PRIVACY POLICY

Published at https://rialto.com.au/rialto-key/privacy-policy

This Privacy Policy explains how we handle personal information collected through the Rialto Key mobile application (App).

It applies to the App only. It does not apply to the rialto.com.au website, to any tenant’s own systems, or to any other service at the Premises.

Who we are. The App is provided by the owners of the land and building located at Rialto, 525 Collins Street, Melbourne, Victoria 3000 (the Premises), being Grollo Australia Pty Ltd AFT Rialto Unit Trust ABN 73166404819 and Dexus Wholesale Management Limited AFT Dexus Australian Commercial Trust ACN 159301907, which own the Premises as tenants in common in equal shares (together Rialto, we, us and our). The Premises, and the App on our behalf, are managed by Knight Frank Australia Pty Ltd ABN 17 004 973 684 of Level 29, 120 Collins Street, Melbourne, Victoria 3000 (Building Manager).

We are bound by the Australian Privacy Principles (APPs) in the Privacy Act 1988 (Cth). This Policy should be read together with the App’s Terms of Use, available at https://rialto.com.au/rialto-key/terms-of-service.

1. The short version
The Rialto Key App does one thing: it puts your building access card in Apple Wallet or Google Wallet, and lets you call a lift from your phone.

• It does not change what information the building holds about you. Your cardholder record already exists in Rialto’s access control system for your physical access card. The App does not create a new record or collect new categories of information about you.

• We use Bluetooth and location for security, not tracking. They confirm you are standing at the lift lobby you are calling from. We do not use them to follow your movements or to build a profile of you.

• There is no advertising, analytics or tracking in the App. No advertising identifiers, no analytics SDKs, no crash-reporting SDKs, no third-party trackers.

• We do not sell your personal information, and we never will.

The rest of this Policy sets this out in full.

2. What personal information we collect
2.1 Information about you as a cardholder
• Your name

• Your email address and/or mobile number

• The tenancy you are employed by or contracted to

• Your access permissions — which doors, lifts, floors and areas you are entitled to use, and at what times

• The status of your credential (active, suspended, revoked) and its issue and expiry dates

This information already exists in Rialto’s access control system in respect of your physical access card. It is provided to us by your employer or engaging tenant, or by Rialto building management, as part of your being issued access to the Premises.

2.2 Information about your Digital Access Card and Device
• An identifier for the credential issued to you

• The type of Device the credential is provisioned to (for example, iPhone or Android phone) and the wallet it is held in

• The operating system version and App version on your Device, where needed to diagnose a fault

2.3 Access and lift-call events
• Doors and readers at which your credential is presented, and whether access was granted or denied

• Lift calls you make through the App, including the time, the floor you called from, and the lift zone or rise concerned

These events are recorded in the same way, and for the same reasons, as events generated by a physical access card.

2.4 Location and proximity data
• Your Device’s approximate location while the App is open and in use, used to confirm you are inside a permitted lift zone

• The identifiers of Bluetooth beacons your Device is near within the Premises, used to confirm which lift lobby and floor you are at

This is explained further in section 4.

2.5 Support enquiries
If you contact us about the App, we collect the information you give us in that enquiry, including your contact details and a description of the issue.

3. What we do not collect
To be explicit, the App does not:

• collect or use any advertising identifier (IDFA, GAID), and contains no advertising

• contain any analytics, crash-reporting or usage-tracking SDK

• track your location in the background, or when the App is closed. Location is used only while you are using the App

• track your location outside the Premises

• access your contacts, photos, camera, microphone, calendar, health data, files or browsing history

• collect payment or financial information

• collect sensitive information as defined in the Privacy Act 1988 (Cth), such as health, racial or ethnic origin, religious beliefs, or union membership

• read or have access to anything else held in your Apple Wallet or Google Wallet

We also do not sell, rent or trade your personal information, and we do not disclose it to anyone for their own marketing purposes.

4. Bluetooth, location and network permissions
The App asks for three permissions. Each is required for a specific security reason, and the App will not work without them.

4.1 Bluetooth
The App uses Bluetooth Low Energy to detect beacons installed throughout the Premises. This confirms that the Device calling a lift is physically present at the lift lobby the call is being made from, and identifies the correct floor and lift rise.

This is a security control. It prevents a lift being called remotely from elsewhere in the building, or from outside it. Beacon detections are used to validate the lift call and are recorded as part of the lift-call event described in section 2.3.

4.2 Location services
The App requests location access while you are using the App only. It does not request or use background or “always” location access, and it does not collect your location when the App is closed.

Location is used to confirm your Device is within a permitted lift zone within the Premises before a lift call is allowed. This is a security control that prevents lift access being obtained from outside the designated lift zones. Location data is not used for marketing, profiling, or any purpose unrelated to access control and lift calls.

