H.A. Bennett & Sons Pty Limited (ACN 007 450 811) and its related entities (referred to as Bennetts, we, our or us), are committed to the protection of your personal information in accordance with the Australian Privacy Principles set out in the Privacy Act 1988 (Cth) as amended by the Privacy Amendment (Enhancing Privacy Protection) Act 2012 (Cth) ( Privacy Act). The protection of your privacy is important to us. The integrity and privacy of our customer details are maintained and upheld at all times and not sold to any other organisation for any reason. That is why we have prepared this Privacy Policy to ensure you are aware of your rights and our commitment to your privacy.

This Privacy Policy describes the manner in which Bennetts collects, holds and uses personal information that is covered by the Privacy Act. It is not intended to cover categories of personal information that are not covered by the Privacy Act. If you wish to make any inquiries regarding this Privacy Policy, you should contact Bennetts in any of the ways specified in clause 10.

Bennetts may, from time to time, review and update this Privacy Policy including to take into account new laws, regulations and technology. All personal information held by Bennetts will be governed by our most recent Privacy Policy, posted on our website (www.hab.com.au) ( Website). Our most recent Privacy Policy will apply to our collection, use and disclosure of personal information.

1. "Personal information" is information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information is true or not, and whether recorded in a material form or not.
2. The type of personal information we collect about you includes:
   1. your name and address;
   2. your telephone numbers;
   3. your email address;
   4. your computer IP address from our Website;
   5. details of your previous dealings with us; and
   6. your financial information (eg. personal credit card information when you make payments to us).
3. We may collect your personal information in the following ways:
   1. in your credit application;
   2. in discussions with you whether in person or by telephone;
   3. through accounts and payments you make to us;
   4. through our Website or by email; or
   5. through a third party, such as our suppliers and merchants or your accountant or lawyer.
4. In some circumstances we may receive personal information that we have not requested. If this occurs, we will comply with our obligations under the Privacy Act. You acknowledge that we may deidentify and/or destroy this information unless we are required to keep it by law.
5. If we collect personal information about another individual from you, you agree that you will ensure that you have informed that individual that you are providing their personal information to us, have obtained their consent to do so and have advised them of this Privacy Policy, including advising that individual:
   1. of our identity, where to view this Privacy Policy and how to contact us;
   2. that he or she can access their personal information;
   3. the purpose for which we have collected their personal information; and
   4. the organisations or types of organisations that we usually disclose the information to.

1. We collect your personal information for the following purposes:
   1. to provide financial and business related information and/or services to you;
   2. to process transactions;
   3. for billing purposes;
   4. to provide you with information and updates on our company and the products and services and promotional offers that we provide using the email address that you have provided;
   5. to compose diagnostic and statistical information for our computer network;
   6. to evaluate the effectiveness of our Website and our products and services; and
   7. to enable us to better understand your needs and to communicate more effectively with you.
2. You have the option to deal with us anonymously or by using a pseudonym. However you acknowledge that where this is impractical (for example when you contract with us) or where the law or a court order provides otherwise we are not required to provide these options to you.
3. If you choose not to provide us with your personal information, we may not be able to undertake certain activities for you such as providing you with requested information, promotional information, products or services.
4. We may use your personal information to provide you with direct marketing materials if you would reasonably expect us to or if you consent to receive direct marketing materials. We will seek your consent to provide you with direct marketing materials if we have obtained your Personal Information from a third party. Direct marketing material may include promotional material about Bennetts or the products or services offered by us. You may opt out of receiving direct marketing material by contacting us in any of the ways specified in the direct marketing materials, by writing to or emailing us at privacy@hab.com.au, or as set out in clause 10 of this Privacy Policy.

1. We believe it is important to make sure that the personal information we hold about you is accurate and up to date. To this end our staff have procedures to monitor your personal information.
2. We also request that you contact us and tell us if any of your personal information has changed (eg. your address) or if you believe that the personal information is inaccurate. After you advise us we can then update our records and ensure that the personal information we hold is accurate and up to date.
3. You may contact us and request particulars of the personal information that we hold about you, and whether that personal information needs to be amended or corrected in any way. We may charge you a fee for providing this information depending on the nature of your request. You may contact us in any of the ways specified in clause 10.

1. We are committed to maintaining the security of our client(s) files and personal information.
2. We will take reasonable steps to protect your information and we use the following security measures to protect and maintain the safety of your personal information:
   1. locked offices;
   2. passwords on all our computers;
   3. a firewall on our computer network, which is monitored by computer security personnel; and
   4. virus protection software.
3. We will keep personal information as long as we need it for the purposes set out in clause 3.1 of this Privacy Policy, after which time we will destroy or de-identify the personal information. Otherwise we may keep personal information for any period required by law.

1. We may disclose personal information to:
   1. our staff and contractors that we engage to undertake services on your behalf;
   2. local, interstate, or foreign employees and agents which may be involved in providing you products and services;
   3. a third party contractor or service provider who may be performing services for us which involves your personal information or who we may engage to assist us in operating our Website, conducting our business, or servicing you, so long as those parties agree to keep this information confidential.
2. We may also disclose your information when we believe release is appropriate to comply with the law, enforce our site policies, or protect ours or others rights, property, or safety.
3. We will not sell your personal information to marketing bodies without your consent.
4. Your personal information may be disclosed outside of Australia to an entity in a foreign country, including entities in which Bennetts has an ownership interest. These countries include the United States of America, Canada and New Zealand. It is possible that such entity may be subject to foreign laws that do not provide the same level of protection of personal information as in Australia. We take steps to ensure that these overseas entities are obliged to protect the privacy and security of your personal information and use it only for the purpose for which it is disclosed.

1. When you view our Website we may store certain information on your computer. This information may be in the form of a small text file called a “cookie”. A cookie is a small file that asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.
2. We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our Website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.
3. Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.
4. You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the Website.

When you access and interact with our Website, we may collect certain information often referred to as “clickstream data”. Such data may include the type of internet browser and operating system you are using, the pages and information you accessed on our Website, the total time spent on our Website and the domain name of the website from which you linked to our Website. Clickstream data will not be used to identify you personally and will not be associated or correlated with any site visitor in a personally identifiable manner.

Our Website may contain links to enable you to visit other websites of interest easily. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information that you provide whilst visiting such sites and such sites are not governed by this Privacy Policy. You should exercise caution and look at the privacy statement applicable to the website in question.

1. If you have any concerns, queries, disputes or complaints about our Privacy Policy or our privacy practices, or you wish to update the personal information held by us please contact our privacy officer on 61 3 9853 0328 or email your request to "privacy@hab.com.au".
2. If you have any disputes of complaints, our privacy officer will attend to them and may request that you put your dispute or complaint in writing. Our privacy officer will investigate any dispute or complaint and respond to you within a reasonable time.
3. This Privacy Policy may be amended or updated to ensure that we maintain the highest standards.

We may revise this Privacy Policy from time to time. If we decide to change our Privacy Policy, we will update the Privacy Policy modification date below.

H.A. Bennett & Sons Pty Limited

(H.A. Bennett & Sons Pty Limited Privacy Policy-last modification date: May 2015)