Privacy Policy and Disclaimer

PART A - PRIVACY STATEMENT:

AFS & Associates Pty Ltd ('AFS') [ABN 51 061 795 337] understands that privacy is important to you.  Protecting your personal information is important to us.

This Policy explains how AFS handles personal information and complies with the requirements of the Australian Privacy Act 1988 (Cth) ("Privacy Act").  This policy relates to AFS's collection and handling of 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.

What does personal information mean?

Personal information is any information about you that identifies you or by which your identity can be reasonably determined.

Collection of personal information

AFS collects personal information from clients, customers, contractors and other individuals in the course of providing tax, accounting, audit, business services, share registry and related services.  AFS may collect personal information in order to;

• provide our service to you
• respond to your requests
• maintain contact with you
• to keep clients and other contacts informed of the services we offer and industry developments that may be of interest to you
• administer your security holding
• all other purposes related to our business.

We may use information about individuals to market our services, including by email.  However, individuals always have the opportunity to elect to opt out of this information service by writing to the Privacy Officer PO Box 454 Bendigo, 3552 or emailing us at afs@afsbendigo.com.au.  Please allow for 28 days for your request to be processed.

AFS collects personal information including but not limited to name, address, tax file numbers, financial institution details, phone numbers, email addresses and shareholding balances. This information is generally, but not limited to, provided to us either directly by you, financial institutions, or through the listed or unlisted organisation ('Issuer') in relation to a share registry service we provide or securities exchanges.  If part, or all of this information is not collected we may not be able to provide to you or the Issuer a complete and accurate service.

The information we collect is generally, but not limited to, being provided directly by you when we deal with you or from an application or other form you completed, verbally or via email depending how you communicate with us.  On occasion an Issuer or security brokers may also provide this information.

The policy of AFS is to only collect information in a way that is lawful, fair and is not unreasonably intrusive.

AFS takes reasonable precautions to ensure the security of personal information held by it from such risks as loss or unauthorised access, destruction, misuse, modification or disclosure.

We employ a number of means to protect your personal information including, but not limited to;

• external and internal premises security
• restricted access to personal information
• entering into confidentiality agreements with all employees, contractors and third party organisations
• business continuity planning

When we no longer require your personal information it is our practice to securely destroy the information or delete it from our systems.

How we use your personal information

It is the policy of AFS to use personal information for the purpose for which it was collected and to offer and provide related services that are connected to that initial purpose.  This includes for example providing, Issuers with registry and registry related services, or to notify you about other Issuer or AFS services relating to the purpose for which your personal information was collected.

AFS will not use or disclose your personal information for any other purpose without first obtaining your express or implied consent.

Will we provide your personal information to anyone else?

AFS does not sell, rent or trade personal information to or with third parties.  In some circumstances AFS will be required to disclose your personal information outside AFS.  For example;

• Disclosures may be required or authorised by law.  For example under the Corporations Act Chapter 2C certain information about you as a security holder (including your name, address and details of securities you hold) must be included in the public register of the entity in which you hold securities and, therefore this information will be disclosed to anyone who requests to inspect it.
• Personal information may also be disclosed to service providers contracted by AFS such as for the provision of IT support, print or mail services.  We require our service providers to adhere to our privacy guidelines and not to keep this information or use it for any unauthorised purposes.
• Documents provided to Banking Institutions under loan covenants established in relation to finance arrangements.

What is a Government identifier?

A Government identifier is a Commonwealth Government or Commonwealth Government agency designated identification number such as your Tax File Number (TFN).

Although at times AFS may request or hold details regarding certain Government assigned identification numbers we do not use such information as identifiers of our own.

We only use Government identifiers for purposes required by law such as when we supply your TFN to the Australian Taxation Office.

Does your personal information leave Australia?

AFS does not send personal information outside Australia unless it is authorised to do so by law.

Sensitive information

Some types of personal information is regarded as sensitive information if it concerns particular topics.  Sensitive information can be information about your;

• racial or ethnic origin; or
• political opinions; or
• membership of a political association; or
• religious beliefs or affiliations; or
• philosophical beliefs; or
• membership of a professional or trade association; or
• membership of a trade union; or
• sexual preferences or practices; or
• criminal record; or
• health information.

AFS only collects, uses or discloses this information about you as allowed by law.

Website

This policy also applies to any personal information we collect via our websites, including afsbendigo.com.au.  AFS may also collect personal information from you via its websites.

Cookies may be used on some areas of our websites. A cookie is a small software application which allows a website to recognise a previous user and to observe how a user navigates within a website. Cookies are now used as a standard by many websites. AFS uses cookies to improve the navigational experience of visitors to our websites and to make them easier to use.

