PRIVACY POLICY

Bare Knuckles Group – Privacy Policy

Bare Knuckles Group (the Group) is firmly committed to protecting your privacy while interacting with our content, products and services. We aim to provide you with a secure and convenient service while at the same time allowing you to control your privacy and to give you a means to voice any questions or concerns you may have.

For this reason, we ensure your information is handled in strict compliance with the Commonwealth Government's Australian Privacy Principles set out in the Privacy Act 1988 (Act). Further information on Australian Privacy law is available from the Office of the Australian Information Commissioner (www.oaic.gov.au).

The purpose of this Privacy Policy is to tell you what kind of information we may gather or hold about you, how we may use that information, whether we disclose it to anyone, and the choices you have regarding our use of, and your ability to correct, this information.

This Privacy Policy covers:

• Members of the Group
• Collection of Personal Information
• Use of Personal Information
• Disclosure of Personal Information
• Marketing
• Data quality
• Storage and data security
• Access and correction
• Identifiers
• Complaint resolution mechanism
• Application and amendments to this Privacy Policy
• Disclaimer
• Contact

Members of the Group

The Group includes Bare Knuckles Group and its related bodies corporate. A reference in this Privacy Policy to the Group, "we", "us" or "our" refers to the members of the Group.

Collection of Personal Information

"Personal Information" is information or an opinion, whether true or not, and whether recorded in a material form or not, about an individual whose identity is apparent, or can reasonably be ascertained. Personal Information that we may collect and hold includes (but is not limited to) the following:

• name;
• postal, residential address and/or service address;
• email address;
• date of birth;
• contact details including telephone numbers (landline and mobile);
• gender;
• occupation and employment details;
• driver licence number;
• payment details;
• ASIC corporate searches;
• any feedback that you give us; and
• information that we collect for marketing purposes, such as your areas of interest and other information you provide to us.

We will collect Personal Information about you only if you provide it to us knowingly or otherwise in accordance with this Privacy Policy. We require this information to provide products and services to you. In some circumstances, we are required to collect this information to comply with our legal obligations such the identification requirements under the Anti-Money Laundering and Counter Terrorism Financing Act 2006.

We may also collect Personal Information from third parties including our related entities and general service providers in the course of providing products and services to you.

The Group may collect Personal Information directly from you when you:

• provide the information to us by completing a form or over the phone;
• visit our website;
• use our services;
• request information about us, our products or our services;
• provide feedback;
• fill in a form on our website; or
• where we are required or authorised by law to do so.

The Group will retain identification information about all individuals with whom it deals.

We may keep a record of visits to our website, using "cookies" and "log files" to store your preferences, record session information and collect information on how you visit and access our website and related online portals. This information is collected automatically whenever you use the website. A cookie is a small amount of data (which may include information about a user's identity, browser type or website visiting patterns) that is sent to your Internet web browser from our web server and stored on your computer. If you do not wish to receive cookies, you can set your browser so that your computer does not accept them. If you disable the use of cookies on your web browser or remove or reject specific cookies from our website or linked sites then you may not be able to gain access to all of the content and facilities in those websites.

We may also log IP addresses (i.e. the electronic addresses of computers connected to the Internet) to analyse trends, administer the website, track users' movements on the website, and gather broad demographic information for aggregate use and for advertisers and business partners.

Use of Personal Information

We use and hold the Personal Information we collect about you for our business functions and activities, which may include the following:

• to communicate with you and provide you with information, products or services you have requested;
• prepare reports, calculate levies, process and reconcile payments;
• deliver information to you;
• to establish and manage merchant facilities;
• to process direct debit payments or any reversals;
• assist customers by providing them with information and support;
• personalise and customise your experiences with our website;
• to manage and administer any account you may hold with us;
• to promote and market our products and services to you or provide you with information that we believe may be of interest to you;
• to personalise and customise your experiences on our website;
• to help us research the needs of our customers and to market our products and services with a better understanding of your needs and the needs of customers generally;
• to conduct research for the purposes of improving existing products or services or creating new products or services;
• to process any job application submitted by you;
• to collect payments;
• for business support purposes including maintenance, backup and audit;
• to allow us to provide advertising material to you regarding us, our clients, and other business partners;
• share the Personal Information with our related entities, business partners and selected third parties; and
• to respond to any queries or complaints you may have.

We may also use your Personal Information for other directly-related purposes.

You consent to us using your Personal Information in the above ways. We may also collect and use your Personal Information for other purposes not listed above. If we do so, we will make it known to you at the time we collect or use your Personal Information.

If you choose not to provide your Personal Information to the Group for the purposes set out in this Privacy Policy, we may not be able to undertake certain activities for you such as providing you with requested information, products or services.

We will not use Personal Information provided by you in a manner inconsistent with the Act, the Australian Privacy Principles or any other relevant laws or guidelines.

Disclosure of Personal Information

Depending on the nature of your engagement with us, we may disclose your Personal Information to the members of the Group, our other related entities and to third parties that provide products and services to us.

We may disclose your Personal Information to our external service providers such as mailing houses who distribute information to you on our behalf or market researchers who have been commissioned by the Group to carry out surveys and research. From time to time, we work may with corporate partners and other third-party providers to promote and/or market services that we consider will be of benefit to you.

