This Privacy Policy applies to any person whose personal information may be collected by BUSBY Web Solutions (ABN 68 100 438 855) hereafter referred to as BUSBY in the ordinary course of its business.

1.1. Purpose of the policy

BUSBY takes its obligations under the Privacy Act seriously and would like to take all reasonable steps in order to comply with the Act and protect the privacy of the personal information that we hold. This policy sets out how we intend to do so.

1.2. The personal information that the firm collects

BUSBY collects and holds the following personal information from customers, and franchises -

Your name:

Date of birth:

Address:

Financial data as provided by you to justify granting of franchise benefits or credit on your behalf.

In the case of Franchisees any other personal information requested in the Franchisee application form. We may contact you by telephone, email or mail using the details you have provided to confirm and verify the information you have supplied. We also automatically receive and record personal information on our server logs when you are browsing our Website. We use this information to do internal research on our user's interests and behaviours to better understand and serve our users.

Cookies are pieces of information that a website can transfer to an individual's computer hard drive for record keeping. Cookies can make websites easier to use by storing information about your preferences on a particular website. The information remains on your computer after the internet session finishes.

Most internet browsers are pre-set to accept cookies. If you prefer not to receive cookies, you can adjust your internet browser to refuse cookies or to warn you when cookies are being used.

1.3. Why we collect it

BUSBY collects, uses and discloses the information in accordance with the Collection Statement. The purpose of collecting personally identifiable information is to allow the BUSBY to fulfil their contractual agreement with you, namely to provide web solutions or franchised business services. This information is only obtained from you when you voluntarily provide it to us.

BUSBY, as service providers, understands the importance of maintaining the confidentiality of our client information. To maintain our reputation as a professional and efficient business of the highest integrity, any information provided by you is treated in strict confidence and shall remain confidential.

In addition to the primary purpose of collection identified above, the information may be used for a secondary purpose by being provided to our wholly owned subsidiaries to allow them to inform you about other services that may suit your needs.

We will use your personal information to contact you regarding our promotions and for marketing purposes. If you do not wish us to do so you can opt out by placing a check in the opt out box on the form on which information is collected from you or by telling one of our employees over the telephone that you do not wish to receive such information.

No information collected in relation to the above will be disclosed to any unrelated third party without your prior approval.

1.3a The Buyer and/or the Guarantor/s agree for the Seller to obtain from a credit reporting agency a credit report containing personal credit information about the Buyer and Guarantor/s in relation to credit provided by the Seller.

1.3b The Buyer and/or the Guarantor/s agree that the Seller may exchange information about the Buyer and the Guarantor/s with those credit providers either named as trade referees by the Buyer or named in a consumer credit report issued by a credit reporting agency for the following purposes:

(a) to assess an application by Buyer; and/or

(b) to notify other credit providers of a default by the Buyer; and/or

(c) to exchange information with other credit providers as to the status of this credit account, where the Buyer is in default with other credit providers; and/or

(d) to assess the credit worthiness of Buyer and/or Guarantor/s.

1.3c The Buyer consents to the Seller being given a consumer credit report to collect overdue payment on commercial credit (Section 18K(1)(h) Privacy Act 1988).

1.3d The Buyer agrees that personal credit information provided may be used and retained by the Seller for the following purposes and for other purposes as shall be agreed between the Buyer and Seller or required by law from time to time:

(a) provision of Goods; and/or

(b) marketing of Goods by the Seller, its agents or distributors in relation to the Goods; and/or

(c) analysing, verifying and/or checking the Buyer's credit, payment and/or status in relation to provision of Goods; and/or

(d) processing of any payment instructions, direct debit facilities and/or credit facilities requested by Buyer; and/or

(e) enabling the daily operation of Buyer's account and/or the collection of amounts outstanding in the Buyer's account in relation to the Goods.

1.3e The Seller may give information about the Buyer to a credit reporting agency for the following purposes:

(a) to obtain a consumer credit report about the Buyer; and/or

(b) allow the credit reporting agency to create or maintain a credit information file containing information about the Buyer.

