Privacy

1. General conditions of access and use

The Privacy Act 1988 (Cth) defines “personal information” to mean information or an opinion, whether true or not, and whether recorded in a material form or not, about an individual whose identity is reasonably identifiable, from the information or opinion.

3. What is sensitive information?

Sensitive information is a subset of personal information. It means information or opinion about an individual’s racial or ethnic origin, political opinions, membership of a political organisation, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual orientation or practices, criminal record, health information about an individual, genetic information, biometric information that is to be used for the purpose of automated biometric verification or biometric identification or biometric templates.

In general, we attempt to limit the collection of sensitive information we may collect from you, but depending on the uses we may collect sensitive information from you in order to carry out the services provided to you.

However, we do not collect sensitive information from you without your consent.

The type of sensitive information we may collect from you or record about you is dependent on the services we provide to you and will be limited to the purpose(s) for which it is collected. We do not use sensitive information to send you Direct Marketing Communications (as defined in section 8 below) without your express consent.

Consent to collection of certain types of sensitive information

• We may collect certain types of sensitive information where you have consented and agree to the collection of such information.
• Generally speaking, we will obtain this type of consent from you at (or around) the point in time in which we collect the information, but the main type of sensitive information that we may collect (if any) will usually relate to:
• the past employment history of an individual
• criminal record of an individual
• the health or medical information about an individual

but only to the extent that where you volunteer such information or if it is necessary for, or incidental to, the purposes of collection set out in section 6.

4. Collection of your personal information

We only collect personal information that is necessary for what we do and we hold the personal information we collect within our own data storage devices or with a third party provider of data storage. The type of information we may collect from you includes depends ultimately upon the purpose of collection and we set out the general purposes of collection at the following paragraph below.

The type of information we may collect from you includes (but is not limited to) the following:

• your contact information such as full name (first and last), e-mail address, current postal address, delivery address (if different to postal address) and phone numbers, including but not limited to any additional personal information you may provide us through the use of any “Contact Us” enquiry through our website
• if applicable, details relating to your employment, potential employment or previous employment, which shall include, but is not limited to, obtaining your tax file number, superannuation details, results of any skills or behavioural testing, qualifications, references, proof of your ability to work in Australia
• your date of birth
• any sensitive personal information listed in section 3
• proof of your date of birth (including, but not limited to, driver’s licence, passport, birth certificate)
• your opinions, statements and endorsements collected personally or via surveys and questionnaires, including but not limited to your views on the products and services offered by us. Unless you advise us otherwise, you expressly agree and consent to the use of any opinion, statement or endorsement which you provide us being used for marketing and advertising purposes, without compensation
• if you are requesting products or services from us or we are purchasing goods or services from you, then any relevant payment or billing information (including but not limited to bank account details, direct debit, credit card details, billing address, repayment information and invoice details)
• details relating to the shareholding and transfer(s) of shareholding, including but not limited to share certificate numbers, shareholder names and contact information, that are necessary for the efficient trading, management and administration of Rob Carr Pty Ltd shareholdings.

As much as possible or unless provided otherwise under this privacy policy, we will collect your information directly from you. If we collect details about you from someone else, we will, whenever reasonably possible, make you aware that we have done this and why.

When you engage in certain activities, such as entering a contest or promotion, filling out a survey or sending us feedback, we may ask you to provide certain information. It is completely optional for you to engage in these activities.

Depending upon the reason for requiring the information, some of the information we ask you to provide may be identified as mandatory or voluntary. If you do not provide the mandatory data or any other information we require in order for us to provide our services to you, we may be unable to effectively provide our services to you.

5. Using our website

If you use our website, we may utilise “cookies” which enable us to monitor traffic patterns and to serve you more efficiently if you revisit our website. In most cases, a cookie does not identify you personally but may identify your internet service provider, computer, your server address, top level domain name, the time and date of your visit, the pages and documents you have accessed or viewed and the type of browser you are using.

