PRIVACY POLICY

Some of the personal information you provide us as part of your dealings with us is required information under the Owners Corporation Act of 2006 and may not be protected under the Privacy Act 1998.

This Privacy Policy sets out how we collect, handle, use, transmit and disclose your personal information and applies to you unless you give us explicit consent to act otherwise. If you would like to know more about data protection generally, there is information available from the Australian Information Commissioner at the following website – www.oaic.gov.au;

We generally collect personal information at our corporate premises and online, both electronically and in hard copy.

We use your personal information primarily for the purposes of communicating with you to fulfill our obligations under our delegated authority to manage your assets and to provide you marketing and promotional material about our products and services (by email, text messaging, social networking, conventional post and other means).

We also use your personal information for the purposes of internal and external accounting and auditing, recording proof of residence and purchase or payment, validating cheque transactions, receiving, processing and delivering product or service  orders, processing payments, managing our websites (which may include registering you to use our websites), regulatory reporting and compliance, recruitment, servicing our relationship with you and provide you with information, products and services you may request from time to time. We may communicate additional purposes for use and disclosure of personal information at the point of collection.

We may engage or deal with other persons or organisations (for example, loyalty program administrators and partners, data analysis specialists, statement producers, data mail houses, data processing organisations, marketing researchers, specialist call centers and service providers, promotional services providers, data hosting service providers, agents, contractors, suppliers, joint venture partners, subsidiaries and other third Party Providers to assist us in carrying out the above purposes.

Your personal information may be disclosed to such persons or organisations for these purposes and, in providing a service, they may contact you directly. In some circumstances, they may disclose personal information they collected from you to for one or more of the purposes already mentioned.

The nature of the information collected will vary depending on the purpose for which the information was collected. However, the information we usually collect includes name, address, credit and debit card details, phone number, email address, work history, our website passwords and usernames, etc. This information allows us to effectively provide products and services to you or otherwise interact with you.

If you provide your email address or mobile telephone number to us, you consent to us using your email address to email you and/or your mobile telephone number to SMS you for any of the purposes listed above.

SOCIAL MEDIA

We may also collect personal information when you submit content on our social media pages. By submitting content, you agree we may use this content including your name and any other personal information submitted by you, either temporarily or permanently, for testimonial, marketing or other purposes in any media without any compensation to you.

COOKIES

Cookies are small files that a website or its service provider transfers to your computer hard drive through your Web browser (if you allow) that enables the sites or service providers systems to recognise your browser and capture and remember certain information. To enhance your experience when using our websites, we use cookies which may automatically collect information from you such as your email address, region and sign in username. Cookies allow us to remember the goods that you have placed in your online shopping bag and save you having to re-enter basic contact information that you provided when registering for an online account with us. We also use cookies for tracking the statistics of our websites. This allows us to better understand our users and improve the layout and functionality of our website. This tracking is conducted in such a way to ensure the anonymity of visitors. Most web browsers are set by default to accept cookies. However, if you do not wish to receive any cookies you may set your browser to either prompt or refuse cookies. Note that rejecting cookies will disable your browser from purchasing and may impair the functionality of our websites.

USE AND DISCLOSURE

If we feel the need to use or disclose your personal information for any purpose other than the primary purposes described above, we will obtain your consent unless the use or disclosure is otherwise permitted under the Act. We will never sell personal information to direct marketing organisations.

If you feel that we are or have in the past used your personal information in error or for any purpose other than the purposed described above, simply write, email or call us using the contact information provided below and we will review and rectify the error or address your concerns immediately or otherwise advise you of the outcome of our review.

Please be sure to include your name and other relevant details.

The Privacy Officer, Stratagised Concepts Group, level 35, 35 Collin Street Melbourne VIC 3000

Email: [email protected]

Phone: 1300 200 100

From time to time we may sell or disclose information you provide us that is not personal information or does not disclose your identity to any person for any purpose at our sole discretion, including to people or companies located outside of Australia. We may also modify your personal information (through encryption or other de-identifying techniques) so that it is in a format from which you cannot be identified and sell or disclose such modified information to any person for any purpose, including to people or companies located outside of Australia.

ACCURACY OF AND ACCESS TO PERSONAL INFORMATION

We endeavor to take all reasonable steps to ensure the personal information we hold is up-to-date, complete and accurate.