If you are concerned about cookies, most browsers now recognise when a cookie is offered and permit you to opt out of receiving it. If you are not sure whether your browser has this capability, you should check with the software manufacturer or your internet service provider. In most cases, you can refuse a cookie and still fully navigate the AFS website.

In order to properly manage our websites, we may log certain statistics about the users of the sites, for example the users' domains and browser types. None of this information specifically identifies an individual and it is used solely to ensure that our websites present the best possible navigational experience for visitors.

If you log onto the website and read or download information our Internet Service Provider/Hosting Provider, will record your server address, domain name, the date and time of your visit to our website, the pages viewed and the information downloaded. This information is used for measuring statistical site performance and website development purposes only.

We can determine if you emailed any articles of interest to a friend using our 'email a friend' functionality, and if your friend has clicked on the hyperlink contained on the email that was sent by you.  We record the email addresses of these recipients which may be used for our own marketing purposes.

Because AFS wants your website experience to be as informative and resourceful as possible, we provide a number of links to websites operated by third parties. AFS is not responsible for the privacy practices or policies of those sites. We encourage you to review each website's privacy policy, especially if you intend to disclose any personal information via that site. A link to another non-AFS website is not an express or implied endorsement, promotion or warranty of the products or services offered by or accessible through that site or advertised on that site.

How we handle emails

We will preserve the contents of any email message that you send us if we believe that we have a legal requirement to do so.  Emails sent to or from us are routinely monitored for quality control, systems administration and legal compliance purposes.

Access and correction of your personal information

Under the Privacy Act you can access information that we hold about you, there some exceptions to this and these are detailed in National Privacy Principle number 6 Access and Correction (extracted from the Privacy Act 1988).

You also have the right to ask us to correct information about you which is inaccurate, incomplete or out of date.  AFS's policy is to consider any request for access or correction in a timely way and to take reasonable steps to correct the information so that it is accurate and complete.

To ensure the integrity and safety of your personal information, AFS will only disclose information if our internal procedures are satisfied.  This may include providing proof of identity and placing your request in writing.

In most cases, access to your personal information is available to you at no charge by contacting AFS on the following:

Phone: 03 5443 0344

Fax: 03 5443 5304

In writing: PO Box 454, Bendigo, Victoria, 3552.

Email: afs@afsbendigo.com.au

Please note if you are a security holder and your security holding is sponsored by a broker, you will need to contact your broker direct who will in turn arrange for the information to be collected.

For more detailed requests for information or in the instance that the information requested is not current and is kept in archives, a fee may be charged to cover the cost of retrieval and the supply of information to you.

All requests for access to personal information will be handled as quickly as possible and we shall endeavour to process any request for access within 30 days of having received the request.

If you have any questions or comments about this privacy policy, or you wish to lodge a complaint about the way we have handled personal information about you, please contact AFS's Privacy Officer

Phone:  03 5443 0344

Fax: 03 5443 5304

In writing: The Privacy Officer, PO Box 454, Bendigo, Victoria, 3552.

Email: afs@afsbendigo.com.au

This privacy policy may change from time to time to keep up with changes in the law, technology and practices.  As a result we may change this policy from time to time.

This Privacy Policy was last updated on 11 February 2009.  All material copyright © 2009 AFS & Associates Pty Ltd.

PART B - DISCLAIMER:

This website and the articles on our website are not a substitute for independent professional advice. We do not warrant the accuracy, completeness or adequacy of the information or material on this website. All information is subject to change without notice. We and each party providing material displayed on this website disclaim liability to all persons or organisations in relation to any action(s) taken on the basis of currency or accuracy of the information or material, or any loss or damage suffered in connection with that information or material. You should make your own enquiries before entering into any transaction on the basis of the information or material on this website. Please ensure you contact us to discuss your particular circumstances and how the information provided applies to your situation.

Quality of information - always check the information

Links to external websites

Security of our website

Users of our website should be aware that the World Wide Web is an insecure public network that gives rise to a potential risk that a user's transactions are being viewed, intercepted or modified by third parties or that files which the user downloads may contain computer viruses or other defects.

We and associated parties accept no liability for any interference with or damage to a user's computer system, software or data occurring in connection with this website. Users are encouraged to take appropriate and adequate precautions to ensure that whatever is selected from this website is free of viruses or other contamination that may interfere with or damage the user's computer system, software or data.

Notification

Notice of new or updated information or material available via our website may be emailed to our website members

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