PRIVACY POLICY  

1 BACKGROUND  

This privacy policy describes the ways in which Naula Pty Ltd processes and protects your  personal information and data. In this policy, all references to “we” or “us” refers to Naula Pty  Ltd ACN 642 599 193 and any of our officers, employees, agents or assigns.  

1.1 Privacy Commitment  

We value your privacy and are committed to safeguarding your personal information, which we  receive in connection with our services. To achieve this commitment to privacy, we comply  with the Australian Privacy Principles and the Notifiable Data Breach Scheme contained in the  Privacy Act 1988 (Cth) (Privacy Act). This legislation governs the way we collect, use, disclose  and store your personal information and how we notify you in circumstances where your  information is lost or accessed without authorisation. For further information regarding  Australia’s privacy legislation, please refer to the Office of the Australian Information  Commissioner:  

∙ online at www.oaic.gov.au;  

∙ by email at enquiries@oaic.gov.au;; or  

∙ by telephone on 1300 363 992.  

1.2 Application  

By accessing our website, communicating with us or otherwise providing us with personal  information in connection with our services, you confirm that you have read and agree to the  terms of this policy and expressly consent to the collection, storage, use and disclosure of your  personal information in accordance with the terms of this policy.  

If you do not feel comfortable with any aspect of this policy, or do not agree to the terms of this  policy, please immediately contact us at info@naula.com.au.  

2 INFORMATION WE COLLECT  

2.1 Personal Information  

In this policy “personal information” refers to any information or opinion about you that we may  hold where you are identifiable or reasonably identifiable from that information or in connection  with other accessible information. Personal information will often include your name, contact  details, and financial details but will also include other information about you, such as your  communication habits and your commentary or opinion.  

We collect information about you in order to provide you with our services and to conduct our  business. In some circumstances, you may choose whether to provide personal information to  us, however your choices may affect our ability to offer you part or all of our services.  

Personal information we collect may include:  

(a) Contact Information: when you use our enquiry form you may provide personal  information such as your name, date of birth, gender, email address, contact  information and any other information which you may provide; 

(b) Communication Information: when you communicate with us via telephone, email,  SMS or online we will collect your contact information and any other information you  choose to provide to us;  

(c) Commercial Information: if you are the representative of one of our clients or  customers, you may need to provide personal information in the course of exercising  your business with us, this may include contact information and communication  information (as set out above) but may also include any other personal information you  provide or that we reasonably request in the course of administering, exercising or  enforcing our commercial arrangements with you or your business;  

(d) Cookie Information: when you access our website, we (including companies we work  with) may place small data files on your computer or any other device. These data files  may be cookies, pixel tags, e-tags, ‘flash cookies’ or other local storage provided by  your browser or associated applications, which are collectively referred to as “cookies”  in this policy. We use these cookies to recognise you, customise our services and  content, measure engagement, ensure your security, mitigate risk and prevent fraud  and to promote trust and safety across our site. You are free to decline our cookies in  your browser if your browser or browser add-on permits unless our cookies are required  to prevent fraud or ensure the security of the websites we control. However, we note  that declining our cookies may interfere with your use of our website.  

3 WHY WE COLLECT INFORMATION  

3.1 Why We Collect Your Personal Information  

We collect your personal information in order to carry out our services in the most professional  and efficient manner possible. We use your information for the purpose for which it was  collected. Some examples of why we collect your personal information include:  

(a) to provide our services to you and the businesses you represent;  (b) to managing agreements and arrangements between us;  

(c) to comply with legal obligations;  

(d) to resolve disputes, including to detect, prevent and investigate potential or actual  instances of fraud;  

(e) to respond to your enquiries; and  

(f) to enable third party service providers to provide us with services such as information  technology, auditing, and legal advice.  

3.2 Secondary Purposes for Collection  

Where your personal information is not ‘sensitive information’ we may use your information for  reasonably expected secondary purposes related to the purposes set out in the “Why We  Collect Your Personal Information” paragraph above.  

In addition, we may also use your personal information as otherwise authorised by law. 

