Functions & Activities

Its key activities include:

• Asset management: Midas Touch Towers owns and manages assets across the residential,  commercial and industrial sectors;
• Development: Midas Touch Towers develops smart, sustainable and resilient residential and commercial assets.

For more information regarding Midas Touch Towers, please visit our website: www.midastouchtowers.com.

Collection of Personal Information

Personal information is defined as information or an opinion that can identify or can reasonably identify an individual. This may include an individual’s name, address, email address and telephone numbers. The type of personal information that Midas Touch Towers collects will depend upon what dealings the relevant individual may have with Midas Touch Towers.

Midas Touch Towers may collect and hold personal information about individuals who:

• purchase, or express an interest to purchase, a Midas Touch Towers home or apartment (for example, when entering into a sale and purchase agreement, or when responding to requests for information about a Mirvac home or apartment)
• register or subscribe for electronic newsletters (either in person at one of our shopping centres or online) customer loyalty programs, competitions or promotions run by Midas Touch Towers;
• hire mobility equipment in a Midas Touch Towers managed shopping centre;
• enter a Midas Touch Towers managed shopping centre, building or car park (for example, our camera surveillance systems (commonly referred to as CCTV) may collect footage or still images of individuals and vehicles as well as licence plate details for security purposes or at some Midas Touch Towers managed buildings, visitors are required to register before entry for building safety purposes);
• park in a Midas Touch Towers managed car park that has a ticketless parking system (Midas Touch Towers may collect licence plate details and in certain circumstances, name, email address and telephone number to measure parking duration and to provide data to improve the management of the car park);
• use mobile applications developed by Midas Touch Towers or logon to wireless facilities provided in a Midas Touch Towers managed building or shopping centre;
• lease, or express an interest to lease, premises, or spaces (including retail pop up spaces), including any related guarantors (for example, when negotiating, entering into or applying to enter into a lease with Midas Touch Towers).
• seek employment with Midas Touch Towers or are Midas Touch Towers employees (for example, when conducting background checks for the purposes of employment);
• supply goods and services (for example, when establishing records and systems to enable payment for goods).
• are security holders in Midas Touch Towers securities or who invest in Midas Touch Towers investment vehicles (for example, when establishing accounts and carrying out due diligence). In the case of Midas Touch Towers Securities, Midas Touch Towers may collect personal information of its security holders from its external registry service provider, Link Market Services Limited;
• use Midas Touch Towers websites, social media and other online services;
• may otherwise come into contact with Midas Touch Towers; or
• are provided loans or other financial accommodation by Midas Touch Towers. 

Midas Touch Towers only collects personal information which is reasonably necessary for its dealings with the relevant individual. The types of personal information may include, but are not limited to:

• information that identifies the individual (for example, name, gender, address, contact details, date of birth, photographic or video images); 
• information needed verify an individual’s identity such as driver licence number; 
• information about the individual’s financial position and credit-worthiness; 
• an individual’s employment history, and other information an individual provides as part of the recruitment process; 
• information including an individual’s image collected via our CCTV systems; 
• information about the individual that is required or authorised by law; 
• the individual’s tax file number; 
• the individual’s opinion/preferences about Midas Touch Towers products, services or staff. 

The Privacy Act imposes restrictions on collecting sensitive personal information such as information about religious views, ethnicity, political opinions and personal health.

Midas Touch Towers generally does not collect sensitive personal information about an individual. However, in certain circumstances, Midas Touch Towers may collect some sensitive information if it is necessary to allow Midas Touch Towers to deal with the individual and provided the individual has given consent for Midas Touch Towers to do so.

Whenever it is reasonable and practical to do so, Midas Touch Towers collects personal information directly from the individual. However, in some circumstances, personal information may be provided to Midas Touch Towers by other parties such as the individual’s agent, employees or Midas Touch Towers authorised agents, service providers and subcontractors. Midas Touch Towers will take reasonable steps to inform the individual that it has the individual’s personal information, unless it is obvious from the circumstances.

Notification of Collection of Personal Information

When Midas Touch Towers collects personal information, Midas Touch Towers will generally provide notification of the collection to the individual to inform the individual about the purpose for the collection, the types of entities that the information is disclosed to, the overseas recipients the information is disclosed to (where applicable), and that the Midas Touch Towers Privacy Policy contains information about how the individual may access the personal information held by Mirvac and how the individual may make a complaint.

Use & Disclosure of Personal Information

Midas Touch Towers operates a number of businesses which handle personal information. Midas Touch Towers policy is only to use personal information for the purpose which was either specified or reasonably apparent at the time when the information was collected. Midas Touch Towers may also use or disclose the information collected for any other related purpose for which the individual would reasonably expect it to be used.