However, in some cases, cookies may collect and store personal information about you. We extend the same privacy protection to your personal information collected in this manner, whether gathered via cookies or from other sources, as detailed in this Privacy Policy. You can set your browser to notify you when you receive a cookie and this will provide you with an opportunity to either accept or reject it in each instance. However, if you disable cookies, you may not be able to access certain areas of our web sites or take advantage of the improved web site experience that cookies offer.

We will also collect your personal information when you contact us via any enquiry form on our website. The extent of the personal information collected in this manner is dependent on the personal information you provide us.

We may gather your IP address as part of our business activities and to assist with any operational difficulties or support issues with our services. This information does not identify you personally.

6. How we may use and disclose your personal information

We will only use or disclose your personal information for the primary purposes for which it was collected or as consented to and/or as set out below.

You consent to us using and disclosing your personal information to facilitate a purpose in connection with:

• if required, the verification of your identity
• the verification of your date of birth, if applicable
• the provision of our products and services to you, which shall include but is not limited to:
  • the administration and management of our products and services, including charging, billing, credit card authorisation and verification, checks for financial standing, credit-worthiness (including but not limited to undertaking an assessment for credit loss and obtaining credit references, if applicable), fraud and collecting debts
  • to offer you updates, or other content or products and services that may be of interest to you
  • the trading, management and administration of shareholdings held by our shareholders in Rob Carr Pty Ltd
  • the processing of any enquiry you submit to us through our website
• to facilitate the administration and management of Rob Carr Pty Ltd, including but not limited to:
  • your employment or potential employment with us.
• the improvement of our services (including to contact you about those improvements and asking you to participate in surveys about our products and services)
• the maintenance and development of our products and services, business systems, website and infrastructure
• business updates by us and our related bodies (including by direct mail and email)
• to provide customer service type functions, including handling customer enquiries and complaints
• our compliance with applicable laws
• the sale, and matters in connection with a potential sale, of our business or company to a third party
• any other matters reasonably necessary to continue to provide our products and services to you.

We may also use or disclose your personal information and in doing so we are not required to seek your additional consent:

• when it is disclosed or used for a purpose related to the primary purposes of collection detailed above and you would reasonably expect your personal information to be used or disclosed for such a purpose
• if we reasonably believe that the use or disclosure is necessary to lessen or prevent a serious or imminent threat to an individual’s life, health or safety or to lessen or prevent a threat to public health or safety
• if we have reason to suspect that unlawful activity has been, or is being, engaged in or if it is required or authorised by law.

In the event we propose to use or disclose such personal information other than for reasons above, we will first seek your consent prior to such disclosure or use.

If you have received communications from us and you no longer wish to receive those sorts of communications, you should contact via the details set out at the top of this document and we will ensure the relevant communication ceases. Any other use or disclosure we make of your personal information will only be as required by law or as permitted by the Privacy Act 1988 or by this Privacy Policy or otherwise with your consent.

7. The types of organisations to which we may disclose your personal information

We may disclose your personal information to organisations outside of Rob Carr Pty Ltd. Examples of organisations and/or parties that your personal information may be provided to include:

• offshore service providers, including the host of this website
• third party service providers providing share registry functions
• investors and potential investors
• our related entities and subsidiaries
• third parties, such as recruitment agencies, data hosting service provider
• our contractors and agents, including but not limited to our suppliers or other companies who assist us in providing our products and services to you.

Your personal information is disclosed to these organisations and/or parties only in relation to the goods or services we provide to you or for a purpose permitted by this Privacy Policy.

We take such steps as are reasonable to ensure that these organisations and/or parties are aware of the provisions of this privacy policy in relation to your personal information.

8. Direct marketing

You expressly consent to us using your personal information, including any email address you give to us, to provide you with information and to tell you about our business, products, services or events or any other direct marketing activity (including third party products, services, and events) (Direct Marketing Communications) which we consider may be of interest to you.

Without limitation to the clause above, if it is within your reasonable expectations that we send you Direct Marketing Communications given the transaction or communication you have had with us, then we may also use your personal information for the purpose of sending you Direct Marketing Communications which we consider may be of interest to you.

