Haben Property Fund Ltd ABN 89 139 914 775 and Haben Management Pty Ltd as trustee for The Haben Retail Management Unit Trust ABN 91 873 552 898 and their affiliates (collectively known as “Haben” and also referred to in this Policy as “us,” “we” and “our”) seek to provide the best possible service to our customers by providing the best possible range of financial products and services.
We understand how important it is to protect your personal information. This document sets out our Privacy Policy commitment in respect of personal information that you may provide to us.
We recognise that any personal information we collect about you will only be used for the purposes indicated in our policy, where we have your consent to do so, or as otherwise required or authorised by law. It is important to us that you are confident that any personal information we collect from you or that is received by us will be treated with appropriate respect ensuring protection of your personal information.
Our commitment in respect of personal information is to abide by the Privacy Act 1988 (Cth) as amended (including the Australian Privacy Principles) (Privacy Act) and any other relevant law.
Haben is an organisation that offers financial products and services to approved customers. We are a fund manager investing in and managing property assets. We may also market our products and services.
When we refer to personal information we mean information or an opinion about you, from which you are, or may reasonably be, identified.
This information may include (but is not limited to) your name, date of birth, driver’s licence number, marital status, phone number, email address, address, nationality, employment history, income, assets and liabilities.
It is not common practice for us to collect other sensitive information about you (such as information about your religion, trade union membership, political opinion, sexual preference or criminal record). We will only collect sensitive information about you with your consent.
We collect and receive personal information about you in order to conduct our business, including assessing and obtaining approval for Haben’s wholesale managed funds and other products and accepting investments. From time to time we may offer other products and services.
Personal information may be collected by us in a number of circumstances, including when an individual:
Where reasonable and practical we will collect your personal information only directly from you. However, we will also collect information about you from third parties such as from our contractors who supply services to us, through our referrers (such as financial advisers), from a publicly maintained record or from other individuals or companies as authorised by you.
If you do not provide the information requested by us, we may not be able to provide you with our services.
If you provide personal information to us about someone else, you must ensure that you are entitled to disclose that information to us and that, without us taking any further steps required by privacy laws, we may collect, use and disclose such information for the purposes described in this Privacy Policy. For example, you should take reasonable steps to ensure the individual concerned is aware of the various matters detailed in this Privacy Policy. The individual must also provide the consents set out in this Privacy Policy in respect of how we will deal with their personal information.
We use your personal information for the purpose for which it has been provided, for reasonably related secondary purposes, any other purpose you have consented to and any other purpose permitted under the Privacy Act. This may include using your personal information for the following purposes:
To enable us to maintain a successful business relationship with you, we may disclose your personal information to:
By providing us with your personal information, you consent to us disclosing your information to such entities without obtaining your consent on a case by case basis.
Sometimes we are required or authorised by law to disclose your personal information. Circumstances in which we may disclose your personal information would be to a Court, Tribunal or law enforcement agency in response to a request or in response to a subpoena or to the Australian Taxation Office.
We may from time to time transfer personal information outside Australia in accordance with the Privacy Act to countries whose privacy laws do not provide the same level of protection as Australia’s privacy laws. For example, we may transfer your personal information to the One Registry Azure Australia East datacentre located in New South Wales. We may also use cloud storage and IT servers that are located offshore.
By providing us with your personal information, you consent to us disclosing your information to entities located outside Australia and, when permitted by law to do so, on the basis that we are not required to take such steps as are reasonable in the circumstances to ensure that any overseas recipient complies with Australian privacy laws in relation to your information.
From time to time we may use your personal information to provide you with current information about our products, special offers you may find of interest, changes to our organisation, or new products or services being offered by us or any company we are associated with. By providing us with your personal information, you consent to us using your information to contact you on an ongoing basis for this purpose, including by mail, email, SMS, social media and telephone.
If you do not wish to receive marketing information, you may at any time decline to receive such information by contacting our Privacy Contacts using the contact details below. We will not charge you for giving effect to your request and will take all reasonable steps to meet your request at the earliest possible opportunity.
