PRIVACY COLLECTION NOTICE

Our policy statement

This Privacy Policy (“Policy”) explains how Levande Pty Ltd (ACN 087 648 691) an entity wholly owned by EQT Infrastructure V Investments Singapore Pte. Ltd. (EQT), our related companies and trusts ("Levande", “we”, “our” or “us”) collect, store, use, disclose and manage your personal information.

Purpose

By providing personal information to us, you consent to our collection, use, storage, disclosure and management of your personal information in accordance with the Privacy Act 1988 (Cth) ("Privacy Act") and this Policy.

What personal information do we collect?

The types of personal information Levande collects about you depends on the nature of your interactions with us. In this Policy, “personal information” has the meaning given to it in the Privacy Act and includes any information or opinion, whether true or not, about an identified individual or an individual who is reasonably identifiable.

We may collect the following types of personal information:

information to verify your identity including your name, date of birth, gender, address, email address and telephone number;
financial information including bank accounts, credit card details, your income and credit-worthiness;
details of your employment history, and other information provided as part of our recruitment process;
your preference of our products, services, facilities and lifestyle activities; information about you and your family and any characteristics, preferences or requirements that are relevant to the products and services that we may provide to you;
your image and/or voice and other personal information (such as your car licence plate) collected via CCTV surveillance systems installed in our retirement living communities;
your device ID, device type, geo-location information, IP address, browsing information and any personal information that you may provide to us directly or indirectly via our websites, Wi-Fi services, mobile applications; and
any other personal information that may be required in order to facilitate your dealings with us.

What sensitive information do we collect?

In this Policy, “sensitive information” has the meaning given to it in the Privacy Act and may include information about an individual's health or medical records. In some circumstances, we may collect sensitive information. For example, we may collect medical and health information about you in order to provide you with the best level of care or to assist us in responding to an emergency situation, or if you are involved in an accident, we may collect medical information and incident reports about the accident.

How is personal information collected?

We will generally collect personal information:

from you directly, when you communicate with us;
from you indirectly, anytime you communicate or interact with us, whether this is by phone, email, face to face meeting, online or social media interaction;
when you use our websites, applications or our Wi-Fi services;
your participation in our surveys, competitions or promotions;
when you visit our retirement living communities or through our CCTV systems; and
through our recruitment process when you apply for a position with us.
We may also collect your personal information from third parties such as:

marketing agencies, data collection and research organisations;
medical professionals (for example if you are involved in an accident);
credit reporting bodies, law enforcement and government entities; and
other individuals (for example employment references).

CCTV footage may also contain personal information, and as such its use and release is governed by additional policies. This is covered in more detail in the section dealing with access to personal information.

What happens if Levande cannot collect personal information?

You are not required to provide personal information to us. However, if you wish to deal with us anonymously or you decide not to provide us with the personal information described above, we may not be able to provide or tailor our products, services or information to you, either to the same standard or at all.

Why do we collect, use and disclose personal information?

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

to provide and market our products and services;
to communicate with you;
to do business with you;
for the general management and conduct of our business;
to comply with our legal obligations;
to assist with or investigate incidents (including potential incidents) which occur on or at our premises;
to consider the suitability of prospective employees;
for security and risk management purposes; and
to help us manage, develop and enhance our services, including our websites, Wi-Fi networks and applications.

To whom does Levande disclose personal information?

We may disclose your personal information (including in some circumstances, your sensitive information) to:

social media channels on which we have a presence such as Meta/Facebook, Twitter and Instagram or other similar social media channels, generally in these cases we limit disclosure of your information to the minimum personal information required for the purpose of its collection;
regulatory authorities, police or government agencies or bodies where required or permitted by law;
related parties, entities and trusts of Levande; and
other companies, service providers and individuals who assist us in providing our services or managing our operations (including employees or contractors, third party service providers involved in the management of our Villages, or consultants or agents acting on Levande's behalf).

In some circumstances, such as when responding to an emergency situation, we may need to disclose your personal information (including sensitive information) to a third party such as emergency services personnel, medical service providers or hospital personnel.

If any Levande entity is sold to a third party, we may transfer any personal information we hold about you to that third party. We may also disclose personal information on a confidential basis to prospective purchasers of a Levande entity.

CCTV at Levande sites and communities

We use CCTV surveillance systems to monitor and record activities at Levande’s retirement living communities to maintain a safe and secure environment for our employees, residents, customers and visitors to our premises.

This means we may use your personal information gathered from CCTV for security and risk management, loss prevention, incident investigation purposes and other purposes set out in this Policy if permitted by the law or otherwise with your consent.

We also use the data collected from our CCTV surveillance systems to maintain or improve our communities, premises and services.

When used for these purposes the data is aggregated anonymously. We do not identify individuals for these uses.

We securely discard the data collected from our CCTV surveillance systems when it is no longer required for business or legal purposes.

Free Wi-Fi service

We may offer a free Wi-Fi network service at certain Levande premises, which may include at some of our retirement living premises and offices.

If you are carrying a device within range of one of our Wi-Fi networks and have Wi-Fi and Bluetooth enabled, we may pick up certain data that is transmitted from your device whether or not you join our Wi-Fi network, including:

your device ID, device type, IP address and MAC address; and
geo-location information and any movement of your device throughout our premises.

If you request to join our Wi-Fi network, we may collect other personal information which you provide to us while accessing our Wi-Fi networks (for example, your name, email address, details of the websites or mobile applications whilst you are connected to our network).

We may also link this type of information to your provided personal information if we hold a common identifier such as your unique device identifier.

