Goodman Limited (ABN 69 000 123 071) and Goodman Funds Management Limited (ABN 48 067 796 641; AFSL 223621) as responsible entity for the Goodman Industrial Trust (ARSN 091 213 839), and any of their controlled entities (“Goodman”, Goodman Group”, “we”, “us”, “our”) recognises the importance of protecting the privacy and rights of individuals in relation to their personal information.

This document is our privacy policy and it tells you how we collect and manage the personal information of the parties with whom we deal, including but not limited to our customers, contractors, agents and other third parties. We respect your rights to privacy under the Privacy Act 1988 (Cth) (Act) and we comply with all of the Act’s requirements in respect of the collection, management and disclosure of your personal information.

What is your personal information?
When used in this privacy policy, the term ‘personal information’ has the meaning given to it in the Act. In general terms, it is any information that can be used to personally identify you. This may include your name, address, telephone number, email address and profession or occupation. If the information we collect personally identifies you, or you are reasonably identifiable from it, the information will be considered personal information.

What personal information do we collect and hold?
We may collect the following types of personal information:

• name;
• mailing or street address;
• email address;
• telephone number;
• facsimile number;
• age or birth date;
• profession, occupation or job title;
• details of services you have enquired about, together with any additional information necessary to deliver those services and to respond to your enquiries;
  any additional information relating to you that you provide to us directly through our websites or indirectly through use of our websites or online presence, through our representatives or otherwise; and
• information you provide to us through our representatives or customer surveys from time to time.

We may also collect some information that is not personal information because it does not identify you or anyone else. For example we may collect anonymous answers to surveys or aggregated information about how users use our website.

How do we collect your personal information?
Goodman will collect your personal information directly from you unless it is unreasonable or impracticable to do so. When collecting personal information from you, we may collect in ways including:

• 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 may also collect personal information from third parties including:

• from third party companies such as credit reporting agencies, law enforcement agencies and other government entities.

Cookies
In some cases we may also collect your personal information through the use of cookies. When you access our website we may place a “cookie” (which is a small summary file containing a unique ID number) on your computer. This enables us to recognise you when you return and greet you each time you visit our website with any relevant preferences. It also enables us to keep track of services you view or preferences you have so that, if you consent, we can send you news about those services. We may also use cookies to measure traffic patterns, to determine which areas of our website have been visited and to measure transaction patterns in the aggregate. We use this to research our users’ habits so that we can improve our online services. Our cookies do not collect personal information. If you do not wish to receive cookies, you can set your browser so that your computer does not accept them.

We may 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.

What happens if we cannot collect your personal information?
If you do not provide us with the personal information described above, some or all of the following may happen:

• we may not be able to provide the requested services to you, either to the same standard or at all;
• we may not be able to provide you with information about our products and services that you may want; or
• we may be unable to tailor the content of our websites to your preferences and your experience of our websites may not be as enjoyable or useful.

For what purposes do we collect, hold, use and disclose your personal information?
We collect personal information about you so that we can perform our business activities and functions and provide best possible quality customer service.

We collect, hold, use and disclose your personal information for the following purposes:

• To inform you of updates concerning the Goodman Group;
• To provide services to you and to send communications requested by you;
• To provide you with access to protected areas of our website;
• To assess the performance of the website and to improve its operation;
• To conduct business processing functions including providing personal information to our related bodies corporate, contractors, service providers or other third parties;
• For the administrative, marketing (including direct marketing), planning, product or service development, quality control or research purposes of Goodman, its related bodies corporate, contractors or service providers;
• To provide your updated personal information to our related bodies corporate, contractors or service providers;
• To update our records and keep your contact details up to date;
• To process and respond to any complaint made by you; and
• To comply with any law, rule, regulation, lawful and binding determination, decision or direction of a regulator, or in co-operation with any governmental authority of any country (or political sub-division of a country).

Your personal information will not be shared, sold, rented or disclosed other than as described in this privacy policy.

To whom may we disclose your information?
We may disclose personal information to:

• Our employees, related bodies corporate, contractors or service providers for the purposes of operation of our website or our business, fulfilling requests by you and to otherwise provide services to you including, without limitation, share registry providers, custodians, web hosting providers, IT systems administrators, mailing houses, couriers, payment processors, data entry service providers, electronic network administrators, debt collectors, and professional advisors such as accountants, solicitors, business advisors, real estate agents and consultants;
• Suppliers and other third parties with whom we have commercial relationships for business, marketing and related purposes; and
• Any organisation for any authorised purpose with your express consent.

