1. About this policy
Sentumar Pty Ltd, Sentumar Investments Pty Ltd and any of its subsidiaries (collectively Sentumar, we, us, our) are committed to protecting the privacy of the personal information which we collect and hold.
We respect the privacy of any personal information that you may provide to us. The way we manage personal information is governed by:
Australia – the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles (APPs) established under the Privacy Act.
The kinds of information that we may collect about you and how that information is held and collected.
The purposes for which we collect, hold, use and disclose personal information.
How you can access the personal information we hold about you and seek to correct such information; and
The way in which you can complain about a breach of your privacy and how we will handle that complaint.
Personal information means information or an opinion about an individual whose identity is apparent or can reasonably be ascertained from that information or opinion: whether the information or opinion is true or not; and whether the information or opinion is recorded in a material form or not.
3. Collection and use of personal information
3.1 Types of personal information collected by Sentumar
We collect information about you which is necessary to assess and engage employment applicants. This includes collecting personal information such as your name, address, professional experience, qualifications, references, past employee details and any other information which is relevant to assist us assess your suitability for employment.
Persons making inquiries regarding self-storage, Co working & Ecommerce hub services
We collect information from you which is necessary to follow-up your inquiry and provide you with newsletters and marketing information. This includes collecting personal information such as your name, address, email address, telephone number and any other information which is necessary to assist Sentumar in providing information regarding self-storage, Co working & Ecommerce Hub services to you.
The type of information Sentumar collects and holds depends on its dealings with relevant individuals and may include the following:
- name, date of birth, gender and contact details including address(es), email address and telephone numbers
- bank account and credit card details
- identification documents such as drivers’ licence or passport
- incident details relating to our properties and workplaces
- enquiries, complaints and records of interactions
- registration and activity details relating to our online services including date and time of access, IP addresses and URL where you accessed our website from
- tax file numbers
- ABNs, insurance details and contact details
- CCTV surveillance footage within our properties
- employee information such as tax file number, training records, police check, contact details, references, qualifications, employment history, emergency contact details, leave, superannuation details and health and safety information, and
- any information that is required to be collected by law or in the necessary course of business.
3.2 How we collect personal information
We will in many cases collect your personal information directly from you for example face to face, over the telephone, via email or over the internet. In other cases, we may collect such information from third parties, for example:
- your agent, associate or representative, where this is reasonably necessary to allow us to deal with you
- public sources including social media, and
- the third parties listed below under ‘Disclosing your Personal Information’.
3.3 How Sentumar uses your personal information
We only use and disclose your personal information for the purpose for which it was collected by us (primary purpose), unless:
- there is another purpose (secondary purpose) and that secondary purpose is related to the primary purpose and you would reasonably expect it, for example where we have informed you that your information will be used for that secondary purpose,
- you have given your consent for your personal information to be used for a secondary purpose, or
- we are required or authorised by law to use your personal information for a secondary purpose (including for quality improvements within Sentumar).
We may collect, store, use and disclose your personal information to:
- provide self-storage, Co working & Ecommerce services to you
- protect the safety and security of our customers, staff, facilities and assets
- establish your identity and assess your application for storage & other related services
- contact you during the storage/Co working relationship
- provide you with information about your account, including billing and provision of notices
- provide you with information about our business and related entities, including promotions
- be able to answer questions from you about your account and our services
- manage our risk, including enabling us to undertake a search of the StorerCheck database, or any relevant credit history entity
- undertake appropriate searches, including a Personal Property Securities Register search, in the event that your account goes into default
- cooperate with enquiries from government and law enforcement bodies
- comply with our legal obligations and exercise and defend our legal rights
- enforce our agreement with you
- investigate and deal with unlawful activity and misconduct
- maintain and update our records
- complete required employment records and manage our staff
- facilitate business mergers, acquisitions and divestments.
Secondary purpose examples could include to:
- contact you about our facilities, business developments, products and services which may be relevant to you, unless you contact us to opt out
- appropriately manage our business, such as assessing insurance requirements and conducting audits
- compile statistics regarding inquiries and customer information for purposes of improving our services and tailoring our marketing
- assist in running our business, including quality assurance programs, billing, improving our services, record-keeping, implementing appropriate security measures and training personnel, and
- effectively communicate with third parties and any related bodies corporate.
We collect personal information under certain laws including the Income Tax Assessment Act and other tax laws, the Corporations Act, the ASX Listing Rules, Fair Work Act, Superannuation Guarantee (Administration) Act, occupational health and safety acts and workers compensation acts.
We are authorised to collect tax file numbers by certain tax and other laws. It is not compulsory for you to provide your tax file number in order to receive all of our services but, if you don’t there may be impacts for you, for example tax law may requires us to deduct tax from your distributions at the highest marginal rate.