In each case, we will only use information or data collected via our free Wi-Fi network service in accordance with, and for the purposes set out in this Policy, or as permitted by the law.

If you do not want this information collected, you can disable Wi-Fi and Bluetooth on your device and elect not to sign into the Wi-Fi network.

Direct marketing communications

We and/or our third-party service providers may send you direct marketing communications and information about:

products, services, discounts, competitions and special promotions that we consider may be of interest to you;
offers or promotions based on how you use our products and services;
third party products and services (including offers and discounts we may have negotiated for our customers) we think may interest you.

These communications may be sent in various forms, including by telephone, post, fax, email, SMS or any other form of electronic communication, in accordance with the Privacy Act and the Spam Act 2003 (Cth) and Do Not Call Register Act 2006. If you consent to Levande and/or third party service providers we engage sending you direct marketing messages, we and/ or our third party service providers will send you the direct marketing messages described above.

Opting-out of other or all marketing communications

You may opt-out of any or all, direct marketing communications at any time by contacting the sender using the details set out in the communication (for example an unsubscribe link), or by contacting our Privacy Officer using the contact details below.

Email: privacy@levande.com.au

Post: Privacy Officer, Levande Level 18, 9 Castlereagh Street, Sydney NSW 2000

In some situations, for example if we are providing services to you, we may still be required to make certain communications to you in connection with providing those services or products to you, or as required by law.

Do we disclose personal information outside Australia?

We may disclose your personal information to the following overseas recipients:

related entities;
other companies, service providers and individuals who assist us in providing services or perform functions on our behalf (such as hosting and data storage providers); and
where we are required or authorised by law to do so.

The countries in which the recipients are likely to be located include Europe (including Sweden), Singapore, United States, Canada, Japan and India.

We will take reasonable steps to ensure that any overseas recipient deals with such personal information in a manner which is compliant with the Privacy Act.

Cookies

Cookies are pieces of information that a website transfers to your device to store and sometimes track information about your use of the website. We use cookies to distinguish you from other users in order to better serve you when you revisit our website.

You can set your browser to notify you when you receive cookies, providing you with the opportunity to either accept or reject it. You can also refuse all cookies by turning them off in your browser. If you refuse cookies, certain parts of our website may not function properly.

We handle personal information collected by cookies in the same way that we handle all other personal information as described in this Policy.

Security of Information

We may hold your personal information in either electronic or hard copy form. The confidentiality and security of your information is very important to us, and we take reasonable steps to protect your personal information from misuse, interference and loss, as well as unauthorised access, modification or disclosure.

We use a number of physical, administrative, personnel and technical measures to protect your personal information, and regularly test our security controls, however the open nature of the internet means there is always some risk that an unauthorised party might find ways to overcome our security measures, and it is not possible to guarantee the security of your personal information. You should also be aware that e-mail communications are not usually encrypted and should not be considered secure.

Where we no longer require your personal information for business or legal reasons, we will take reasonable steps to destroy or de-identify it.

Where required by applicable law, we will notify you, and the Office of the Australian Information Commissioner and/or other relevant regulatory authorities, of data breaches affecting your personal information.

Third party links

Our websites and mobile applications may contain links to websites owned and operated by other organisations. When you click on one of these links, you are moving to another website. Unless stated otherwise, we are not responsible for the privacy practices of, or any content on, those linked websites. We encourage you to read the privacy policies and other terms that apply to those websites as they may differ from this Policy, and if you have any privacy concerns, we encourage you to contact those website providers directly.

Access, update, correction and deletion of personal information

If you wish to seek access to, correct, delete or update your personal information that we hold about you, please contact our Privacy Officer using the contact details set out below. Depending on the nature of your request, we may ask you to provide us further information in order to verify your identity and ask you to put in writing the information you require.

There may be instances where we cannot grant you access to, or are not able to update or delete, the personal information we hold, for example, if a legal exception applies or where granting access would interfere with the privacy of others or result in a breach of confidentiality, or where we are required to retain or cannot delete the information for legal or regulatory compliance reasons. If that happens, we will give you written reasons for refusal (if permitted by law to do so).

In the case of requesting access to CCTV footage, we have a corporate procedure, developed to conform with the Privacy Act that governs our use and release of CCTV footage. It may also be the case that we are unable to release CCTV footage if there is an investigation or legal action pending.

If you wish to update or delete the personal information that we may hold, please contact our Privacy Officer at privacy@levande.com.au. If we disagree that there are grounds for amending your personal information, we will inform you of the reasons and add a note to the personal information stating that you disagree with it.

We will not charge you for requesting access to, corrections or deletion of your personal information, however we may recover reasonable expenses associated with providing you with access to your personal information.

Complaints and concerns about your privacy

If you have any questions about how we handle your personal information, or if you wish to make a complaint about our information handling practices, please contact our Privacy Officer:

Email: privacy@levande.com.au

Post: Privacy Officer, Levande Level 18, 9 Castlereagh Street, Sydney NSW 2000

Our Privacy Officer will acknowledge receipt of your complaint and after we have completed our investigation, contact you (usually in writing) to advise the outcome, usually within 30 days, and invite a response to our findings.

If you consider that we have been unable to satisfactorily resolve your concerns about our handling of your personal information, you can contact the Office of the Australian Information Commissioner:

Email: enquiries@oaic.gov.au

Phone: 1300 363 992

Post: Office of the Australian Information Commissioner GPO Box 5218 Sydney NSW 2000

Please visit the OAIC website at www.oaic.gov.au for further information.

Changes to Levande’s Privacy Policy

We may update our Policy from time to time to take into account new laws and technology, changes to our operations and business practices.

Effective: 1 August, 2022