4 INFORMATION WE DISCLOSE  

4.1 Who We Disclose Your Personal Information To  

We will only disclose your personal information for the purposes outlined in the “Why We  Collect Your Personal Information” paragraph above, or as you otherwise consent or authorise.  

We are not in the business of selling your personal information. We consider the privacy of this  information to be a vital part of our relationship with you. Therefore, we will not sell your  personal information to third parties, including third party advertisers.  

4.2 Third Party Disclosure  

In connection with the purposes of collection or as otherwise permitted under the Privacy Act,  we may disclose your personal information to third parties such as:  

(a) our service providers;  

(b) our related entities;  

(c) government agencies; and  

(d) financial institutions.  

We will take all reasonable steps to ensure that third parties we disclose your personal  information to maintain and protect the privacy and security of your personal information and  only use that information for the purposes for which it was disclosed.  

4.3 Overseas Data Transfer  

We will not send your personal information to recipients outside of Australia without first:  

(a) taking reasonable steps to ensure that the overseas recipient complies with the  Australian Privacy Principles, the Privacy Act and this policy;  

(b) obtaining your consent; or  

(c) otherwise complying with the Privacy Act.  

Currently, we do not disclose personal information to jurisdictions outside Australia.  

We may use cloud computing solutions or data storage which may be stored, under our control,  in servers located outside of Australia.  

5 HOW WE HANDLE INFORMATION  

5.1 Personal Information Security  

We take reasonable steps to protect personal information we hold at all times.  

We store and process your personal information in accordance with physical, electronic and  procedural safeguards to reduce the risks of loss, misuse, unauthorised access, disclosure  and alteration. We, in collaboration with our third party service providers, maintain physical  security measures to guard against unauthorised access to systems and electronic safeguards 

such as firewalls and data encryption. We ensure that access to your personal information is  limited to authorised employees who require that access to fulfil the responsibilities of their job.  

5.2 Information Retention  

We will only retain your information for as long as required for the purposes for which the  information was collected, or to comply with legal obligations or resolve disputes.  

We will take reasonable steps to destroy or de-identify your personal information when we are  no longer permitted to keep it.  

5.3 Data Breaches  

Where we detect misuse, loss or unauthorised access to or modification or disclosure of your  personal information, we will comply with all relevant provisions of the Notifiable Data Breach  Scheme operated under the Privacy Act.  

6 YOUR RIGHTS & CHOICES  

6.1 Anonymity & Pseudonymity  

You are entitled to engage with us on an anonymous or pseudonymous basis where it is  practical to do so. If you request, we will engage with you on an anonymous or pseudonymous  basis to the extent possible while complying with our regulatory obligations.  

6.2 Access & Correction  

You are entitled to access the personal information we hold about you and may request that  we correct any errors in the information we hold. If you would like to access or correct your  personal information held by us, please contact our Privacy Officer at the address below.  

We will take reasonable steps to allow you to access your information unless circumstances  exist that would prohibit us from doing so.  

We will correct your personal information where we are satisfied that the information is  inaccurate, out of date, incomplete, irrelevant or misleading. If we correct any personal  information that we have disclosed to third parties, we will take reasonable steps to notify those  parties of the change or update. You accept that following a request to correct your information  we may be required to take reasonable steps to verify your identity or the personal information,  which may include confirmation with third parties.  

If we refuse to provide you with access to, or the correction of, your personal information that  we hold we will provide reasons for such refusal in accordance with the Privacy Act.  

7 HOW TO CONTACT US  

7.1 Queries  

If you have any queries or concerns or would like to discuss any matter concerning your  privacy, please contact us at info@naula.com.au. 

7.2 Complaints  

If you are concerned that we may have breached the Australian Privacy Principles or the  Privacy Act, please contact us immediately. We will undertake a reasonable and expeditious  assessment of the concern and suggest relevant resolution processes.  

Alternatively, you may wish to contact the Office of the Australian Information Commissioner.  8 CHANGES TO THIS POLICY  

We may update this policy from time to time. We encourage you to periodically review this  page for the latest information on our privacy practices.  

The effective date of this policy is 21 December 2023.