Legal

1.

INTRODUCTION

1.1

Overview:  This Privacy Policy explains how we may collect, hold, use and disclose information that identifies you (your personal information). If you would like to contact us in relation to this Privacy Policy or our use of your information, please email us at the details set out in the Contact us section below.

1.2

Application of this Privacy Policy:  Please read this Privacy Policy carefully.  It applies to any personal information that you provide to us or authorise us to collect.  By accessing our website at www.vitalhealthcareproperty.co.nz (our website) or otherwise providing us with personal information, you authorise us to collect, use and disclose your personal information in accordance with this Privacy Policy.  

1.3.

Updates to this Privacy Policy:  We may update this Privacy Policy at any time by posting an updated version of this Privacy Policy on our website.  The updated version of this Privacy Policy will take effect immediately upon such notice (or, if applicable, on the date specified in the updated Privacy Policy) and will apply to all personal information that we hold about you. We may also take additional steps to bring the changes to your attention, including by notifying you directly.  We will update you of any material changes as required by law.

1.4

Additional rights and obligations:  This Privacy Policy applies in addition to, and does not limit, our rights and obligations under the Privacy Act 2020 (as amended or replaced from time to time) (Privacy Act) or any specific authorisation that you provide to us when you interact with us.

2.

WHO WE ARE

2.1

Your personal information will be held by NorthWest Healthcare Properties Management Limited at Level 16, AIG Building, 41 Shortland Street, Auckland, New Zealand (the Manager) as manager of the Vital Healthcare Property Trust (Vital). References to Vital or we, us or our in this Privacy Policy include the Manager.

3.

COLLECTION OF PERSONAL INFORMATION

3.1

Types of personal information we collect:  The personal information we collect will depend on your interaction with us.  The personal information we commonly collect includes:

a)   Contact details: such as name, title, address, telephone number, e-mail address
b)   Marketing: details of your marketing preferences 
c)   Enquiry details: details of enquiries you make (e.g. by completing a form on our website) and other communications you have with us
d)   Lease information: details of tenant or guarantor name, address and phone number
e)   Financial information: details of financial substance, including financial statements from prospective tenants or assignees 
f)   Credit information: including information about your default and repayment history
g)   Feedback: details of any feedback or comments that you provide on us or our website 
h)   Technical information: this includes information that we automatically collect when you access or use our website (e.g. IP address, browser type, cookie information).

You are not required to provide us with any personal information that we request.  However, if you do not do so, we may not be able to provide you with certain information that you have requested. We’ll let you know if this is the case.

3.2

How we collect personal information:  Generally, we collect personal information directly from you.  We may also collect your personal information from a third party if you have authorised them to provide, or authorised us to collect, that information. For example, we may collect information about unitholders from the Registrar, Computershare Investor Services Limited or if you are a tenant or guarantor, you may have authorised your accountant to share your financial statements with us. In addition, we may collect information about you and your use of our website through the use of automatic data collection tools. These tools collect certain standard information about your access and computer, such as your browser type, operating system and language, access times and your Internet Protocol (IP) address.

3.3

Cookies:  We may also collect information through cookies on our website. Cookies are small pieces of information that are stored on a user’s computer. We may use cookies to personalise your experience on the website, make it easier for you to navigate our website, and improve your experience by storing your search or login details (if any). Cookies can be disabled via your web browser; however doing so may limit your access to some of the website’s content and features. We may also use cookies to track non-personally identifiable information such as usage and volume statistics, for research purposes in order to further develop our website. 

3.4

Information about other people:  If you provide us with, or authorise us to collect, personal information about another person, you confirm that they have authorised you to provide us, or authorise us to collect, their personal information in accordance with this Privacy Policy and that you have informed them of their rights to access and request correction of their personal information, as set out below.

4.

USE OF PERSONAL INFORMATION

4.1

How we may use your information: We may use your personal information for the following purposes:

a)   for the general operation of Vital (including asset management) 
b)   to conduct credit checks (to assess the creditworthiness of a guarantor or tenant) 
c)   to manage our relationship with you (including to notify you of changes to our website, terms and conditions, and respond to queries or complaints)
d)   to provide you with marketing that you have requested or that we think you might be interested in (e.g. via newsletters or other marketing materials) unless you have opted-out of such marketing
e)   to comply with our legal obligations and policies
f)   to ensure the security of our networks and systems, protect against, identify and prevent fraud and other claims
g)   to analyse your use of our website, personalise and improve your experience on our website using cookies and similar technologies
h)   to facilitate our internal business operations (including for training, risk management and for developing, maintaining and testing our IT systems and infrastructure)
i)   for any other purpose authorised by you or permitted by law.

4.2

Additional information about credit information: We may use the services of credit reporting and debt collection agencies on an on-going basis, and may exchange information about you with those agencies (including information about your default and repayment history). Those agencies may retain that information and provide that information to other customers who use their services

4.3

Use of aggregated and anonymous information: We also use aggregated and anonymous information (where identifiable characteristics are removed, so that you will remain anonymous) for statistical and research purposes. 

4.4

How we may communicate with you: We may communicate with you by email and other electronic means.

5.

DISCLOSURE OF PERSONAL INFORMATION

5.1

How we may share your information: We may share your personal information for the purposes set out above with the following parties:

a) our related companies and organisations, partners, contractors and service providers (including IT services providers), to assist us with the operation of our business;
b) authorities, regulators and professional advisers (including lawyers, bankers, auditors and insurers); 
c) third parties to whom we may choose to sell, transfer or merge parts of our business or our assets; 
d) any other party authorised by you or to whom we are required or authorised to disclose personal information in accordance with applicable law.

5.2

Transfer of personal information overseas: Occasionally we may need to send your personal information outside New Zealand, including to service providers and our related companies that may be located overseas or have overseas operations.  In particular, we have operations in Australia and Canada. If we do send personal information overseas either directly or via a third party, it will only be for the purposes listed in this Privacy Policy. We will ensure that any such transfer of personal information will only be undertaken in compliance with the Privacy Act.

6.

SECURITY AND STORAGE

6.1

Security: We take reasonable technical and organisational security measures to prevent loss or unauthorised access, use, alteration or disclosure of personal information you provide to us or authorise us to collect. We also require any contractors or service providers who require access to your information required to implement reasonable technical and organisational security measures to protect your information.

6.2

Inherent risks: Unfortunately, the transmission of information via the Internet is not completely secure.  Although we will apply our normal procedures and comply with legal requirements to protect your information, we cannot guarantee the security of your information transmitted to or from the website and any transmission is at your own risk. 

6.3

Links to third party websites:  The website may from time to time contain links to and from other websites.  If you follow a link to any of those sites, please note that those sites ought to have their own privacy policies and that we do not accept any responsibility or liability for those sites or for their privacy policies.  Please check those privacy policies before you submit your information to those sites. 

6.4

Login details:  If, from time to time, you have a username, password or other login details which enable you to access certain parts of the website, you must not allow any other person to use them and must treat them as confidential.  If you believe or suspect that someone else knows your login details you must contact us using the email address set out under the Contact us heading below as soon as possible.

7.

ACCESS AND CORRECTION OF PERSONAL INFORMATION

7.1

Your rights: Under the Privacy Act, you have the right to access and request correction of any personal information that we hold about you.  Please refer to the Contact us section below.

8.

CONTACT US

8.1

How to contact us: If you have any questions or requests relating to this Privacy Policy or personal information that we may hold about you, please contact us please contact the Manager by emailing enquiry@vhpt.co.nz or calling 0800 225 264.