At Podion Global ABN 17 14 109 334, we are committed to high standards of conduct in all our business activities, which includes protecting your privacy in accordance with the applicable privacy law. This policy describes how we will manage your personal information in an open, transparent, and lawful way.

This Privacy Policy applies to the personal information we collect, store, maintain and use about you as our customers, visitors to our websites, users and contributors to social media and other digital services, job applicants, and members of the public. By using our website, engaging with us (including via social media or other channels), or otherwise acquiring any product or service from us, you agree to and accept the contents of this Privacy Policy.

When we refer to personal information, we mean information which identifies you as an individual or from which your identity can be reasonably determined.

We collect and deal with your personal information so that we can better:

• assist you with your transactions with us;
• tell you about and improve our products, services, and experiences that we offer to you;
• support our business administration and related functions;
• accept/consider job applications, and send you opportunities that may be of interest to you;
• assist with any enquiries you make;
• meet our legal obligations; and
• for other reasons you might reasonably expect us to use your personal information for.

Without your personal information, we may not be able to provide our products or services to you.

When we collect and hold personal information, it may include details such as;

• name, company name and contact details (including business address, delivery address, email address, telephone number);
• marketing preferences, including the type of marketing materials you wish to receive and the method of delivery (email, SMS, direct mail, or other); and
• any other details reasonably related to dealings with us (e.g. job applications).

We may collect personal information about you during your interactions with us including when:

• you shop on our website;
• directly from you during conversations with our team members (by phone, in person or electronically);
• when you communicate with us during competitions, special events and promotions; and
• you visit or contribute to our online channels such as our websites, social media platforms and other digital services.

If you apply for employment and complete forms applicable to the recruitment and selection process, we will collect your personal information through that process.

We may also collect personal information from third parties including through the acquisition of third party mailing lists and from organisations with whom we have an affiliation.

Our website uses a technology called cookies. A cookie is a small element of data that our website may send to your computer. A cookie is typically stored on your computer’s hard drive and permits our website to recognise you when you return.

Our use of cookies helps us to provide you with a better experience during your use of our website by allowing us to understand what areas of the site are of interest to you.

You may configure your web browser to not accept cookies. You can also delete cookies that are already on your computer by going to the “settings” section in your browser which should provide instructions on how to locate the file or directory that stores cookies. Please note that by deleting or disabling future cookies, your user experience may be affected and you might not be able to use certain functions of our website.

We use a number of third party websites and social media platforms including Instagram, LinkedIn, Facebook and YouTube.

We may make use of any information that you make public when you use any such services or platforms. Such information available for use by us may include images and text relating to us or our products, services, promotions, events and club cards.

You may be able to access other third party websites through our websites. If the operators of those third party websites collect information about you, we may have arrangements in place with those third parties that allows us to collect or have access to that information.

The main purposes for which we collect, hold and use your personal information are:

• to provide you with products and services that you have requested from us;
• to communicate with you, including about products and services, special offers, and events which might interest you; and
• to answer your questions, provide you with information or advice or consider and respond to requests or complaints made by you.

If you are a candidate for employment, we may use your personal information to assess your suitability for a position with us.

We will use or disclose your personal information for direct marketing purposes if you have provided your information for that purpose or if you have subsequently provided consent for your information to be used in this way.

We may send you direct marketing communications to keep you informed about products and services we provide via email, mail, telephone, social media platforms or any other appropriate means.

We acknowledge and respect our customers’ choice to “opt-out” of direct marketing communication activities from us. You may choose not to receive direct marketing communications from us by ‘opting-out’.

You may opt out of direct marketing communications at any time by contacting us on +61 (0)3 9708 6349 or by emailing optout@podionglobal.com

You can also unsubscribe from emails by clicking the unsubscribe link on the footer of the email communication you have received.

We will comply with your optout request within a reasonable timeframe.

We may need to disclose your personal information to third parties who perform functions or services in connection with our business, such as delivery; product repair or recall; payment processing; marketing; banking; mailing functions; gateway provision; insurance; document management; information technology services including data storage, hosting and security; employment matters; for operation of our websites; or where we are otherwise required to by law.