4.3 The Rialto lift network
Parts of the Premises, in particular the basement and carpark levels, have limited or no mobile network coverage. Rialto operates a dedicated hidden wireless network within the Premises so that lift calls can still be made from these areas.

When the App detects this network, your Device may automatically join it. This network carries traffic to the in-building lift call servers only. It does not provide general internet access, it cannot be used to browse the internet or reach any other service, and your Device is automatically released from it approximately 60 seconds after connecting. We do not inspect, log or retain the content of your Device’s other network activity.

5. Why we collect and use your personal information
We collect and use your personal information to:

(a) verify your identity and confirm you are entitled to access the Premises;

(b) issue, provision, manage, suspend and revoke your Digital Access Card;

(d) confirm, at the moment you call a lift, that you are physically present in a permitted lift zone;

(e) maintain the security and safety of the Premises, including investigating security incidents, misuse of access credentials, and emergency or evacuation events;

(f) account for who is in the building in an emergency or evacuation;

(g) diagnose and resolve faults with the App, the access control system or the lift system;

(h) respond to your enquiries and support requests; and

(i) send you the communications described in section 8.

We collect this information because we cannot provide building access, or operate the App, without it. If you do not provide it, or do not grant the permissions described in section 4, we will not be able to issue you a Digital Access Card or provide the lift-call function. You can continue to use a physical access card and the physical lift call buttons and destination terminals.

6. Who we disclose your personal information to
We may disclose your personal information to:

(a) The Building Manager and Rialto building management personnel — who administer the access control system and building security on our behalf;

(b) Your employer or engaging tenant — where reasonably necessary in connection with your access rights, your onboarding or offboarding, or the investigation of a security or safety incident;

(i) HID Global, which operates the credential management platform (HID Origo) used to issue and manage your Digital Access Card;

(ii) Gallagher, the supplier of the access control system (Command Centre) in which your cardholder record is held;

(iii) OTIS, which operates the eCall lift service and the in-building lift call servers;

(iv) Apple and Google, which operate Apple Wallet and Google Wallet and the platforms the App is distributed through; and

(v) Random Solutions Pty Ltd, which develops, publishes and supports the App;

(d) Emergency services and building wardens — in an emergency, or where necessary to prevent or lessen a serious threat to the life, health or safety of any person; and

(e) Others as required or permitted by law — including in response to a court order, subpoena, warrant, or a lawful request from a regulator or law enforcement agency.

We require our service providers to handle personal information consistently with this Policy and their obligations under the Privacy Act 1988 (Cth), and to use it only for the purpose of providing their services to us.

Apple Wallet and Google Wallet
Your Digital Access Card is held in Apple Wallet or Google Wallet. Apple and Google handle information about your Device and your wallet under their own privacy policies, not this one. We do not control that handling, and their policies prevail in respect of your relationship with them.

(a) Apple. Apple’s handling of personal information is set out in the Apple Privacy Policy at https://www.apple.com/legal/privacy/. Apple also publishes a specific Wallet & Privacy disclosure, explaining what it does with data when a pass or key is added to Apple Wallet, at https://www.apple.com/legal/privacy/data/en/wallet/. Your use of Apple Wallet and the App Store is governed by the Apple Media Services Terms and Conditions (Australia) at https://www.apple.com/legal/internet-services/itunes/au/terms.html.

(b) Google. Google’s handling of personal information is set out in the Google Privacy Policy at https://policies.google.com/privacy. Your use of Google Wallet and Google Play is governed by the Google Terms of Service at https://policies.google.com/terms and the Google Wallet User Policy at https://wallet.google/policy/.

(c) These links are current as at the date of this Policy. Apple and Google may amend or relocate these documents without notice to us.

7. Overseas disclosure
Some of our service providers are located, or store data, outside Australia:

• HID Global operates the HID Origo credential management platform as a cloud service. Credential data may be stored or processed in [HID ORIGO HOSTING REGION — confirm with HID: e.g. Australia, the United States and/or the European Union].

• Apple Inc. (United States) and Google LLC (United States) operate the wallet platforms your Digital Access Card is provisioned to, the app stores the App is distributed through, and the push notification services used to send you App notifications.

Your cardholder record and access event history are held in Rialto’s Gallagher Command Centre system and the in-building lift call servers, both located at the Premises in Australia.

Before disclosing personal information overseas, we take steps that are reasonable in the circumstances to ensure the overseas recipient handles it in a manner consistent with the APPs. By using the App, you acknowledge that where personal information is disclosed to an overseas recipient, we may not be able to ensure that recipient complies with the APPs, and that the recipient may not be subject to the Privacy Act 1988 (Cth) or to Australian privacy laws.

