IFM Investors Pty Ltd (“IFM Investors”) and its subsidiaries (hereafter “IFM Group”, “we”, “our” or “us”) are committed to ensuring the confidentiality and security of your personal information and acting in accordance with your rights under the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and other applicable laws.
Information we collect
When you register with IFM Investors, we will collect personal information from you, which includes:
- email address; and
- contact numbers (including home number, mobile number, fax number and work number);
We will be unable to provide you with information and updates about the Offer unless you provide this information. We also collect general information such as the pages you access, the date and time of your visit, your IP address, cookie identifiers, and the domain name and country from which you access this website.
Unless we notify you otherwise, IFM Investors Pty Ltd is the controller for your personal data.
Communications undertaken through IFM Group Systems
All communications undertaken through IFM Investors and IFM Group systems (including, without limitation, email, text messages and instant messages) and all internet sites accessed are treated by IFM Investors and the IFM Group as business/work-related. IFM Investors and the IFM Group may monitor and, where relevant, intercept, your communications (whether sent or received and
including the content of such communications) where it is appropriate and necessary to do so. For the avoidance of doubt, such interception shall be deemed necessary where it is for the purpose of fact finding during the course of an investigation or actual or threatened litigation proceedings. IFM Investors and the IFM Group may carry out such monitoring and interception without providing further notice to you. You acknowledge and agree that monitored and intercepted communications may be used as evidence in disciplinary or legal proceedings.
How we use your information
We use your information for managing your registration and providing you with information you request.
Grounds for processing
Our use of your information as described above is permitted by applicable data protection lawbecause it is:
- necessary for our or others’ legitimate interests in pursuing the purposes set out above, such interests in each case not being overridden by your privacy interests. For more information on how this balancing test has been carried out, please contact firstname.lastname@example.org; and
- necessary to comply with a legal obligation to which IFM is subject.
Disclosure of your information
We will disclose personal information to the following third parties:
- Our service providers – We will share personal information with our service providers who assist us in performing our functions and services. These service providers will include our media and communications agents. When disclosing personal information to third party service providers, we shall ensure that such third parties comply with the relevant laws and regulations concerning the protection of personal information.
- Other organisations
- If we are reorganised or sold to another organisation, we may transfer information we hold about you to them so they can continue to provide services to you;
- If we are required to by law, under any code of practice by which we are bound or where we are asked to do so by a public or regulatory authority or governmental entity.
We also use ‘cookies’, which are small amounts of information stored on your computer’s hard drive that allow us to recognise your computer when you visit the site. Most browsers can be configured so as not to accept cookies, however this may affect the functionality of the website.
International transfers of personal information
Entities in the IFM Group may share personal information with each other (including sending information to its international offices) as well as funds advised by IFM Investors and their
subsidiaries, in each case for the purposes outlined in this notice. IFM may also share personal information with a third party carrying out services abroad for the IFM Group. This may result in your information being transferred from the European Economic Area (the “EEA”) to countries that the EU Commission has not declared to have an adequate level of data protection (e.g. Australia and the United Stated). IFM will not send your information to a party in another country, unless we have taken steps to ensure that the information will be protected to the standard required under the applicable privacy laws. To ensure an appropriate level of protection for personal information from the EEA, we typically use a data transfer agreement in the appropriate standard form approved for this purpose by the European Commission or (where applicable) relevant authority in the United Kingdom. Further details of these transfers and copies of these agreements are available from us on request.
Retention of your information
We will keep your personal information for the longer of the period required in order to meet our legal or regulatory responsibilities, and the period envisaged within our retentions policy. We will never retain your personal information for longer than is necessary. In most cases, our retention
IFM Investors uses appropriate security procedures and technology to keep your information secure. However, users should be aware that the transmission of information to or from the website may not be totally secure. We utilise the United States NIST Cybersecurity Framework to help frame our policy and to manage and assess our controls to prevent, detect and respond to security risks.
You have a number of rights under European Union data protection legislation which, in certain circumstances, you may be able to exercise in relation to the personal information we process about you.
- the right to access a copy of the personal information we hold about you;
- the right to correction of inaccurate personal information we hold about you;
- the right to restrict our use of your personal information;
- the right to be forgotten;
- the right of data portability;
- the right to object to direct marketing; and
- the right to object to our use of your personal information.
These rights are not absolute. If we do not comply with your request, we will explain why.
Where we rely on consent as the legal basis on which we process your personal information, you
may also withdraw that consent at any time.
If you have any questions or wish to exercise any of the above rights, you may send an email to email@example.com. You can also use this e-mail address if you wish to make a complaint about how we process your information.
IFM Investors’ registered address is Level 29, 2 Lonsdale Street, Melbourne, Victoria, Australia.
You can also lodge a complaint about our processing of your personal information with the relevant data protection authority in your country of residence.
Status of this privacy notice
This privacy notice was last updated in June 2022.
It may be subject to amendments. Any future changes or additions to the processing of personal data as described above in this privacy notice affecting you will be communicated to you through an appropriate channel, depending on how we normally communicate with you.