Edwards Pavers

including all of its "Related Bodies Corporate" and/or "Associated Entities" as such terms are defined in the Corporations Act 2001 C'th highly values the privacy of our customers, franchisees, suppliers, employees and other persons who have business/commercial dealings or other associations/relationships with us.

Purpose

Edwards Pavers is committed to compliance with the Privacy Act 1988 C'th, including the 13 Australian Privacy Principles contained in Schedule 1 to such Act, the Privacy Regulation 2013 and the Privacy Credit Reporting Code 2014 – Version 1.2 ("the Legislation") in relation to the collection, use, management, protection and disclosure of personal information which comes into our possession or is under our control about the individuals with whom we conduct business, work or otherwise enjoy an association or relationship ("the Edwards Pavers commitment"). This Policy discloses how Edwards Pavers complies with the Legislation and otherwise achieves the Edwards Pavers commitment.

Important definitions

For the purposes of the Legislation and this Policy:

• Personal Information means: Information or an opinion about an identified individual, or an individual who is reasonably identifiable - (a) Whether the information or opinion is true or not; and (b) Whether the information or opinion is recorded in a material form or not.

• Sensitive Information means: (a) Information or an opinion about an individual's racial/ethnic origin, political opinions, membership of a political association, religious beliefs/affiliations, philosophical beliefs, membership of a professional/trade association, membership of a trade union, sexual orientation/practices or criminal record- that is also personal information; or (b) Certain health/genetic information (as further/better defined in Section 6 of the Privacy Act 1988 C'th) about an individual.

Other words/terms contained in this Policy and which have the same meanings as defined in Section 6 of the Privacy Act 1988 C'th are "Australian law", "breach", "consent", "credit", "credit information", "credit provider", "credit reporting body", "credit worthiness", "collects", "default information", "enforcement body", "government related identifier", "guarantee", "holds", "identification information", "identifier", "individual", "organisation" and "payment information".

Collection of personal information & why it is collected

Edwards Pavers only collects personal information which is reasonably necessary to enable us to carry out the various functions and activities of our organisation, efficiently conduct normal business /commercial operations and otherwise professionally and effectively connect/interact with the individuals with whom we have dealings ("the collection purposes").

The kinds of personal information collected and which Edwards Pavers holds includes:

• Identification information about an individual, in particular, full name, address, contact details, (email and telephone/facsimile numbers), date of birth, occupation and driver licence number;
• Trade referees and associated contact details;
• The individual's Bank and associated contact details;
• Particulars of assets and liabilities;
• Cookies/digital identifiers providing details/statistics in relation to website visits, notes made of telephone contact (including recorded/saved or transcribed voicemail/texts) and the content of letters received, copies of letters sent, facsimile transmissions and emails (both electronically stored and in printed form).

Personal information is collected to enable Edwards Pavers to:

• Assess the credit worthiness of an individual applying for a Commercial Credit Trade Account ("Trade Account") or an individual offering to guarantee a Trade Account sought by a corporate Applicant or another person;
• Assess the eligibility and credentials of an individual as a potential Franchise Operator or as an acceptable guarantor for an approved Franchisee;
• Supply products and/or provide services in the ordinary course of our business;
• Assess the capacity of an individual to pay or continue to pay for products and/or services delivered on credit terms;
• Assist in the management of Trade Accounts, including the collection of overdue amounts;
• Monitor and keep under review an individual's suitability for the provision of ongoing credit, taking into account payment history and other risk management criteria;
• Provide benefits/rewards to Trade Account customers who become members of our Edwards Pavers Trade Club;
• Maintain and expand our organisation's Database of customers and other business/commercial associates for the purposes of distributing industry information, issuing advertising/marketing materials, conducting product promotions and otherwise enhancing the way we do business.

Without the benefit of such personal information, Edwards Pavers might not be able to achieve or fully achieve the collection purposes.

Method of collection of personal information

Edwards Pavers obtains personal information by lawful and fair means primarily from the individual directly, but also from:

• Trade referees as provided by the individual (including as to default information and payment information);
• The individual's Bank, as disclosed by the individual;
• other credit providers, with the individual’s consent;
• credit reporting bodies authorised to disclose personal information, with the individual's consent (including disclosure of credit information, default information and payment information).

Use and disclosure of personal information

Edwards Pavers will only use or disclose personal information in our possession or under our control:

• If and as may be reasonably necessary in relation to the activities of an enforcement body or as may be required or authorised by Australian law;
• Otherwise, only for or in relation to the collection purposes.