At any time, you may request a copy of your personal information held by us by contacting us using the contact information provided above. If you believe any of your personal information held by us is incomplete or inaccurate, please notify us in writing so that we may update that information. Every reasonable effort will be made to provide or update personal information on request, unless an exemption under the Act applies. In these circumstances we will provide written notification as to why your request has been refused.

We may withhold or refuse you access to your personal information if we are legally authorised to do so or where its disclosure to you is restricted by law, is the subject of legal action, or may compromise the privacy of another person.

DATA SECURITY

We will endeavor to take reasonable steps to protect the personal information we hold from misuse, loss and unauthorised access, modification, destruction or disclosure. We adopt practices to prevent unauthorised access to our premises, systems or physical storage locations. Personal information that is no longer required will be destroyed as appropriate.

ONLINE TRANSACTION SECURITY

We take online transaction security seriously. We process online transactions using at least a 128 bit SSL encryption to a secure credit card payment gateway system.

We may collect but will not store your credit card details on our databases or servers. You will need to enter those details each time you make a purchase on our websites. However, we do maintain records of your transaction history. As mentioned above, we adopt practices which seek to prevent unauthorised access to such records.

The Internet is not a secure method of transmitting information. Accordingly, we cannot accept responsibility for the security of information you send to or receive from us over the Internet or for any unauthorised access, use or modification of that information.

Our websites may provide links or references to other 3rd party websites and resources. These websites and resources are not subject to this Privacy Policy. You should review the privacy policy of each 3rd party website and resource accessed via links from our websites, and assess whether the policy of each website and resource is satisfactory to you before you use the website or resource. You acknowledge and agree that we are not responsible for any personal information you choose to disclose to a 3rd party through a 3rd party website referred to by or linked to any of our websites and that such 3rd parties may store your personal information in any location in accordance with their own security standards.

EMAIL

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IDENTIFIERS AND ANONYMITY

Where personal information is collected, it will usually be identified by a common identifier such as the name of the individual, address or transaction details. We will not use identifiers assigned by a government agency, such as tax file numbers, to identify your personal information.

Wherever it is lawful and practical, we will give you the option of not identifying yourself when interacting with us.

WHERE INFORMATION IS STORED

Subject to the below, personal information we collect from you is stored securely at our offices and on data servers located in Australia, New Zealand, the UK or the USA. We may also engage or deal with Third Party Providers to assist with carrying out the purposes discussed in this Privacy Policy, which may include the provision of data storage and hosting services in relation to your information. We will disclose your personal information to our Third Party Providers to the extent necessary for them to provide such assistance (including storage and data hosting services) and as otherwise required for you to use our websites and to obtain products or services we offer from time to time.

In addition to Australia, our Third Party Providers may also store your personal information in New Zealand, South Africa, the United Kingdom and the USA. If our Third Party Providers store your personal information outside Australia, the Act requires us to ensure that they comply with applicable Australian privacy laws unless you agree otherwise.

By providing us with information (including personal information), using our websites or obtaining any products or services provided by us from time to time, you: (i) consent to us disclosing and transferring your information (including personal information) to our Third Party Providers located outside of Australia, particularly in New Zealand, South Africa, the United Kingdom and the USA; (ii) consent to us and our Third Party Providers storing your information (including personal information) in locations and on servers located outside of Australia, particularly in New Zealand, South Africa, the United Kingdom and the USA; and (iii) agree that the requirement under the Act for us to ensure that our Third Party Providers comply with applicable Australian privacy laws in respect of your information (including personal information) does not apply if our Third Party Providers store personal information outside of Australia, including in New Zealand, South Africa, the United Kingdom and the USA (as applicable). We may in the future store your personal information in other locations outside of Australia or engage other providers that may store your personal information in or outside of Australia and will update this Privacy Policy if either is the case. We recommend that you visit our website regularly to keep up to date with any changes.

SENSITIVE INFORMATION

Where we collect personal information that is also sensitive information, such as health details, we will only do so if the individual has consented or the collection is required or permitted by law, including where necessary for the establishment, exercise or defense of a legal or equitable claim.

FEEDBACK

If at any time you believe we have not followed our privacy policy, or if you have some query or comment about our privacy policy, please contact our privacy officer, at the address set out above. We will make every reasonable effort to resolve the problem to the satisfaction of all parties and/or provide you with a response to your query or comment. If you are not satisfied with our response, you can lodge a complaint with the Australian Information Commissioner through its website located at www.oaic.gov.au/privacy/privacy-complaints.

UPDATING THIS PRIVACY POLICY

We may update this privacy policy from time to time by posting a revised version on our website.