraw the consent; and
- object to any processing of Personal Data that we process on the “legitimate interests” or “public interests” grounds, unless our reasons for the underlying processing outweighs your interests, rights and freedoms.
- object to direct marketing (including any profiling for such purposes) at any time.
These rights are subject to certain exemptions to safeguard the public interest (e.g. the prevention or detection of crime) and our interests (e.g. the maintenance of legal privilege). We will aim to respond to requests within 30 days.
If we are unable to resolve an inquiry or a complaint, you have the right to contact the data protection regulator in the country in which you are based.
8. Data Controllers
As a global organisation, there are a number of entities through which Goodman is operating in the EEA. Depending on the location of our business, any of the following entities of the Group may be the data controller in relation to your personal data, solely or together with other group entities:
Goodman Belgium NV, Medialaan 50, 1800 Vilvoorde, Belgium
Goodman Management Services (Belgium) NV, Medialaan 50, 1800 Vilvoorde, Belgium
T: +32 2 263 40 00
Goodman Management Holdings (Lux) S.à r.l., 5, rue de Strasbourg, L-2561 Luxembourg, Grand Duchy Luxembourg
GELF Management (Lux) S.à r.l., 5, rue de Strasbourg, L-2561 Luxembourg, Grand Duchy Luxembourg
GJL Management (Lux) S.à r.l., 5, rue de Strasbourg, L-2561 Luxembourg, Grand Duchy Luxembourg
T: +35 226 363 220
Goodman France S.à r.l., 24 rue de Prony , 75017, Paris, France
T: +33 1 55 35 08 50
Goodman Germany GmbH, Peter-Müller-Straβe 10, 40468, Düsseldorf, Germany
T: +49 211 49 980
Goodman Italy srl, Largo Augusto 3, 20122, Milan, Italy
T: +39 342 876 86 15
Goodman Netherlands BV, Strawinskylaan 1225, Tower B, Level 12, 1077 XX, Amsterdam, Netherlands
T: +31 20 709 39 30
Goodman Real Estate (Spain) S.L., C/ Claudio Coello, nº 124 – 7ª planta, 28006, Madrid, Spain
T: +34 91 414 15 50
Goodman UK Limited
Goodman Logistics Management (UK) Limited
Goodman Logistics Developments (UK) Limited
Goodman Real Estate Adviser (UK) Limited
Goodman Operator (UK) Limited
each of Nelson House, Central Boulevard, Blythe Valley Park, Solihull, West Midlands, B90 8BG
T: +44 20 3426 0800