In the course of pursuing achievement of the collection purposes, it may be necessary from time to time for Edwards Pavers to disclose personal information to or exchange such information with various third parties, including:

• Other credit providers;
• A credit reporting body;
• Guarantors of corporate Applicants/other persons seeking a Trade Account and/or appointment as a Franchise Operator;
• Major clients (such as Building/ Construction companies) and suppliers of related products/services with whom we have developed working relationships (with the individual's consent);
• Our legal, accounting, business, information technology and/or data management/storage advisers, consultants or contractors.

Disclosure beyond the jurisdiction of Australian law

Edwards Pavers is unlikely to disclose personal information to any overseas recipient.

However, should Edwards Pavers intend to, for any reason, in fact disclose personal information to an overseas recipient, we will:

• Take prior reasonable steps to ensure the overseas recipient does not breach the Legislation; or
• First be reasonably satisfied that the overseas recipient is subject to substantially similar laws with respect to the protection of personal information (including the availability to the individual concerned of enforcement rights and mechanisms); or
• First obtain the individual's consent (after informing him or her that such consent will have the effect of relieving us from any responsibility should the overseas recipient breach the Legislation); or
• In any event, be likewise relieved from any such responsibility should the disclosure to an overseas recipient be required or authorised by Australian law.

Integrity, protection & security of personal information

Edwards Pavers will take reasonable steps to ensure that personal information collected, used and disclosed is:

• Accurate, up-to-date, complete, relevant and not misleading;
• Protected from misuse, interference and loss;
• Protected from unauthorised access, modification or disclosure;
• Securely stored on our computer network and otherwise at one or more of our various business premises within Australia;
• Destroyed or de-identified when no longer needed by our organisation or required to be retained by Australian law.

Some of the security measures we have in place to protect personal information include:

• A secure server for our computer network, including installation and maintenance of firewalls, use of log-in passwords/tools and virus protection programs;
• Restriction of access to relevant personnel only;
• Internal training of relevant personnel regarding our obligations with respect to the handling and management of personal information.

Also, Edwards Pavers will:

• Not adopt any government related identifier for an individual as our own identifier for such individual, nor disclose such identifier unless required or authorised by Australian law;
• Subject to it being lawful and reasonable to do so, destroy any unsolicited personal information coming into our possession or under our control (or de-identify such information), unless it is determined that we could have lawfully and fairly solicited/collected the information.

Direct marketing communications

All direct marketing communications issued by Edwards Pavers contain a prominent statement regarding the simple means by which recipients may easily request not to receive further such communications (opt out) and we will promptly action any such request, without charge.

Anonymity and pseudonymity

Subject to being lawful and practicable, individuals have the option of not identifying themselves personally, or using a pseudonym when dealing with Edwards Pavers.

However, if this option is exercised, we may not be able to provide some or all of our products and/or services, nor extend the high level of attention and service we otherwise strive to deliver.

Sensitive information

Edwards Pavers will not collect sensitive information about an individual unless:

• The individual consents and such information is reasonably necessary or directly relevant to our business functions and activities;
• Such collection is required or authorised by Australian law.

Access to or enquiries/concerns relating to personal information

Any individual about whom Edwards Pavers holds personal information may contact our designated Privacy Officer to:

• Gain access to and/or seek the correction or updating of such information;
• Request notification be given to any other credit provider to whom personal information has been previously disclosed of corrections/amendments we have agreed to make;
• If we are unable to change personal information in accordance with a request, have a statement prepared by the individual (asserting his/her position) associated with the information, so that the statement is apparent to users of the information;
• Have personal information added to or removed from our Marketing Database or Internet website;
• Make any enquiry, request or complaint about our compliance with the Legislation (we will respond within a reasonable period of time, be open/transparent and act fairly, reasonably and lawfully with respect to any requests/complaints);
• Request a paper copy of this Privacy Policy (free of charge).

Should we be unable to comply with any request, in particular to change personal information held about an individual, we will provide a written notice setting out the reasons (unless it is unreasonable for us to do so) and available mechanisms to complain about our decision.

Edwards Pavers may charge for giving access to an individual to his/her personal information and if we do so, such charge will be reasonable and shall not apply to the making of the access request itself.

Edwards Pavers will not charge an individual at all for making a request to correct/update personal information or to associate an individual's statement with his/her personal information (in circumstances where we are not able, for good/sufficient reason, to change such personal information).

Contact details for our Privacy Officer are:

The Privacy Officer

Liam@edwardspavers.com.au

Edwards Pavers 12 Lionel Road MOUNT WAVERLEY VIC 3149

Currency of this policy

We may update this policy from time to time, and may let you know of significant changes to this policy by posting a notification on our website. The current version of this policy will always be available on our website.