1.4. Access to your personal information

BUSBY provides access to the personal information that we hold about you. Access will be provided in accordance with our Access Policy. If you require access to your personal information please contact the Company Secretary.

1.5. Complaints

If you have any complaints about our privacy practices or wish to make a complaint about how your personal information is managed, please contact the Company Secretary. Complaints will be handled under the BUSBY's Privacy Complaints Policy.

1.6. Storage

We will take all reasonable steps to protect the security of the personal information that we hold. This includes appropriate measures to protect electronic materials and materials stored and generated in hard copy.

COLLECTION STATEMENT

The personal information collected is collected by the BUSBY.

2.1. Use

Personal information is collected for the purpose of providing web solutions or franchised business services.

2.2. Disclosure

We will provide your information to such of our franchises as we deem necessary for you to receive the services you request. We will not sell your personal information to any third party. We will only disclose your personal information where:

- we have your consent to share the personal information. By providing us with your information you consent to allow us to provide such information to our franchises for the purpose of you obtaining the service you have requested or other information related to our business;

- we are required by law to do so.

- we deem it necessary to provide you with services related to our business;

- we reasonably believe that use or disclosure is necessary to prevent or lessen a serious and imminent threat to an individual's life, health or safety or a serious threat to public health or safety; or we have reason to suspect that unlawful activity has been, is being or may be engaged in and the use or disclosure of your personal information is a necessary part of any investigation of the matter or in reporting our concerns to relevant persons or authorities.

2.3. Legal reasons why we collect the personal information

We collect the information in order to comply with our legal obligations under the contractual arrangements we have with you and to meet legal requirements you have in regard to taxation and other statutory returns.

2.4. What happens if you choose not to provide the information?

You are not obliged to give us your personal information. However, if you choose not to provide BUSBY with the personal detail required we may not be able to provide you with the service requested to meet your requirements.

2.5. Access

You can gain access to the personal information BUSBY holds about you. If you wish to do so please refer to our Access Policy or contact the Company Secretary.

2.6. Sources of information

Where possible, BUSBY will collect the information directly from the client.

ACCESS POLICY

This policy is directed to those individuals whose personal information is held by BUSBY.

3.1. Purpose

The purpose of this Policy is to set out how BUSBY will provide access to your personal information. The Policy is part of our Privacy Policy and our desire to provide for, maintain and give effect to your right to privacy.

3.2. Overriding principles

At all times the conduct under this Policy will be governed by the following principles -

- All requests for access will be treated seriously;

- All requests will be dealt with promptly;

- All requests will be dealt with in a confidential manner;

Your requests to access your personal information will not affect your existing obligations or affect the commercial arrangements between you and BUSBY.

3.3. Form of Access

BUSBY will provide access by allowing you to inspect, take notes of or receive copies or print outs of the personal information BUSBY holds about you.

You can make your request in writing by contacting the Company Secretary. To obtain access you will have to provide proof of your identity, to the reasonable satisfaction of the Company Secretary. This is necessary to ensure that personal information is provided only to the correct individuals and that the privacy of others is not undermined.

3.4. When will Access be denied?

Access will be denied if -

- the request does not relate to the personal information of the person making the request;

- providing access would pose a serious and imminent threat to life or health of a person;

- providing access would create an unreasonable impact on the privacy of others;

- the request is frivolous and vexatious;

- the request relates to existing or anticipated legal proceedings;

- providing access would prejudice negotiations with the individual making the request;

- access would be unlawful;

- denial of access is authorised or required by law;

- access would prejudice law enforcement activities;

- access discloses a 'commercially sensitive' decision making process or information; or

- any other reason that is provided for in the National Privacy Principles (NPP's) set out under the Privacy Act.

Where possible, BUSBY will favour providing access. It may do so by providing access to the appropriate parts of the record or by using an appropriate "intermediary".

Where there is a dispute about the right or forms of access, these will be dealt with in accordance with BUSBY's grievance policy.

3.5. Time

We will take all reasonable steps to provide access within 30 days of your request. In cases where the request is not complicated or does not require access to a large volume of information, we will provide information within 14 days.

