Our Privacy Commitment

Fragrance Vic-Mel (Spencer) Pty Ltd (ACN 169 848 159) (Fragrance) 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 complying with the Australian Privacy Principles (APPs).

About this Policy

This privacy policy outlines 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 Privacy Act 1988 (Cth) (Act) whilst carrying out our activities.

References to "our", "us" and "we" in this policy are references to Fragrance.

This privacy policy applies to personal information collected from and about staff, customers, suppliers and any other person whose personal information Fragrance may collect from time to time. Personal information is any information or opinion about an identified individual or an individual who is reasonably identifiable.

This privacy policy explains:

• what types of personal information we might collect;
• how we use personal information;
• when we will disclose personal information to others;
• how we manage and secure personal information;
• how you can access and seek to correct personal information that we hold about you; and
• how you may make a complaint if you think that we have breached the APPs.

From time to time, we may review and update this privacy policy – for example, to reflect changes to the law, technology or our company. You should check the privacy policy posted on our website periodically to read about any changes, modifications, or revisions that we have made.

1. What types of personal information do we collect?

Fragrance aims only to collect personal information that is reasonably necessary for its activities. The types of personal information that we collect will depend on the nature of the interaction between you and Fragrance, and where and how we collect the information.

Personal information collected by Fragrance may include:

• your name, postal address, email address, telephone and fax numbers and other contact details and also information about your use of Fragrance's services;
• information about job applicants, staff members, volunteers and contractors; and
• details of other people who come into contact with Fragrance such as suppliers.

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. However, in certain circumstances, if you choose not to provide your personal information to Fragrance, we may not be able to provide you with our services/do business with you or engage you to work at Fragrance.

2. How do we collect your personal information?

We will always collect personal information directly from you, unless it is unreasonable or impracticable to do so. For example, we collect your information when you make an order or payment, send us correspondence by e-mail or in writing, deal with us over the telephone or in person. We do not collect personal information from visitors on our website other than what is supplied to us on a voluntary basis. From time to time we may receive personal information about you that we have not requested or solicited. In these circumstances, we will only hold onto such information where the information is necessary in our dealings with you.

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

• you are authorised to provide that information to us;
• you have obtained the express consent of the individual to disclose their personal information to us for its relevant use, including for use in our business and to provide our services;
• you have complied with the APPs in collecting that personal information, including by making all relevant notifications required under APP 5; and
• 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.

3.How do we use your personal information?

Information of customers and suppliers

Personal information is collected from customers and suppliers to enable Fragrance to conduct its business. The purposes for which Fragrance uses personal information of customers and suppliers include:

• to provide them with its services and/or products;
• to provide ongoing support or help to manage products, for example if they have a query;
• to communicate with them;
• to provide information about other promotions, products or services that Fragrance considers would interest them (which they can tell Fragrance not to do at any time);
• to help Fragrance run its company, for example to improve its products or services or its security, train staff or undertake marketing activities; and
• to comply with its legal obligations.

If we collect your personal information for any other purpose, we will let you know that purpose at the time we collect the information.

Information of job applicants, staff members and contractors

Fragrance collects personal information of job applicants, staff members and contractors for the primary purpose of assessing and (if successful) engaging the applicant, staff member or contractor, as the case may be.

The purposes for which Fragrance uses personal information of job applicants, staff members and contractors include:

• managing the individual's employment or engagement;
• insurance purposes;
• ensuring that it holds relevant contact information; and
• satisfying its legal obligations.

4. When will we disclose your personal information to others?

Fragrance aims to confine its disclosure of personal information to the primary purpose for which it has been collected, or for a related purpose. This means Fragrance will usually only disclose personal information in connection with its business and administrative functions, including when disclosure is necessary to provide you with a product or service that you have requested; help us with the running of our organisation; or for security reasons.

Sometimes we may also disclose your personal information outside Fragrance for the purpose for which the information was collected, or for a related purpose – for example when disclosure is necessary to complete a transaction on your behalf, provide you with a product, service or activity you have requested, to facilitate day to day operations of our organisation, or for security reasons.

We may disclose your personal information to:

• companies related to Fragrance for the purposes of facilitating your orders and payments, completing transactions, to provide a product or service to you, direct marketing, product reviews and feedback;
• companies related to Fragrance that are located overseas in Singapore;
• outsourced service providers who perform functions on our behalf, such as organisations providing security services, conducting market research, analysis of sales and trends, providing email and mail handling services and generally helping us to improve our products and services to you;
• authorised agents and representatives of Fragrance who sell products or provide services on our behalf;
• anyone authorised by you to receive your personal information (your consent may be express or implied and can be withdrawn at any time);
• an actual or prospective purchaser in the event we sell part of our business; and
• anyone to whom we are required by law to disclose personal information.

We generally require third parties only to use your personal information for the specific purpose for which it was given to us and to protect the privacy of your personal information. We will only disclose your personal information to third parties on the basis that such parties agree with Fragrance to keep your information confidential.

Consent

By accepting the terms of this privacy policy or by providing us with your personal information, or both, you consent to the collection, use, storage and disclosure of your personal information for each of the purposes and to all of the parties outlined in this privacy policy.