We may combine or share any information that we collect from you with information collected by any of our related bodies corporate.

Direct marketing materials
We may send you direct marketing communications and information about our services that we consider may be of interest to you. These communications may be sent in various forms, including mail, SMS, facsimile and email, in accordance with applicable marketing laws such as the Spam Act 2003 (Cth).

If you indicate a preference for a method of communication, we will endeavour to use that method whenever practical to do so. In addition, at any time you may opt-out of receiving marketing materials from us by contacting us (see the details below) or by using opt-out facilities provided in the marketing communications and we will then ensure that your name is removed from our mailing list. We do not provide your personal information to other organisations for the purposes of direct marketing.

How can you access and correct your personal information?
You may request access to any personal information we hold about you at any time by contacting us (see the details below). Where we hold information that you are entitled to access, we will try to provide you with a suitable means of accessing it (for example, by mailing or emailing it to you).

There may be instances where we cannot grant you access to the personal information we hold. For example, we may need to refuse access if granting access would interfere with the privacy of others or it would result in a breach of confidentiality. If that happens we will give you written reasons for the refusal.

If you believe that personal information we hold about you is incorrect, incomplete or inaccurate, then you may request us to amend it. We will consider if the information requires amendment. If we do not agree that there are grounds for amendment then we will add a note to the personal information stating that you disagree with it.

What is the process for complaining about a breach of privacy?
Goodman requests that complaints about breaches of privacy be made in writing, so we can be sure about the details of the complaint. Goodman’s Privacy Officer will normally deal with privacy complaints. Goodman will attempt to confirm as appropriate and necessary with you your understanding of the conduct relevant to the complaint and what you expect as an outcome. Goodman will inform you whether Goodman will conduct an investigation, the name, title, and contact details of the investigating officer and the estimated completion date for the investigation process.

After Goodman has completed its enquiries, we will contact you, usually in writing, to advise the outcome and invite a response to our conclusions about the complaint. If we receive a response from you, Goodman will assess it and advise if Goodman has changed its view. If you are unsatisfied with the outcome, Goodman will advise further options including, if appropriate, review by the Privacy Commissioner with the Office of the Australian Information Commissioner.

Do we disclose your personal information outside Australia?
We may disclose personal information to our related bodies corporate and third party suppliers and service providers located overseas for some of the purposes listed above.

We take reasonable steps to ensure that the overseas recipients of your personal information do not breach the privacy obligations relating to your personal information. We may disclose personal information to entities outside Australia, including the following:

• our related bodies corporate, located in New Zealand, United Kingdom, Belgium, Germany, France, Czech Republic, Spain, Sweden, Luxembourg, Slovenia, Poland, The Netherlands, Hungary, Japan, China, Hong Kong, United States, Brazil;
• our data hosting and other IT service providers, located in the United States, Belgium, Romania and India; and
• other third parties located in the Philippines.

Security
We take reasonable steps to ensure your personal information is protected from misuse and loss from unauthorised access, modification or disclosure. We may hold your information in either electronic or hard copy form. Personal information is destroyed or de-identified when no longer needed.

We cannot provide any assurance regarding the security of transmission of information you communicate to us online. We also cannot guarantee that the information you supply will not be intercepted while be transmitted over the public internet. Accordingly, any personal information or other information which you transmit to us online is transmitted at your own risk.

Links
Our website may contain links to other websites operated by third parties. We make no representations or warranties in relation to the privacy policies of any third party website and we are not responsible for the privacy policies or the content of any third party website. Third party websites are responsible for informing you about their own privacy practices.

Contacting us
If you have any questions about this privacy policy, any concerns or a complaint regarding the treatment of your privacy or a possible breach of your privacy, please use the contact link on our website or contact our Privacy Officer using the details set out below.

Privacy Officer: privacy@goodman.com

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/Europe: privacy.UKCE@goodman.com
United States: privacy.US@goodman.com
Greater China: privacy.HK@goodman.com
Japan: privacy-JP@goodman.com

Changes to our privacy policy
We may change this privacy policy from time to time. Any updated versions of this privacy policy will be posted on our website.

This privacy policy was last updated on 17 December 2013.