3.6. Costs and Charges

BUSBY will impose reasonable charges in relation to the following:

- Photocopying;

- Delivery cost of information stored off-site - where information is stored off-site, the cost of obtaining access to the information; Access to electronic databases.

PRIVACY COMPLAINTS: How we handle privacy complaints (for individual clients)

4.1. Introduction

BUSBY sees the importance of privacy to BUSBY, its customers and other stakeholders. As such, BUSBY is committed to protecting the privacy of the personal information that we hold. This is part of BUSBY's -

Legal obligations under the Privacy Act 1988.

Ethical and business obligations

Service to you

BUSBY places high priority on effectively dealing with any complaints relating to privacy concerns that you may have.

4.2. Overriding principles At all times the conduct under this policy will be governed by the following principles -

All complaints will be treated seriously.

All complaints will be dealt with promptly.

All complaints will be dealt with in a confidential manner.

The privacy complaint will not affect your existing obligations or the commercial arrangements that exist between this firm and you.

4.3. Who may complain under this policy?

If you have provided us with personal information you have a right to make a complaint, have it investigated and dealt with under this policy.

4.4. What is a privacy complaint?

A privacy complaint relates to any concern or dispute that you have with our privacy practices as it relates to your personal information. This could include matters such as -

- How personal information is collected;

- How personal information is stored;

- How this information is used or disclosed;

- How access is provided.

4.5. What do I do if I have a complaint about privacy practices?

All complaints should, in the first instance, be in writing. Usually, your contact with the firm will be the proper person to discuss or resolve your complaint, however, if your privacy complaint is not resolved the matter will then be referred to our Privacy Officer (Mr Keegan Crage).

All complaints will be logged on a complaints register.

4.6. Grievance procedure

The goal of this policy is to achieve an effective resolution of your complaint within a reasonable set timeframe (30 days or as soon as practicable). Once the complaint has been made, the point of contact can then resolve the matter in a number of ways -

Request further information - Your initial contact may request further information from you. You should be prepared to give as many details as possible including details of any relevant dates and documentation. This will enable the contact to investigate the complaint and determine an appropriate and useful solution. All details provided will be kept confidential.

Discuss options - We will discuss options for resolution and if you have suggestions about how the matter might be resolved you should discuss these with your contact. The contact could also suggest other solutions or give examples of how the personal information can be revised or stored in a different way.

Investigation - The complaint may be investigated. BUSBY will try to do so as soon as possible. It may be necessary to contact others in order to proceed with the investigation. This may be necessary in order to progress your complaint.

Escalate internally - If your complaint cannot be resolved at a local level or by the Privacy Officer, it will then be referred to an Executive Director. This will be discussed with you before the referral occurs.

Discussion with any other parties - If your complaint deals with the conduct of our employees we will raise the matter with the employee concerned and seek their comment and input in the resolution of the complaint and investigation stage.

The complaint is resolved - If your complaint is found to be substantiated, you will be informed of the reason for the decision. BUSBY will then take appropriate steps to resolve the complaint and prevent the problem from recurring.

The complaint is not resolved - If the complaint is not substantiated, or cannot be resolved to your satisfaction, but this policy has been followed, the decision of the Managing Director will be final. Your contact will discuss with you the reasons for the decision.

Disagreement as to outcome - If there is still disagreement your complaint will be dealt with by a mutually agreed independent intermediary.

Further Action If after all the above steps have been followed your complaint is unresolved you are free to take your complaint formally to the Federal Office of the Privacy Commissioner.

4.7. Records

The Group will keep a record of your complaint and the outcome. Such material will be confidentially stored.

4.8. Anonymous complaints

BUSBY is unable to deal with anonymous complaints as we are unable to investigate properly and follow up such complaints.

However, in the event that an anonymous complaint is received, BUSBY will note the issues raised and try and resolve them appropriately. For example, BUSBY may wish to conduct further training or provide assistance in a given area.

4.9. Information

For any further information about this policy, please contact our Privacy Officer on privacy@busbywebsolutions.com.