If Midas Touch Towers wishes to use or disclose the personal information in other circumstances, it needs to obtain the individual’s consent to do so.

In general, Midas Touch Towers uses personal information for the following purposes:

• providing products or services that have been requested;
• communicating with the individual;
• assessing the suitability of prospective tenants;
• helping Midas Touch Towers manage and enhance its products and services, including analysing customer feedback and future customer needs;
• providing ongoing information and marketing about products and services to individuals that Midas Touch Towers believes may be interested and where the individual has signed up;
• managing security and safety requirements in Midas Touch Towers managed buildings and sites;
• complying with regulatory and legal obligations;
• recruiting employees and contractors; or
• fulfilling its obligations to employees.

Marketing

The individual’s prior consent will be obtained before personal information is used for marketing purposes in situations where the personal information has been collected from the individual and the individual would not reasonably expect Midas Touch Towers to use the information for that purpose, the personal information has not been collected directly from the individual or where sensitive information is involved.

If the customer no longer wishes Midas Touch Towers to use his or her personal information in order for Midas Touch Towers to provide marketing materials, the customer is to advise Midas Touch Towers via the relevant method provided for in the electronic marketing message sent to the customer (e.g. via an ‘unsubscribe’ link) or to write to the Midas Touch Towers Privacy Officer (refer to contact details below). Midas Touch Towers will act and amend its records promptly.

Disclosing Personal Information to Other Parties

Midas Touch Towers may disclose personal information to other entities within the Midas Touch Towers.

External parties may be given access to personal information held by Midas Touch Towers in certain circumstances. These include, but are not limited to:

• Midas Touch Towers contractors, consultants, advisers and service providers who assist Midas Touch Towers in the operation of its business or to provide a customer service (for example, a company which helps maintain Midas Touch Towers computer systems or sends out Midas Touch Towers mail);
• joint venture partners for the purposes of seeking relevant regulatory approvals;
• third party lenders and insurers;
• the Australian Securities Exchange, the Australian Securities and Investments Commission and to other regulatory authorities or government agencies as agreed to or required by law;
• anyone authorised by a provider of personal information;
• relevant parties in situations when Midas Touch Towers is required by law to provide the information.

Midas Touch Towers limits the information disclosed to external parties to what is required for them to perform their services for Midas Touch Towers or the relevant individual, or what is required by law.

Midas Touch Towers generally requires these parties to agree to Midas Touch Towers Privacy Policy and to strict conditions governing how this information may be used and stored.

From time to time, Midas Touch Towers may disclose personal information to external parties located outside Australia to allow the external parties to perform their services for Midas Touch Towers.

These currently include organisations located in the countries listed in the Appendix. Midas Touch Towers will only disclose personal information overseas when it is necessary for the services provided by these external parties and when it is in accordance with the Australian Privacy Principles. This includes taking reasonable steps to ensure that the external party has appropriate data handling arrangements in place.

Midas Touch Towers does not sell personal information to entities outside the Midas Touch Towers.

Applying for Employment

Midas Touch Towers collects personal information from individuals who submit applications or register interest for employment with Midas Touch Towers. If the application is unsuccessful, Midas Touch Towers may retain the information in case a more appropriate opportunity becomes available. The unsuccessful applicant will be advised that they can contact Midas Touch Towers to request Midas Touch Towers not to retain the applicant’s information.

Security of Personal Information

Midas Touch Towers will take reasonable steps to protect personal information that it holds from unauthorised access, modification, misuse, interference and loss. Midas Touch Towers maintains physical security measures over its physical premises, and a range of computer and network security measures (such as systems access, firewalls, data encryption) over its electronic systems. Midas Touch Towers employees are required to maintain the confidentiality of any personal information held.

If other parties provide support services, Midas Touch Towers generally requires them to agree to appropriately protect the privacy of the information provided to them.

Access to Personal Information

Any individual can request access to the personal information Midas Touch Towers may hold about them. To obtain access to the information, the individual needs to write to the Midas Touch Towers Privacy Officer (refer to contact details below). Midas Touch Towerswill require evidence to verify the identity of the individual.

This service is free of charge unless the personal information requested requires preparation time. In this situation, Midas Touch Towers will provide an estimate of how much this service will cost and request agreement before proceeding.

In normal circumstances, Midas Touch Towers will provide the individual with access to the individual’s personal information. However, in some circumstances, there may be legal, regulatory or administrative reasons to deny the requested access. If access is denied, Midas Touch Towers will provide the individual with the reasons for doing so.

