GENERIC PUBLICATIONS PRIVACY POLICY

Our Privacy Commitment

Generic Publications Pty Limited A.C.N. 104 215 241 of 21A Richmond Road, Homebush West, New South Wales 2140 is committed to managing your personal information openly and transparently and to keeping your personal information safe. We will take all necessary measures to fulfil this commitment, including to comply with the Privacy Act 1988 (Cth) (Act) and the Australian Privacy Principles (APPs);

About this Policy

This policy is intended to explain clearly and in plain language some of the key processes and procedures that we have implemented to manage your personal information, to protect your privacy and to comply with the Act and the APPs.

References to "our", "us" and "we" in this policy are references to Generic Publications Pty Limited A.C.N. 104 215 241. A copy of this policy is available on the website located at www.gpadvertising.com.au (the website).

This policy gives a broad overview of our policies in relation to privacy but if you require further information, you are welcome to contact us or to read any of the privacy statements or notices that will be issued to you as and when personal information is collected.

You must read this privacy policy before providing us with any personal information, including using the website. By providing us with your personal information, you are confirming your agreement to the policies and procedures described in this privacy policy.

1. What sort of personal information do we collect?

Depending on the exact nature of our relationship with you, we may request that you provide some or all of the following information:

1. information that we may require to initially identify you, including your name, home address and your date of birth;
2. information that we can use to contact you, including your telephone number, mobile number, email address, work address, mailing address;
3. information we may require to confirm your identity, including your driver's licence number, passport details, business name, Medicare card;
4. information that may assist us to confirm your financial position or credit history when you are considering a finance or credit arrangement, including your credit card details, bank details, purchase history or transaction details and loan and credit information where finance arrangements apply.

It would be very unusual for us to need to collect all or even most of the above information from you however the information we will require will depend on the specific service or services that we are providing to you. We will only collect personal information from you that is necessary and relevant to our relationship with you and that we reasonably require in order to satisfactorily perform the services that you require from us.

Generally, we will not collect sensitive information (which includes information about your religion, political views, ethnicity, criminal records and sexual preferences). However, we may need to collect some sensitive information if you are applying for a job with us, and you have provided us with your consent to do so.

2. Why do we require your personal information?

There are various reasons why we might need to collect, hold, use or disclose your personal information and this will depend upon the specific services that we are providing to you but we will tell you the main reason for asking for your personal information at the time when we ask you to provide it.

Broadly, the reasons that we will need to collect your personal information include:

1. to provide a service to you, or in relation to a service that we are about to provide to you and for contacting you in relation to those services, which primarily include undertaking trade promotions or competitions and sending electronic newsletters or other communications:
2. to contact you in relation to an event, special offer or product that you might be interested in;
3. preventing fraud and other criminal activities;
4. to assist us to run our business and to improve our services and performance, including staff training, accounting, risk management, record keeping, archiving, systems development, developing new products and services and undertaking planning, research and statistical analysis; and
5. to comply with our legal obligations.

There is no obligation for you to provide us with any of your personal information but if you choose not to provide us with your personal information, we may not be able to provide the information, goods or services that you require.

3. How do we collect your personal information?

The means by which we collect your personal information will depend on the nature of the service that we are providing to you.

We may collect your personal information:

1. directly from you, either in person or over the phone or through the website;
2. from third parties, and from various social media platforms, like Facebook, where you interact with third parties and/or such platforms in conjunction with us or any of the services we provide;
3. from third parties, including from any enterprise carrying on business under the name or style of “Harvey Norman®”, “Domayne®” and/or “Joyce Mayne®”, whether a franchisee or otherwise;
4. by using geo-targeting (delivering content based on geographic location) software when you access or interact with social media platforms, like Facebook, if your privacy settings and preferences within that social media platform or website permit us to;
5. when you access and interact with the website;
6. from publically available sources, for example, the electoral role, the telephone directory or from other websites; or
7. from other sources

We will always collect your personal information directly from you unless it is impracticable to do so.

Your personal information will not be collected if you are only browsing a website. However, your location may be collected by geo-targeting software if your privacy settings and preferences within the website or social media platform permit the sharing of your location and cookies may be used to better tailor information and our services to meet your needs. A cookie is a small piece of text that is placed within the memory of a computer and can be later retrieved by web page servers. Cookies are used to enhance your interaction and convenience in using our website and we do not use cookies to record any of your personal information. Cookies may record information about your visit, including the type of browser and operating system you use, the previous site you visited, your server’s IP address, the pages you access and the information downloaded by you. While this anonymous statistical data may be aggregated and used in broader statistical analysis by us and our web monitoring service provider to improve our services, at no time can we personally identify you as the source of that data.

4. Collecting personal information about others

You represent and warrant to us that where you provide personal information to us about another person:

1. you are authorised to provide that information to us;
2. you have obtained the express consent of the individual to disclose their personal information to us for the use of that personal information by us, including for use in our business and to provide our services;
3. you have complied with the Act, including the APPs in collecting that personal information, including by making all relevant notifications required under APP 5 and specific to our use of the personal information; and
4. you have informed that person about the contents of this privacy policy including who we are, how we use and disclose personal information, and that they can gain access to, and correct, that information.