Some of our third party service providers have operations overseas or are located overseas. In order for them to provide their services to us (e.g. storage and processing of our data, collection of personal information in a different country to your location), we may have to send your personal information overseas. Before we do so, we will take reasonable steps to ensure that our third party service providers do not breach the relevant privacy laws in relation to your personal information.

We will ensure that any overseas sharing of personal information is done in a way which requires compliance with privacy and security industry standards, both during transit and at the overseas destination.

Even though our website is professionally hosted and operate in a secure environment, there is always a risk in transmitting your personal information via the Internet. To make sure you are accessing a secure server, please check for the unbroken key or closed lock symbol generally located either at the bottom left or top right of your browser window. You can also check this by looking at the URL. If the URL is secure, then the first characters will read ‘https’ rather than just ‘http’.

We will take reasonable steps to protect your personal information, including from misuse, interference and unauthorised access or disclosure. We require our team members to adhere to our internal information security policies to safeguard your personal information at all times.

If we no longer need your personal information, then we may destroy or de-identify the information.

If we become aware that your information has been subjected to unauthorised access, we will report such breach as required by law.

We hold personal information in a number of ways, including:

• as part of customer records and other electronic documents which are stored in our information technology systems and servers or those operated by third parties who provide services to us in connection with our business; and
• by securely storing hard copy documents at our various premises and using third party document management and archiving services.

When practicable, you may choose not to identify yourself when dealing with us. You also may elect to use a pseudonym to protect your identity.

If you wish to access or correct any of your personal information, you may contact us at any time. The contact details for the Privacy Officer are set out below under ‘Contacting Us’.

Before we provide you with access to your personal information we will require proof of identity. Please provide as much detail as you can about the information you are requesting, in order to help us retrieve it. If we refuse your request or are unable to provide you with access to your personal information or are unable to provide it in the manner requested by you, we will provide a written response outlining our reasons.

Once your identity is confirmed, we will provide you with access to your personal information in a reasonable period of time, except in limited circumstances (such as if the 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).

We will endeavour to keep your personal information accurate, up-to-date and complete. You can assist us with this by letting us know if you notice errors or discrepancies in information we hold about you and letting us know if your details change.

If you consider any personal information we hold about you is inaccurate, out-of-date, incomplete, irrelevant or misleading you are entitled to request correction of the information. After receiving a request from you, we will take reasonable steps to correct your information.

Podion take reasonable steps to delete or securely destroy or permanently de-identify your personal information where it is no longer required and to protect your personal information from unauthorised access, disclosure, loss, misuse and alteration.

If you wish to have your personal information removed from our records, you may request that your personal information be deleted or securely destroyed. It will not always be possible to comply with your request to delete or destroy your personal information.

The current version of this Privacy Policy is available on our website. If you need a copy of this Privacy Policy in a different form, please ask us and we will try to meet your request. If we make any changes to this Privacy Policy, we will place the updated policy on our website.

If you have any questions or concerns about this privacy policy or how we have handled your personal information, you may contact us at any time. The contact details for the Privacy Officer are set out below under ‘Contacting Us’.

If you have a complaint about privacy, please contact the Privacy Officer. The Privacy Officer will first consider your complaint to determine whether there are simple or immediate steps which can be taken to resolve the complaint. If your complaint requires more detailed consideration or investigation, we may ask you to provide further information about your complaint and the outcome you are seeking. We will then typically gather relevant facts, locate and review relevant documents and speak with the individuals involved. We will respond to your complaint as soon as reasonably practicable and, in any case, within 30 days.

If you are not satisfied with our response to a complaint, or you consider that we may have breached the Australian Privacy Principles or the Privacy Act, you are entitled to make a complaint to the Office of the Australian Information Commissioner.

The Office of the Australian Information Commissioner can be contacted by telephone on 1300 363 992. Full contact details for the Office of the Australian Information Commissioner can be found online at www.oaic.gov.au.

We reserve the right to make changes to this privacy policy from time to time. Any changes to the privacy policy will be published on Podion’s website. This privacy policy was last amended in February 2020. We encourage you to periodically review the privacy policy for the latest information on our privacy practices.

If you would like to contact us in relation to this privacy policy or your personal information please contact us at:

Podion Global

100 Wedgewood Road, Hallam, Victoria, Australia 3803

Telephone: +61 (0)3 9708 6349

Fax: +61 (0)3 9708 6349

Email: info@podionglobal.com