If at any time you do not wish to receive any further Direct Marketing Communications from us, you may ask us not to send you any further information about products and services and not to disclose your information to other organisations for that purpose. You may do this at any time by using the “unsubscribe” facility included in the email or by contacting us via the details set out at the top of this document.

9. Cross border disclosure

Any personal information provided to us may be transferred to, and stored at, a destination outside Australia, where we may have entered into contractual arrangements with third party service providers to assist us with providing our goods and services to you. Further, if you are an officer or employee of Rob Carr Pty Ltd, your personal information may be disclosed outside Australia to our investors or potential investors. Personal information may also be processed by staff or by other third parties operating outside Australia who work for us or for one of our suppliers, agents, partners or related companies.

By submitting your personal information to us, you expressly agree and consent to the disclosure, transfer, storing or processing of your personal information outside of Australia. In providing this consent, you understand and acknowledge that countries outside Australia do not always have the same privacy protection obligations as Australia in relation to personal information. However, we will take steps to ensure that your information is used by third parties securely and in accordance with the terms of this privacy policy.

The Privacy Act 1988 requires us to take such steps as are reasonable in the circumstances to ensure that any recipients of your personal information outside of Australia do not breach the privacy principles contained within the Privacy Act 1988.

By providing your consent, under the Privacy Act 1988, we are not required to take such steps as may be reasonable in the circumstances. However, despite this, we acknowledge the importance of protecting personal information and have taken reasonable steps to ensure that your information is used by third parties securely and in accordance with the terms of this privacy policy.

If you do not agree to the transfer of your personal information outside Australia, please contact us by via the details set out at the top of this document.

10. Data quality and security

We have taken steps to help ensure your personal information is safe. You will appreciate, however, that we cannot guarantee the security of all transmissions or personal information, especially where the Internet is involved.

Notwithstanding the above, we will take reasonable steps to:

• make sure that the personal information we collect, use or disclose is accurate, complete and up to date;
• protect your personal information from misuse, loss, unauthorised access, modification or disclosure both physically and through computer security methods
• destroy or permanently de-identify personal information if it is no longer needed for its purpose of collection.

However, the accuracy of personal information depends largely on the information you provide to us, so we recommend that you:

• let us know if there are any errors in your personal information
• keep us up-to-date with changes to your personal information (such as your name or address).

11. Access to and correction of your personal information

You are entitled to have access to any personal information relating to you which we possess, except in some exceptional circumstances provided by law. You are also entitled to edit and correct such information if the information is inaccurate, out of date, incomplete, irrelevant or misleading.

If you would like access to or correct any records of personal information we have about you, you are able to access and update that information (subject to the above) by contacting us via the details set out at the top of this document.

12. Resolving privacy complaints

We have put in place an effective mechanism and procedure to resolve privacy complaints. We will ensure that all complaints are dealt with in a reasonably appropriate timeframe so that any decision (if any decision is required to be made) is made expeditiously and in a manner that does not compromise the integrity or quality of any such decision.

If you have any concerns or complaints about the manner in which we have collected, used or disclosed and stored your personal information, please contact us by:

• telephone: 1300 883 602
• email: reception@robcarr.com.au
• post: 74-76 Union Circuit, PO Box 6103, Yatala, QLD 4207 Australia Please mark your correspondence to the attention of the Company Secretary.

In order to resolve a complaint, we:

• will liaise with you to identify and define the nature and cause of the complaint
• may request that you provide the details of the complaint in writing
• will keep you informed of the likely time within which we will respond to your complaint
• will inform you of the legislative basis (if any) of our decision in resolving such complaint.

We will keep a record of the complaint and any action taken in a Register of Complaints.

13. Consent

By using our website or by accepting the terms of one of our terms and conditions which refer to this privacy policy, you are agreeing to the terms of this Privacy Policy.

We reserve the right to modify our privacy policy as our business needs require. We will notify you of such changes (whether by direct communication or by posting a notice on our website), after which, your continued use of our products, services or website or your continued dealings with us shall be deemed to be your agreement to the modified terms. If you do not agree to our continued use of your personal information due to the changes in our privacy policy, please contact us via the details set out at the top of this document.