5. Unsolicited personal information

From time to time we may receive personal information about you that we have not requested or taken steps to come to know. In these circumstances, we will only hold onto such information as permitted by the Act. Any information that has not been requested but is subsequently retained by us will be subject to the procedures and requirements set out in this privacy policy.

6. How do we use or disclose your personal information?

We may use and disclose your personal information for the purposes for which it was collected or for a related purpose such as:

1. to consider your request for a product or service;
2. to enable us to provide a product or a service to you;
3. to facilitate and promote competitions or promotions;
4. to carry out or respond to your requests;
5. to any third-party suppliers of our goods or services;
6. to our third-party service providers, including to assist us in providing and improving our services to you, and to analyse market trends and better understand your needs or to develop, improve and market our products and services to you;
7. for regulatory reporting and compliance with our legal obligations;
8. to relevant third parties to undertake fraud checks;
9. to various regulatory bodies and law enforcement officials and agencies to protect against fraud and for related security purposes;
10. to perform administrative and operational tasks (including risk management, systems development and testing, staff training and collecting debts);
11. to include in a database compiled by us or our third-party service providers for use in direct marketing of promotions, products and services that we, or our third-party service providers, think may be of interest to you;
12. to seek your feedback in relation to particular products or services, customer satisfaction and our relationship with you and to manage any complaints;
13. to Harvey Norman Holdings Limited A.C.N. 003 237 545 (HNHL), the subsidiaries of HNHL and our related body corporates for the direct marketing by those entities of promotions, products and services offered by those entities,
14. to monitor or improve the quality and standard of service that we provide to you;
15. to consider any concerns or complaints you may raise against us;
16. to our agents, successors and/or assigns;
17. to notify you of offers that may be of interest to you; and
18. to better understand your preferences.

By agreeing to accept the terms of this privacy policy or by providing your personal information to us, or both, you are taken to have consented to the use and disclosure of your personal information for the above purposes.

At the time that we collect your personal information, we will make it clear to you why we are collecting your information, including through this privacy policy where appropriate. We will use your personal information in accordance with, and as permitted by, the Act.

Other than as outlined in this privacy policy, or in any notice provided to you at the time of collecting your personal information, we will not disclose your personal information without your consent unless disclosure is permitted by the Act.

7. Do we share your personal information with others?

We may provide your personal information to the third parties as outlined in this privacy policy.

We may share your personal information with HNHL, the subsidiaries of HNHL, our related body corporates and with any enterprise carrying on business under the name or style of “Harvey Norman®”, “Domayne®” and/or “Joyce Mayne®”, whether a franchisee or otherwise. By agreeing to accept the terms of this privacy policy or by providing your personal information to us, or both, you consent to your personal information being shared with these entities.

We deal with third party service providers who may assist us with a variety of functions including with marketing, research, mail and delivery, security, insurance, professional advisory (including legal, accounting and auditing advice), banking, payment processing, credit reporting, fraud checks or technology services. By agreeing to accept the terms of this privacy policy, or by providing personal information to us, or both, you are taken to have consent to us disclosing your personal information to our third-party service providers. Where we engage third party service providers to perform services for us, those third parties may be required to handle or deal with your personal information. Under these circumstances, those third parties must safeguard this information and must only use it for the purposes for which it was supplied and we will make all reasonable enquiries to try to ensure that this is the case.

Wherever possible, we will limit the information provided to independent third parties to that information required for those third parties to properly perform their functions.

8. Do we use your personal information for marketing purposes?

As part of the services that we provide to you, we may:

1. use personal information that we have collected about you to identify a product or service that may benefit you;
2. contact you from time to time to let you know about a product or service that we believe you might be interested in; and
3. disclose your personal information to our related entities or business partners or to third parties to enable them to tell you about a product or service that you might be interested in.

Where we intend to use your personal information for direct marketing purposes, we will seek your consent to do so prior to using your personal information. You can opt-out, unsubscribe or make a request not receive direct marketing communications from us, by calling 02 9201 6111 or by writing to us at 21A Richmond Road, Homebush West, NSW 2140. Additionally, each direct marketing communication, including all emails and SMS, will include an opt-out or "unsubscribe" option which will immediately indicate to us that you no longer wish to receive materials of this kind.

You may make a request that we do not disclose your personal information to facilitate direct marketing by another organisation and you may request that we provide you with the source of any personal information we use for direct marketing purposes. Any such requests will be actioned within a reasonable period of time and there will be no charges to you for making, or to you from us actioning, such requests.

9. How do we store your personal information?

We have implemented appropriate processes and techniques to protect personal information from loss, misuse and interference and from unauthorised access, modification or disclosure. In addition, access to your personal information is limited to those who specifically need it to conduct their responsibilities.

We take all necessary steps to destroy or permanently de-identify your personal information where it is no longer required and to protect your personal information from loss, misuse and interference and from unauthorised access, modification or disclosure.

While care is taken to protect your personal information on our websites, unfortunately no data transmission over the Internet is guaranteed as 100% secure. Accordingly, we cannot ensure or warrant the security of any information you send to us or receive from us online. This is particularly true for information you send to us via email as we have no way of protecting that information until it reaches us. Once we receive your personal information, we are required to protect it in accordance with the Act.

