PRIVACY AND CREDIT REPORTING POLICY

Your privacy is important

This privacy and credit reporting policy outlines how Al.ive Body Pty Ltd (ACN 635 011 960) (“us”, “our” or “we”) collects, uses and discloses personal information as required by the Australian Privacy Principles (“APPs”) contained in, and for the purposes of Part IIIA of, the Privacy Act 1988 (Cth) (“Privacy Act”).

The kinds of personal information we collect and hold

We collect and hold personal information about customers, suppliers, job applicants, staff members, contractors, people who are interested in the goods and/or services that we offer or those entities associated with us offer and other people who come into contact with us (“you”).

Without limitation, the kinds of “personal information” we collect and hold may include your name, address and other contact details, which of our products and/or services you have purchased, credit and debit card details and information obtained when you use our website, including which of our pages you have accessed.

If we provide you (or an entity related to you) with credit, we may also collect and hold credit information and credit eligibility information about you. Without limitation, this may include credit reports, identification information, consumer credit liability information, details of amounts payable to us and the terms of the relevant credit, and information relating to payments made, default information and payment information.

If you are applying for a job with us, we may also collect personal information which may be considered sensitive information for the purposes of the Privacy Act.

Manner of collection and purpose of collection, holding and use of personal information

We will generally collect personal information (including the types of credit-related personal information referred to above) (personal information) about you directly by way of forms and other documents provided to us by you (including via the internet), correspondence you provide to us and discussions with you.

Occasionally, we may collect personal information about you from third parties such as credit providers and trade references. For example, we may collect personal information about you from entities associated with us or from an entity related to you such as your employer or credit eligibility information about you from credit reporting bodies (“CRBs”) if we provide you (or an entity related to you) with credit.

We will only collect, hold and use personal information (except sensitive information, see below) for the following purposes unless otherwise required or permitted by law or expressed approved by you:

• to enable us to conduct our business generally and to facilitate the supply of goods or services offered by us to you;
• to provide you with marketing materials in relation to offers, specials, products and services we have available from time to time via any medium including mail, telephone (including by SMS message) and email;
• to get a better understanding of you, your needs, your behaviours and how you interact with us in order to identify ways in which we can provide you with a better service, or enhance your experience of our website or other services;
• if you are a job-applicant or a potential contractor, to assess your suitability and (if successful) engage you and to assist with administering your employment or contract;
• if we are providing you (or an entity related to you) with credit, to assess your creditworthiness (or the creditworthiness of your related entity which is receiving the credit);
• for our internal management purposes, to manage our relationship with you (or any entity related to you) and to manage the payment and recovery of amounts payable to us by you;
• to monitor and profile who is accessing and using our website; and
• for other purposes which are reasonably necessary in connection with our ordinary functions and activities.

We will only use sensitive information for the purposes for which it was provided or for a purpose directly related to such purpose, unless you agree otherwise or the use of such sensitive information is required or authorised by law.

If we are unable to collect personal information relating to you, we may be unable to provide the credit, goods and/or services you require (or that an entity related to you requires) or continue our relationship with you (or any entity related to you) and you may be unable to access all or parts of our website.

Disclosure of your personal information

We may disclose personal information about you to the following types of entities if required in connection with the purposes listed above:
• our contractors, suppliers, consultants, advisers, associates and related entities;
• any industry body, tribunal, court or otherwise in connection with any complaint, inquiry or investigation made by you about us;
• if we are providing you (or an entity related to you) with credit, CRBs, trade insurers, insurance brokers and businesses assisting us with providing credit;
• any entity included in a transfer of all or part of our assets or businesses;
• any person who proposes to provide or has provided us with a guarantee to secure your obligations (or the obligations of an entity related to you) to us;
• if you have provided us with referees to assist with a credit application, a job application or the assessment of a potential contract between you and us, the referees you have provided;
• an organisation providing verification of your identity, including on-line verification of your identity; and
• other persons or entities with your consent or as permitted or required by law.

[We are unlikely to disclose your personal information to overseas recipients.] //OR// [We will not disclose your personal information (including your credit-related information) to any entities located overseas (unless you are not located in Australia, in which case we may disclose personal information to entities located in the country you are located in)].

If you fail to make a payment to us as and when due or commit a serious credit infringement we may disclose details of such events to CRBs. A CRB may use such information in reports given to other credit providers to help assess your creditworthiness. You have certain rights to request that CRBs do not use or disclose credit reporting information about you if you believe on reasonable grounds you have been or are likely to be a victim of fraud. You should contact each relevant CRB directly if you wish to request this.