Our shopping centres may notify customers that filming or photography may be taking place in and around where the notice is displayed (Filming Activity).
By entering that area, you consent to Haben (or a Filming & Photography Company) making an audio, audio-visual and/or photographic recording or image (Recording/Image) of your person, voice and/or image and any performance or interview you may give while you are in or around in areas displaying this notice/signed areas.
If you do not wish to be recorded or for your image to be taken by Haben or the Filming & Photography Company, you may wish to avoid those parts of the shopping centre in which the Filming Activity is occurring until the recording has finished. You may also speak to a Haben staff member present and discuss alternative options.
Haben will own all recordings/images made of you by Haben or the Filming & Photography Company while you are in or around the shopping centre including all rights in those recordings/images.
You also consent to the Filming & Photography Company and Haben and its related and subsidiary companies using such recordings/images, to the extent permitted by law, for any reporting, marketing and publicity purposes to promote the shopping centre without compensating you in any way. Where appropriate and feasible we may take steps to de-identify individuals in the background of footage taken when this material is being used for reporting, marketing and publicity purposes.
To the extent permitted by law, you agree to waive any and all rights you may have against Haben in respect of the recordings/images, and in addition discharge and release Haben from any and all liabilities, claims and/or demands of any kind or nature whatsoever, which you may have against Haben arising out of or related to the use of any recording/image or photograph involving you.
You acknowledge and agree that your personal data is subject to this Privacy Policy.
It is important to our relationship that the personal information we hold about you is accurate and up to date. During the course of our relationship with you we will ask you to inform us if any of your personal information has changed.
If you consider that any information we hold about you is incorrect, you should contact us to have it updated. We will generally rely on you to assist us in informing us if the information we hold about you is inaccurate or incomplete.
We will provide you with access to the personal information we hold about you, subject to limited exceptions in the Privacy Act as outlined below. You may request access to any of the personal information we hold about you, at any time.
To access personal information that we hold about you, use the contact details specified below. We may charge a fee for our reasonable costs in retrieving and supplying the information to you.
There may be situations where we are not required to provide you with access to your personal information. For example, such a situation would be information relating to an existing or anticipated legal proceeding with you, or if your request is vexatious.
An explanation will be provided to you if we deny you access to your personal information we hold.
In most circumstances it will be necessary for us to identify you in order to successfully do business with you, however, where it is lawful and practicable to do so, we will offer you the opportunity of doing business with us without providing us with personal information. Such a situation would be where you make general inquiries about interest rates or current promotional offers.
We will take reasonable steps to protect your personal information, including your credit-related personal information, by storing it in a secure environment, and when the information is no longer needed for any purpose for which the information may be used or disclosed, it will be destroyed or permanently de-identified.
We will also take reasonable steps to protect any personal information from misuse, loss and unauthorised access, modification or disclosure.
You may request further information about the way we manage your personal information or lodge a complaint by contacting our Privacy Officer(s) on the contact details below.
We will deal with any complaint by investigating the complaint, and providing a response to the complainant within 15 business days, provided that we have all necessary information and have completed any investigation required. In cases where further information, assessment or investigation is required, we will seek to agree alternative time frames with you.
If you feel your complaint has not been satisfactorily addressed in the first instance, or that it is taking too long to resolve, you may contact the Office of the Australian Information Commissioner (OAIC) to have the complaint heard and determined. To contact the OAIC call 1300 363 992 or find them online at www.oaic.gov.au.
You can contact us by calling us on +61 2 9302 5900 or by writing to:
The Privacy Officer
Haben Property Fund Ltd
Level 4, 36 Cross Street
Double Bay NSW 2028
We are constantly reviewing all of our policies and attempt to keep up to date with market expectations. Technology is constantly changing, as is the law and market practices.
As a consequence we may change this Privacy Policy from time to time or as the need arises.
This Privacy Policy was last updated on 27 May 2025.