10. What if there is a breach in relation to my personal information?

We take breaches of your privacy very seriously. In the event that there is a data breach relating to personal information that we hold about you, such loss of, unauthorised access to, or unauthorised disclosure of, the information (“Data Breach”), we will take immediate steps to contain and remedy any effects of the Data Breach in accordance with our Data Breach Response Plan. Where required under the Act, we will notify you and the Office of the Australian Information Commissioner (“OAIC”) of the Data Breach.

11. Maintaining your personal information

We take reasonable steps to ensure that:

1. the information that we collect about you is accurate, complete and up-to-date at the time of collection;
2. when we use your personal information, it is accurate, up-to-date, complete and accurate at the time of use; and
3. if we disclose your personal information, it is accurate, up-to-date, complete and accurate at the time of disclosure.

You warrant that all information that you provide to us is accurate, complete and up to date at the relevant time.

12. Will we disclose your personal information to anyone overseas?

There may be circumstances where we need to disclose your personal information that we hold about you to a third party overseas ("Overseas Recipients"). This may occur, for example, where we have a database or server hosted outside Australia.

Prior to us disclosing your personal information to an Overseas Recipient, APP 8.1 requires that we will take all reasonable steps to ensure that the Overseas Recipient complies with the APPs (other than APP 1) in relation to your personal information, or that the Overseas Recipient is bound by laws that offer you at least as much protection as the APPs and that you are able to enforce your rights under those international laws in the event of any breach unless an exception applies (the "Overseas Disclosure Obligations").

We will take all reasonable steps to satisfy our Overseas Disclosure Obligations. The countries to which we are most likely to send your personal information include New Zealand, Malaysia, Ireland, United Kingdom, United States of America and Singapore.

13. How can you access your personal information?

Usually we will be able to provide you with access to your personal information upon receipt of your written request, either by email sent to privacy.officer@genericpublications.com.au or by post sent to The Privacy Officer, 21A Richmond Road, Homebush West, NSW 2140, and confirmation of your identity. There are some limited circumstances in which we may not be able to provide you with access to your personal information when requested. Such circumstances might include where access would pose a serious threat to the life, health or safety of another person or where such access would unreasonably impact on the privacy of others.

Where you request access to your personal information, we will respond to any such request in accordance with the Act. We may recover from you our reasonable costs of supplying you with access to your personal information but we will not charge you for any request you might make to access your information.

14. How can you seek to correct your personal information?

We do what we can to ensure that the information we hold about you is accurate, complete, upto- date, relevant and not misleading. To assist us to do this, it is imperative that you provide us with correct information at the time you provide it to us and immediately inform us if any of the information changes at any time. You may make a request that we correct any of your information. We would prefer your request to be in writing.

We will respond to any requests regarding the correction of your personal information within a reasonable period after the request is made in accordance with the Act.

We will not charge you for any request to correct your personal information, nor will we pass on to you any costs incurred by us in correcting your personal information or for associating a statement with your personal information.

15. What if you want to make a complaint about some aspect of our privacy procedures?

We are committed to maintaining and protecting your privacy but it is possible that in limited circumstances, mistakes might be made. If you are concerned with the way your personal information has been handled then you are entitled to make a complaint. If you would like to lodge a complaint, please contact us through our Privacy Compliance Officer, whose details are set out below.

If your personal information has not been handled in an appropriate way, we will do our best to remedy your concerns as quickly as possible. If your complaint is not satisfactorily resolved, you may approach an external dispute resolution service or apply to the OAIC to have the complaint heard and determined.

16. Protecting your identity

Wherever it is practicable, we will always provide you with the option not to identify yourself when dealing with us. Alternatively, you may elect to use a pseudonym to protect your identity.

17. Links to other websites

This website may contain links to websites which are owned or operated by third parties (being parties that are unrelated to us). You should make your own enquiries as to the privacy policies of these parties. We are not responsible for information on, or the privacy practices of, such websites.

18. Changes and exemptions to this policy

From time to time it may be necessary for us to review and revise this privacy policy. We reserve the right to change our privacy policy at any time.

Please note that the Act contains certain exemptions which may permit us to use your personal information in a particular way if specific circumstances arise. Any such exemption under the Act will take priority over this privacy policy to the extent of any inconsistency.

19. How can you contact us?

Please find below our contact details. Please do not hesitate to contact us in relation to any privacy-related concerns and we will use our best endeavours to address any such concerns thoroughly and in a timely manner.

If it is practical to do so, you can contact us without identifying yourself. However, if you choose not to identify yourself, it may be more difficult for us to assist you with your enquiry. This will depend on the nature of your enquiry.

20. Express consent to collection, storage, use and disclosure

In addition to the other consents provided by you above, by agreeing to accept the terms of this privacy policy, or by providing your personal information to us, or both, you are taken to have expressly consented to the collection, storage, use and disclosure of your personal information for each of the purposes and to all of the parties outlined in this privacy policy.

PP GP Version 1.0 February 2020