The CRB we deal with is [insert]. Copies of [their] privacy polic[ies] dealing with how they manage credit-related personal information can be found on their website[s].

How we hold personal information

We hold personal information in paper form and electronic form. We have in place steps to protect the information we hold from misuse, interference and loss and from unauthorised access, modification or disclosure.

How to obtain access to your personal information

You may obtain access to personal information which we hold about you by contacting us using the contact details set out below. When you request copies of your personal information held by us we will endeavour to provide you with such personal information as soon as reasonably practicable.

If you request access to your personal information, we may require you to verify your identity and specify what information you require. We may charge you a fee for identifying and providing access to your personal information. There may be occasions when access to personal information we hold about you is denied. Such occasions would include where release of the information would have an unreasonable impact on the privacy of others.

Accuracy and completeness of personal information

While we will endeavour to ensure that the personal information collected from you is up to date, accurate and complete, we will assume that any personal information provided by you is free from errors and omissions. You may request that we update or vary personal information that we hold about you using the contact details set out below.
How to make a complaint about a breach of your privacy rights

If you are of the view we have breached the APPs, the Privacy Act, or any related privacy code in dealing with your personal information, you may make a complaint by writing to us using the contact details set out below and we will endeavour to provide you with confirmation as to how we propose to deal with the complaint as soon as reasonably practicable.
If you are not satisfied with our response to your complaint, you may make a complaint to the Office of the Australian Information Commissioner by visiting https://www.oaic.gov.au/privacy/privacy-complaints and following the relevant steps.

Direct marketing communications

From time to time we may use your personal information (except sensitive information) to provide you with marketing materials in relation to offers, specials, products and services that we have available or that are made available by others and we think may be of interest to you. If you would not like to receive direct marketing materials from us you may notify us using the contact details set out below.

If requested by us, a CRB may use credit reporting information about you to assess whether you may be eligible to receive direct marketing communications from us (i.e. pre-screening). You have the right to request that CRBs do not use credit reporting information about you for this purpose. You should contact each relevant CRB directly if you wish to request this.

Our use of online analytics tools and technology

We may collect personal information using cookies and other tools and technologies (including web beacons, device IDs, geo-location information, HTML5 local storage, Flash cookies and IP addresses).

Cookies are small files that store information on your computer, TV, mobile phone or other device which you use to browse websites (including our website) on the Internet. Cookies enable the entity that put the cookie on your device to recognise you across different websites, services, devices and/or browsing sessions. You can disable cookies through your internet browser but our website may not work as intended for you, or at all, if you do so.

To the extent we collect personal information about you through our use of cookies and similar tools and technology, we will collect, use, disclose and hold such personal information in a manner that is consistent with this privacy policy and in accordance with the Privacy Act.

We may also use cookies and other online analytics tools and technology provided by third-party partners on our website, including Google Analytics, Google AdWords, Google Ads Remarketing and Meta Pixel. To the extent required, we grant these third parties access to selected information in order to perform specific tasks on our behalf. They may also establish third-party cookies in order to deliver the services that they are providing. Third-party cookies may also be used to track you on other websites that use the same third-party service. As we have no control over third-party cookies, they are not covered by this cookie policy.

Our use of such tools and technology is subject to our compliance with the applicable terms and conditions, and the collection and processing of personal information by these third parties is subject to their applicable privacy policies.

Please refer to the privacy policies and privacy statements of Google and Meta for further information about how Google and Meta collect, use, process and protect personal information collected through the use of their technology and tools.
Cookies

A cookie is a data file that a website transfers to your computer. This enables the website to track the pages you have visited. A cookie only contains information you supply. It cannot read data on your computer. Our website uses cookies. You can set your browser to refuse cookies, however, this may mean you are unable to take full advantage of our website.

Anonymity and pseudonyms

You have the option of not identifying yourself or using a pseudonym when dealing with us unless we are required by law or a court/tribunal to deal with individuals who have identified themselves or it is impractical for us to deal with you if you have not identified yourself or used a pseudonym.

Variation of policy

We reserve the right to change this privacy and credit reporting policy from time to time to take account of new laws and technology, changes to our functions and activities and to make sure it remains appropriate. The updated policy will be available on our website.

Contact details

Please direct all complaints, requests and queries in relation to your privacy to: Privacy Officer, Level 1, 539 Brighton Road, South Brighton SA 5048, Telephone + 61 477 017 621 (e-mail address: [hello@alivebody.com.au]).