3.4 Complete and accurate details
If we are unable to collect the personal information we seek about you, or it is incomplete or inaccurate, we may not be able to provide the services you are seeking or deal with you effectively.
Sentumar uses camera surveillance systems (commonly referred to as CCTV) for the purposes of maintaining safety and security of our business premises and facilities. Those CCTV systems may also collect and store personal information and we will comply with all privacy legislation in respect of any such information.
4. Disclosing your personal information
We may provide your personal information to:
third parties involved in providing services to you, such as:
- Storer Check Pty Limited ACN 129 521 848, an entity which operates a data base containing identification and collection of information about problem storers
- government law enforcement departments and regulatory authorities, such as State Police Departments, & the Federal Police.
- any person who can demonstrate to the satisfaction of Sentumar a legal or equitable interest in any stored goods
- liquidators, administrators, or other persons appointed to administer your financial affairs
- third parties contracted to provide services to Sentumar
- consultants such as auditors, accountants and lawyers, insurance companies, property managers and estate agents
- any of the related bodies corporate of Sentumar Pty Ltd & Sentumar Investments Pty Ltd
- your Alternate Contact Person (ACP)
- anyone authorised by you to receive your personal information (your consent may be express or implied), an
- anyone Sentumar is required or permitted by law to disclose your personal information to.
Some of these third parties may be located in Taiwan, Singapore, Finland, Chile, Belgium, North America, South America, New Zealand, Netherlands, Denmark and Ireland and other countries.
From time to time you may provide us with personal information about another individual, such as your nominated Alternate Contact Person (ACP). If you do so, you must ensure that you have the right to disclose information about the other individual including their personal information. You must take reasonable steps to ensure the individual is aware that:
- you have made this disclosure
- we may use this information as we would personal information collected about you, and
- they may access and correct the information held by us in the same manner as you.
As stated in 4.1(b) we subscribe to the StorerCheck system. By applying to store with us, including making a web or telephone enquiry, you agree to the following:
- We may search the StorerCheck data base for information StorerCheck may have about you.
- We may communicate with other users of the StorerCheck system and discuss your information with them.
- We may choose to refuse you storage, or terminate your storage agreement, if you are listed with StorerCheck.
- We may release or update any details and personal information StorerCheck have about you, including but not limited to:
- Your name.
- Your address.
- Your previous address(es).
- Your email address.
- Your licence number and details.
- Your passport number and details.
- Your date of birth.
- Your storage history, including account payment history.
- Your details and personal information will be released to StorerCheck in the event that you breach your storage agreement or engage in illegal or threatening behaviour including but not limited to:
- Not paying for storage.
- Dumping or abandoning goods.
- Being chronically late with payments.
- Being abusive or threatening to staff members or other storers.
- Eliciting the involvement of law enforcement agencies, such as law enforcement enquiries regarding your storage activities and the execution of search warrants against you, this facility or your storage/co working space.
- Any other breach of the storage / co working agreement.
We may use the information you provide during this application, including web or telephone enquiries, or information provided at any other time to update any listing you currently have with StorerCheck. If you do not consent to these terms, you should not apply for storage / co working space with us.
By applying to store with us you consent to the terms and conditions set out in this document and on-line at www.storercheck.com.au, including our right to search StorerCheck for your details, and to release your information and details to StorerCheck in certain circumstances. For further information about Storer Check Pty Ltd go to www.storercheck.com.au
5. Data storage, quality and security
All your personal information is stored securely by us or our third-party information storage providers, including overseas providers in Taiwan, Singapore, Finland, Chile, Belgium, North America, South America, New Zealand, Netherlands, Denmark and Ireland, in either hard copy or electronic form.
5.2 Data security
Sentumar strives to ensure the security, integrity and privacy of personal information, and we will take all reasonable steps to protect your personal information from misuse, interference, loss, unauthorised access, modification or disclosure. Sentumar reviews and updates (where necessary) our security measures considering current technologies. We take a number of steps to protect the security of your personal information. Depending on the information and other circumstances, those steps may include, security passes for access to our premises, network firewalls, access passwords on our computers and contractual protections where we use service providers to store information for us.
We also have policies and processes which govern document retention and data breach incidents. We endeavour to ensure that personal information is kept as current as possible and that irrelevant or excessive data is deleted or made anonymous as soon as reasonably practicable. However, some personal information may be retained for varying time periods to comply with legal and regulatory obligations and for other legitimate business reasons.
5.4 Online transfer of information
Despite the steps we take to protect the privacy of your personal information, no data transfer over the internet is 100% secure. When you share your personal information with Sentumar via an online process, we cannot guarantee the security of that information.
There are ways you can help maintain the privacy of your personal information, including:
- always closing your browser when you have finished your user session
- always ensuring others cannot access your personal information and emails if you use a public computer, and
- never disclosing your user name and password to third parties.