Where we have obtained your express consent for the purposes of direct marketing or for any secondary purpose to that for which your personal information was collected, you may inform us in writing at any time that you withdraw that consent.

Sending information overseas

There may be circumstances where we need to disclose personal information that we hold about you to a third party overseas (Overseas Recipients). Fragrance will not disclose your personal information to an Overseas Recipient without first taking reasonable steps to ensure that the Overseas Recipient does not breach the APPs in relation to your personal information. However, we will not be required to take these steps, to ensure the Overseas Recipient does not breach the APPs in relation to your personal information, where:

1. you have provided your informed consent to the disclosure; or
2. the Overseas Recipient is subject to a law or binding scheme of equal or higher standards of privacy protection;
3. the disclosure is required under Australian law;
4. any other exception applies under the APPs.

5. Fragrance website

When you visit the public pages of our website, our website server makes a record of your visit and logs the following information;

• your IP ('Internet Protocol') address (which, in general terms, is a unique identifier assigned to your computer when it is connected to the Internet);
• search terms used;
• the operating system and Internet browser software you are currently using; and
• the data that you download (such as web pages or other document files or software), and the time that you download it.

This information cannot be used to identify you and is only used for statistical purposes to help us identify what parts of our website our users visit the most, which in turn assists us to determine how to improve our services.

If you contact us through our website or email us, Fragrance will only use your personal information to respond to your request or answer your queries. We will not add your email address to our mailing list without your consent.

Fragrance uses 'cookies' in the secure section of our website, which are a mechanism to keep track of certain information between visits to the site by the same user. Our website uses cookies to make the browsing experience more responsive when accessing some services on the website. This information is not linked to any personal information and cannot be used to identify the user. This means that Fragrance's obligations in relation to personal information do not apply to the information that it collects via cookies.

You can adjust your web browser's settings to detect or disable cookies if preferred.

Other websites

To the extent that our website contains links to sites operated by third parties, including other organisations, those linked websites are not controlled by us and we are not responsible for the privacy practices of the site operators. Before you disclose your personal information to any linked websites, we advise you to examine their privacy policies and terms and conditions of use.

6. How we manage and secure personal information

We have appointed the Privacy Officer to be responsible for the management of personal information that we collect. Fragrance staff are required to respect the confidentiality of all personal information and the privacy of individuals, and we have directed our staff that personal information must be dealt with in accordance with this privacy policy.

Fragrance has security systems in place which are intended to protect your personal information from misuse, loss, unauthorised access, modification or disclosure by the use of various methods including locked storage of paper records and password protected access rights to computerised records.

If Fragrance receives personal information about you which it did not request and which it does not reasonably require, Fragrance may destroy or de-identify this information where appropriate.

If you reasonably believe that there has been an unauthorised use or disclosure of your personal information, please let us know by contacting the Privacy Officer at the contact details listed in paragraph 9 below.

7. Updating personal information that we hold about you

Fragrance aims to keep all personal information that we hold accurate, complete and up-to-date. We encourage you to tell us if you change your contact details. If you believe that the information we hold about you is incorrect, incomplete or out-of-date, please contact the Privacy Officer. We will not charge you for correcting your personal information.

Fragrance is required by law to keep some types of information for certain periods of time. If we no longer require your personal information, we will generally destroy or de-identify that information. Any determination as to whether or not the information is required to be retained by us will be made within a reasonable period after the information is received by us. 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. Fragrance reserves the right to retain information for a period longer than that for which it is required to retain the information if Fragrance considers that it is necessary, and as long as it is in accordance with the APPs.

8.How you can access personal information that we hold about you

You have the right to obtain access to any personal information which Fragrance holds about you and to advise Fragrance of any perceived inaccuracy in that information. There are some exceptions to this right.

In some circumstances, Fragrance is entitled to deny access, for example if providing access would impact unreasonably on the privacy of others or prejudice negotiations in which we are involved. If we do refuse access, we will let you know the reasons for our refusal.

If you make a request for access to your personal information, we may ask you to verify your identity and specify what information you require. Fragrance may charge a reasonable fee to cover our costs of locating, retrieving, reviewing and copying any material requested. If the information sought is extensive, Fragrance will generally advise the likely cost in advance.

9. Questions or complaints

If you have any questions or would like to access or make a correction to your personal information that we hold about you, please contact us at:

   PDS Group
   E: info@pdsgroup.com.au
   T: (03) 9429 6211

If you would like to complain to us about Fragrance's compliance with the APPs, please ensure your complaint is made in writing and addressed to the Privacy Officer at the details set out above. We will do our best to remedy your concerns as quickly as possible, including by acknowledging receipt of your complaint within 48 hours and trying to resolve the complaint within 30 working days. Where this is not possible, we will contact you within this period to let you know an anticipated time frame within which your complaint will be resolved.

If your complaint is not satisfactorily resolved, you may approach an external dispute resolution service or apply to the Office of the Australian Information Commissioner ("OAIC") to have the complaint heard and determined.