Changing Personal Information

If an individual wishes to change personal information that the individual believes may be inaccurate, out-of-date, incomplete, irrelevant or misleading, the individual may write to the Midas Touch Towers Privacy Officer requesting the information to be changed.

If Midas Touch Towers disagrees with the individual that the personal information should be changed, Midas Touch Towers will provide the individual with the reasons for doing so. The individual has the right to request that a notation be included with their personal information to indicate their disagreement with their personal information held by Midas Touch Towers.

Collection of  other Information

Midas Touch Towers may also collect the following information from you:

A cookie is a small data file that may be placed on the computer of a web user (usually in the browser software folder) during a visit to a Midas Touch Towers website. Cookies are necessary to allow the Midas Touch Towers website and the user’s computer to interact effectively and enhance security. Cookies can record information about the user’s visit to assist Midas Touch Towers in better understanding the needs of the user. For example, user traffic data may be collected and used to infer the website user’s demographic using various web analytic technologies. Midas Touch Towers sometimes also use performance tracking technology (such as conversion tags) to help Midas Touch Towers to track user behaviour on its websites. General such user traffic and performance tracking data is non-personally identifiable and is collected on an aggregate level to report statistics to assist Midas Touch Towers to improve the quality and relevancy of its services. However, if the user has completed the online registration form on Midas Touch Towers websites, such cookie data may be linked to the personal information Midas Touch Towers holds about the user. In these circumstances, this cookie data will be treated the same manner as the personal information which it has been linked.

• Midas Touch Towers may also use cookies from third party ad servers for the purpose of targeting our online advertisements on other sites. The cookies provided by the third party ad servers will collect information such as the device the user used to access the Midas Touch Towers website (such as the type of device, the browser type or the operating system), the user’s browsing behaviour (such as what the user searched for, the pages the user viewed, the date and time of the visit and how long the user stayed) and the performance of our marketing campaigns (such as which ads or online content the user viewed or accessed). The information collected through this technology is not personally identifiable but such information will be shared with the third party ad servers for the purposes of showing the user more relevant advertising on Midas Touch Towers websites or partner sites. If users of a Midas Touch Towers website do not wish to receive any cookies, they should set their browser to refuse cookies but this means that they may not be able to use certain parts of the Midas Touch Towers website. If the user does not want third party ad servers to use cookies for targeted advertising purposes, the user can use an opt out mechanism provided by various advertising industry bodies such as Network Advertising Initiative opt-out (http://www.networkadvertising.org/choices/DAA).

• Where electronic devices such as mobile phones and tablets are enabled to allow connectivity to and are detected by Wi-Fi networks (or similar) in Mirvac managed buildings or shopping centres, Midas Touch Towers may automatically collect data relating to the device identification code and its location. Midas Touch Towers may use the anonymised data to create aggregate information to, among other things, analyse shopping behaviour to improve its shopping centres, but the aggregate information will not identify the customers. If a customer does not wish to have their device identification code detected, they should disable the Wi-Fi network (or similar) connectivity of their device.When customers register to use Wi-Fi services provided by Midas Touch Towers, Midas Touch Towers collects their personal information in relation to their use of the Wi-Fi services, and for any other purposes they have consented to.

• Midas Touch Towers websites use, among other technologies, Google’s suite of analytics programs to track website traffic. Where users have chosen to enable Google to associate their web and app browsing history with their Google account, and to use information from their Google account to personalise ads, Google will use data from its signed-in users together with Midas Touch Towers Google Analytics data to build audience lists for cross-device remarketing. For users of Midas Touch Towers websites, Google Analytics will collect Google-authenticated identifiers associated with the user’s Google Accounts (and therefore, personal information). Google Analytics will also temporarily join these identifiers to Midas Touch Towers Google Analytics data. If a customer does not wish to have their Google-authenticated identifies joined with Midas Touch Towers Google Analytics data, they should opt out of the ‘personalised ads’ option via their Google account.

Changes in the Future

Additional Information on Privacy

For further information about privacy issues and the protection of privacy, visit the Office of the Australian Information Commissioner’s website at http://www.oaic.gov.au.

Approved & Adopted

This policy was approved and adopted by the Midas Touch Towers Holdings on 27 Feburary 2022.

Apendix –  Disclosure to other Countries

Updated 8th of September 2022

Personal information may be disclosed to third parties performing services for Midas Touch Towers located in the following jurisdictions:

• Dubai
• United States;
• China;
• Singapore; and
• United Kingdom.