8. Notifications and communications
We may send you in-app messages, push notifications, text messages and emails about the App, your Digital Access Card, and matters affecting access to or safety within the Premises, including emergency and fire drill notifications, security or access issues, and lift or system outages.

You can turn off non-essential push notifications in your Device settings. Turning them off does not stop essential service messages such as security alerts or notices that your credential has changed.

We do not use your information for marketing, and the App does not send marketing communications.

9. How we hold and protect your information
Your cardholder data and access permissions are held within Rialto’s physical access control system, Gallagher Command Centre, operated by or on behalf of Rialto building management. This is the same system that already holds your information for your physical access card.

Your Digital Access Card credential itself is issued through the HID Origo platform and is provisioned into the secure element of Apple Wallet or Google Wallet on your Device, where it is protected by your Device’s passcode, Face ID, Touch ID or equivalent. The App does not store your credential, and neither we nor the App can read the credential once it is in your wallet.

We take reasonable steps to protect personal information from misuse, interference and loss, and from unauthorised access, modification or disclosure. These include access controls limiting who can view cardholder records, encryption of data in transit, and the physical and system security measures applying to the Premises’ access control infrastructure.

No system can be guaranteed completely secure. If a data breach occurs that is likely to result in serious harm, we will notify affected individuals and the Office of the Australian Information Commissioner in accordance with the Notifiable Data Breaches scheme.

10. How long we keep your information
We keep your cardholder record for as long as you hold access to the Premises. When your access ends, your credential is revoked and your record is deactivated.

Access and lift-call event logs are retained in accordance with Rialto’s security and records retention practices, and for as long as reasonably necessary for building security, incident investigation, and to meet our legal obligations. We then destroy or de-identify the information, unless we are required by law to retain it.

11. Deleting the App and ending your access
You can remove the App from your Device at any time, and you can remove your Digital Access Card from Apple Wallet or Google Wallet at any time. Doing so stops the App collecting location or Bluetooth data on your Device.

Removing the App does not by itself cancel your building access or delete your cardholder record, because that record is held in the building’s access control system, not in the App. To have your access revoked, contact your employer or Rialto building management. If your Device is lost or stolen, you must tell them immediately so your credential can be suspended.

12. Accessing and correcting your information
You can ask us for access to the personal information we hold about you, and ask us to correct it if it is inaccurate, out of date, incomplete, irrelevant or misleading. Contact us using the details in section 15.

We will respond within a reasonable period, usually within 30 days. There is no charge for making a request, though we may charge a reasonable fee for the cost of providing access in some circumstances. If we refuse a request, we will tell you why in writing and how you can complain about that decision.

Some information we hold about you originates from your employer or engaging tenant. Where a correction relates to that information, we may need to refer you to them.

13. Complaints
If you think we have breached the APPs or mishandled your personal information, please contact us using the details in section 15. Tell us what happened and how you would like it resolved. We will acknowledge your complaint promptly and aim to respond within 30 days.

If you are not satisfied with our response, you can complain to the Office of the Australian Information Commissioner:

• Website: www.oaic.gov.au

• Phone: 1300 363 992

• Post: GPO Box 5218, Sydney NSW 2001

14. Changes to this Policy
We may update this Policy from time to time. The current version is always published at https://rialto.com.au/rialto-key/privacy-policy, and the date at the top shows when it was last changed. If we make a change that materially affects how we handle your personal information, we will let you know through the App or by email before it takes effect.

15. Contact us
For any question, request or complaint about this Policy or about how we handle your personal information:

Email: rialtokey@rialto.com.au

Post: The Privacy Officer, Rialto Key, c/- Knight Frank Australia Pty Ltd, Level 1, 525 Collins Street, Melbourne, Victoria 3000

Published at https://rialto.com.au/rialto-key/privacy-policy

This Privacy Policy explains how we handle personal information collected through the Rialto Key mobile application (App).

It applies to the App only. It does not apply to the rialto.com.au website, to any tenant’s own systems, or to any other service at the Premises.

Who we are. The App is provided by the owners of the land and building located at Rialto, 525 Collins Street, Melbourne, Victoria 3000 (the Premises), being [GROLLO OWNING ENTITY — insert registered name and ABN] and [DEXUS / GIC JOINT VENTURE OWNING ENTITY — insert registered name and ABN], which own the Premises as tenants in common in equal shares (together Rialto, we, us and our). The Premises, and the App on our behalf, are managed by Knight Frank Australia Pty Ltd [ABN — to be confirmed] of Level 29, 120 Collins Street, Melbourne, Victoria 3000 (Building Manager).