6.1 Google Analytics is used for Display Advertising
A 'cookie' is a small data file placed on your machine or device which lets us identify and interact more effectively with your computer. Cookies do not identify individual users, but they do identify your web requests, ISP (which can be used to locate your general location), browser type, browser language and the date and time of your request.
We use Google Analytics for Display Advertising which use a third-party DoubleClick cookie to collect data about the way you use our website and send various cookies to your browser. This allows us to collect demographical information about you such as your general location and gender. We uses the information which it collects about you so we can customise our website to suit the needs of our users and modify and market our services.
6.2 Remarketing, Display Networking Impression Reporting and Demographics and Interest Reporting
Sentumar uses Remarketing with Google Analytics to advertise its services and products online. Third party vendors, such as Google, show Sentumar's ads on internet sites and use first-party cookies and third-party cookies to load ads based on your prior visits to the Sentumar owned websites . This allows us to deliver advertising content specifically targeted to the interests you have expressed during those previous visits.
Sentumar may use Google Display Networking Impression Reporting to collect and process information about how its services and products are considered by customers online. We and other third-party vendors, including Google, use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) to report about customer impressions of Sentumar advertisements, other uses of advertisement services and how interactions with these advertisement impressions and services are related to visits to our site.
Sentumar may use Google Analytics Demographics and Interest Reporting to collect and process information about the demographics of its online customers. We will not collect any information via this method which can identify you, but may collect general demographic information including your age, gender, and interests which we may then use to target our advertisement campaigns and enhance our products and services.
6.3 Opting-out and controlling advertising cookies
You can prevent your data from being captured by Google Analytics which is used by us (in the ways outlined above) by opting-out of Google Analytics by downloading and installing the add-on for your web browser located at https://tools.google.com/dlpage/gaoptout/. More information about how we use Google Analytics can be found at https://www.google.com/analytics/terms/us.html.
You can re-set your browser to refuse all cookies or to receive a warning message with each cookie which you can then refuse by turning it off in your browser. Your internet service provider should be able to assist you to set your preferences.Unless you provide (or have provided) an e-mail address in the course of a visit to our website, we cannot identify you.
6.4 Social Media
7. Links to other sites
Sentumar may provide links to third party websites. These linked sites may not be under our control and Sentumar is not responsible for the content or privacy practices employed by those websites. Before disclosing your personal information on any other website, we recommend that you carefully read the terms and conditions of use and privacy statement available on the relevant website.
8. Accessing and amending your personal information
You have a right to access your personal information which Sentumar holds about you. If you make a request to access your personal information, we will ask you to verify your identity and specify the information you require.
You can also request an amendment to any of your personal information if you consider that it contains inaccurate information.
You can contact Sentumar about any privacy issues as follows:
The Privacy Officer - Sentumar Pty Ltd
96-98 Denison St, Hillsdale NSW 2036
PH: 02 9145 8088
Depending on the complexity of your complaint, we will usually aim to consider and respond to it within 7-30 days. We will use our best endeavours to resolve any complaint to your satisfaction. However, if you are not satisfied with our response, you are entitled to contact the Office of the Privacy Commissioner who may investigate your complaint further.
If you have a complaint about Sentumar's information handling practices or consider we have breached your privacy, you can lodge a complaint with:
the Privacy Officer, on the contact details listed in clause 8 above; or
the Office of Australian Information Commissioner
We will deal with complaints as follows:
Step 1: let us know
If you would like to make a complaint, you should let us know by contacting our Privacy Officer (see section 8 for contact details).
Step 2: investigation of complaint
Your complaint will be investigated by our Privacy Officer.
A response to your complaint will be provided in writing within a reasonable period.
Step 3: contact OAIC
We expect our procedures will deal fairly and promptly with your complaint. However, if you remain dissatisfied, you can also contact the Office of the Australian Information Commissioner.
OAIC Contact Details
Telephone: 1300 363 992 (if calling from outside Australia including Norfolk Island please call: +61 2 9284 9749)
National Relay Service:
TTY users: phone 133 677 then ask for 1300 363 992
Speak and Listen users: phone 1300 555 727 then ask for 1300 363 992
Internet relay users: connect to the National Relay Service then ask for 1300 363 992
Post: Office of the Australian Information Commissioner, GPO Box 5218, SYDNEY NSW 2001
Fax: +61 2 9284 9666
10. Data Breach
A data breach occurs when personnel information held by an entity is lost or subjected to unauthorised access, modification, disclosure or other misuse or interference.
In the event of a suspected or actual data breach, contact us by the method detailed in this website.
Sentumar has a data breach response plan which sets out procedures and clear lines of authority in the event of a data breach.
Where it is determined that notifiable data breach has occurred, we will report the breach to the Office of the Australian Information Commissioner and you as appropriate and in accordance with applicable laws.