We may also disclose your Personal Information to our website host or software application providers in certain limited circumstances, for example when our website experiences a technical problem or to ensure it operates in an effective and secure manner.

We do not otherwise disclose your Personal Information without your permission, unless the disclosure is:

(a) in accordance with this Privacy Policy or any agreement you enter into with us;
(b) required or authorised by law, including without limitation the Australian Privacy Principles; or
(c) made with your consent.

We do not disclose personal information to unauthorised overseas recipients.

Marketing

You consent to us using your Personal Information for sending you information, including promotional material, about us or our products and services, as well as the products and services of our related entities and third parties, now and in the future. You also consent to us sending you such information by means of direct mail, telemarketing, email, SMS and MMS messages. You can contact us if you do not want to receive marketing information from us, or by using the unsubscribe options provided in any Marketing Information email, if you want to stop receiving information.

We use remarketing tools and third-party technologies such as Google Analytics and other software as part of our digital marketing strategy/activities. These tools and technologies collect and analyse certain types of information, including cookies, IP addresses, onsite behaviour, purchase history and other similar information.

If you would like to know more about these remarketing tools and third-party technologies, you can view Google’s Remarketing Privacy Guidelines, Policies and Restrictions pages.

Data quality

The Group will take reasonable steps to make sure that the Personal Information it collects, uses or discloses is accurate, complete and up to date. To assist us in this, you need to provide true, accurate, current and complete information about yourself as requested, and properly update the information provided to us to keep it true, accurate, current and complete. Please contact us if you believe your Personal Information is inaccurate or incomplete, and we will use all reasonable efforts to correct the information.

Storage and data security

The Group will take reasonable steps to protect the Personal Information it holds about you from misuse and loss and from unauthorised access, modification or disclosure. The Group maintains strict standards and security procedures to prevent unauthorised access to the Personal Information whether it is in an electronic or paper format, and to ensure the correct use of this information. Personal Information is stored in a central database that is password protected with access available only to authorised persons (such as employees of the Group or our external database administrator) or otherwise your Personal Information is securely held within the Group's offices and available only to authorised persons.

If you have been provided with a secure login identity and password to access the Group's website, it is very important you keep the login identity and password secure and make every effort to ensure they are not misused, lost or stolen. You must tell us immediately if you become aware of or suspect your login identity or password has been compromised in any way that impacts or may impact access to the Group's website. The Group cannot be held responsible if you disclose the login identity or password to anyone else.

The Group will take reasonable steps to destroy or permanently de-identify the Personal Information if it is no longer needed for any purpose.

Access and correction

You are entitled to access the Personal Information we hold about you. If you request access to your Personal Information, in ordinary circumstances we will give you full access to your Personal Information. However, there may be some legal or administrative reasons to deny access. If we refuse your request to access your Personal Information, we will provide you with reasons for the refusal. We may charge a reasonable fee for providing you with access to that Personal Information.

A request for access can be made by contacting our Privacy Officer using the "Contact" details provided below.

If you establish the Personal Information we hold about you is not accurate, complete and up to date, the Group will take reasonable steps to correct the information so it is accurate, complete and up to date. If reasonable steps to correct the information cannot be taken by the Group where such correction of the Personal Information is not technically possible or would be impracticable for the Group to perform, the Group may be unable to continue to provide services to you. The Group will provide reasons for denial correction.

The Group may also update the Personal Information it holds about you if instructed to do so by certain third parties that originally provided us that information. The Group may also provide access to the Personal Information to such third parties.

Identifiers

The Group will not adopt as its own identifier, an identifier that has been assigned by a government agency (or by an agent of, or contractor to, a government agency acting in its capacity as agent or contractor).

The Group will not use or disclose an identifier assigned to you by a government agency (or by an agent of, or contractor to, a government agency acting in its capacity as agent or contractor) except where such use or disclosure is expressly provided for in this policy.

Complaint resolution mechanism

If you have a question, concern or complaint regarding the way in which we handle your Personal Information, you should contact our Privacy Officer using the "Contact" details provided below.

The Group takes a best practice approach to addressing privacy complaints. We will issue you with a timely response to any complaint that, if appropriate, will outline the measures the Group will take to resolve the complaint.

Application and amendments to this Privacy Policy

The Group will take reasonable steps to let you know, generally, what sort of Personal Information it holds, for what purposes, and how it collects, uses, and discloses that information.

The Group is constantly improving and enhancing its services to clients and may update this Privacy Policy from time to time. Any changes to the policy will be advised to you by updating this page on the website of the Group's members.

If you have any comments or suggestions regarding this Privacy Policy or if you have any concerns about what information we have about you or how we store it, please contact the Group's Privacy Officer using the "Contact" details provided below.

Disclaimer

Images and videos on this website, within downloadable content and in other promotional channels, are indicative of the latest advice and insights regarding marketing best practice.

Your access to and use of the content on this website is governed by these Terms and Conditions.

Contact

If you have any queries about this policy, or the manner in which the Group applies this Privacy Policy to your Personal Information please contact our Privacy Officer via this form.

Postal address:
Privacy Officer
Bare Knuckles Group
PO Box 581
South Yarra VIC 3141

These guidelines are in place as of 01/07/2022 and may be revised or updated at any time, without notice.