PRIVACY POLICY

1. We respect your privacy

(a) We respect your right to privacy and are committed to safeguarding the privacy of our customers and website visitors. We adhere to the Australian Privacy Principles contained in the Privacy Act 1988 (Cth). This policy sets out how we collect and treat your personal information.

(b) "Personal information" is information we hold which is identifiable as being about you.

2. Collection of personal information

(a) Sinclair Brook will, from time to time, receive and store personal information you enter onto our websites, provided to us directly or given to us in other forms.

(b) Sinclair Brook only collects personal information where we consider it to be reasonably necessary for our business functions or activities.

(c) Sinclair Brook only uses personal information for the purpose specified or which is reasonably apparent at the time the information was collected, or for a related purpose for which the individual would reasonably expect it to be used.

(d) The kinds of personal information that we may collect include:

· your name, date of birth, age, occupation and employment details;

· your postal address, email address and telephone number;

· information about individuals who wish to purchase or express an interest to purchase property from us;

· information about individuals who wish to lease spaces and relevant information reasonably necessary to grant a lease;

(e) Additionally, we may also collect any other information you provide while interacting with us.

(f) We may receive personal information from other parties that we deal with. If we do, we will protect it as set out in this Privacy Policy

3. Use of your personal information

(a) Sinclair Brook may use personal information collected from you to provide you with information and updates relating or our projects or services. We may also make you aware of new and additional projects, services and opportunities available to you. We may use your personal information to improve our projects and services and better understand your needs.

(b) Sinclair Brook may contact you by a variety of measures including, but not limited to telephone, email, sms or mail.

4. Disclosure of your personal information

(a) We engage with a range of third parties in order to operate our business and provide services. We may disclose personal information to third parties for the same purposes as are set out in paragraph 3 above.

(b) Organisations to which we may disclose your personal information to include our contractors, consultants, professional advisers, agents and service providers insofar as reasonably necessary for the purposes set out in this Policy.

(c) We may from time to time need to disclose personal information to comply with a legal requirement, such as a law, regulation, court order, subpoena, warrant, in the course of a legal proceeding or in response to a law enforcement agency request.

(d) We may also use your personal information to protect the copyright, trademarks, legal rights, property or safety of Sinclair Brook, its customers or third parties.

(e) Information that we collect may from time to time be stored, processed in or transferred between parties located in countries outside of Australia.

(f) If there is a change of control in our business or a sale or transfer of business assets, we reserve the right to transfer to the extent permissible at law our user databases, together with any personal information and non-personal information contained in those databases. This information may be disclosed to a potential purchaser under an agreement to maintain confidentiality. We would seek to only disclose information in good faith and where required by any of the above circumstances.

(g) By providing us with personal information, you consent to the terms of this Privacy Policy and the types of disclosure covered by this Policy. Where we disclose your personal information to third parties, we will request that the third party follow this Policy regarding handling your personal information.

(h) Sinclair Brook does not sell personal information.

5. Security of your personal information

(a) Sinclair Brook is committed to ensuring that the information you provide to us is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.

(b) The transmission and exchange of information is carried out at your own risk. We cannot guarantee the security of any information that you transmit to us or receive from us. Although we take measures to safeguard against unauthorised disclosures of information, we cannot assure you that personal information that we collect will not be disclosed in a manner that is inconsistent with this Privacy Policy.

6. Websites

(a) When you visit our websites

When you come to our websites (including sinclairbrook.com.au) we may collect certain information such as browser type, operating system, website visited immediately before coming to our site, etc. This information is used in an aggregated manner to analyse how people use our site, such that we can improve our service.

(b) Cookies

We may from time to time use cookies on our websites. Cookies are very small files which a website uses to identify you when you come back to the site and to store details about your use of the site. Cookies are not malicious programs that access or damage your computer. Most web browsers automatically accept cookies but you can choose to reject cookies by changing your browser settings. However, this may prevent you from taking full advantage of our websites. Our websites may from time to time use cookies to analyses website traffic and help us provide a better website visitor experience. In addition, cookies may be used to serve relevant ads to website visitors through third party services. These ads may appear on other websites you visit.

Our site may from time to time have links to other websites not owned or controlled by us. These links are meant for your convenience only. Links to third party websites do not constitute sponsorship or endorsement or approval of these websites. Please be aware that Sinclair Brook is not responsible for the privacy practises of other such websites. We encourage our users to be aware, when they leave our website, to read the privacy statements of each and every website that collects personal identifiable information.

7. Complaints about privacy

(c) If you have any complaints about our privacy practises, please feel free to send in details of your complaints to GPO Box 4540, Melbourne, Victoria, 3001 or info@sinclairbrook.com.au. We take complaints very seriously and will respond shortly after receiving written notice of your complaint.

8. Changes to Privacy Policy

(d) Please be aware that we may change this Privacy Policy in the future. We may modify this Policy at any time, in our sole discretion and all modifications will be effective immediately upon our posting of the modifications on our website or notice board. Please check back from time to time to review our Privacy Policy.

Last Updated: 11th August 2021