PRIVACY POLICY AND COLLECTION STATEMENT

INTRODUCTION

Hazletts maintains a Privacy Policy and a Collection Statement in compliance with the Privacy Act 1988 (“the Privacy Act”).

Hazletts is committed to respecting and protecting the privacy of its clients and the visitors to its website.

The Privacy Policy outlines Hazletts’ policy in managing the personally identifiable information (“the Information”) which Hazletts acquires and maintains in relation to its clients and the visitors to its website.

Regarding website visitors, Hazletts has structured its website so that, in general, a website visitor can visit Hazletts on the web without identifying itself or revealing any Information.

Regarding Hazletts’ clients, once a client chooses to provide Hazletts with the Information, that client can be assured that the Information will only be used to support the client’s commercial relationship with Hazletts.

PRIVACY POLICY

National Privacy Principles:

Hazletts is bound by the National Privacy Principles contained in the Privacy Act.

Collection Information:

Hazletts collects the Information directly from its clients and from visitors to its website.

In summary the Information is information or an opinion relating to an individual which can be used to identify that individual.

Legal basis for collection of the Information:

Hazletts collects the Information in order to fulfil its obligations to its clients to develop and maintain a system capable of providing comprehensive, efficient and accurate services to its clients.

Quality of Personal Information:

Hazletts will undertake all reasonable steps to ensure that the Information which is collected and maintained is accurate, complete and up-to-date. However, it is the responsibility of each client to notify Hazletts of any amendments which are required in respect of the Information relating to that client. Clients are therefore encouraged to contact Hazletts in order to update the Information.

Security:

The National Privacy Principles require Hazletts to take reasonable steps to protect the security of the Information.

Hazletts’ employees are required to respect the confidentiality of the Information and the privacy of individuals.

Hazletts maintains the following security measures which are designed to protect the Information from misuse and loss and from unauthorised access, modification or disclosure:

*          restricted access procedures

*          the confidentiality and disclosure provisions of any licence or service agreements made between Hazletts and third parties

Management Practice:

Clients and website visitors have the right to request more information about the way in which Hazletts manages the Information. This can be done by the client or website visitor submitting a request in writing to R. Hazlett & Co., Level 4, 122 Castlereagh Street, Sydney NSW 2000 or GPO Box 96 Sydney NSW 2001 or by contacting Hazletts on either of the following:

*          Telephone: (02) 9261 5211

*          Facsimile:  (02) 9264 7752

Where Hazletts no longer requires the Information relating to a client or website visitor for a permitted purpose under the National Privacy Principles Hazletts will take reasonable steps to delete, de-identify or destroy the Information.

COLLECTION STATEMENT

VISITORS TO HAZLETTS’ WEBSITES

Nature of Website Usage Information:

When a person accesses Hazletts’ website Hazletts’s internet service provider (ISP) may log the following information for standard statistical analysis:

*          the server address of the website visitor’s ISP

*          the date and time of the website visitor’s visit

*          the pages accessed by the website visitor

*          the type of browser used by the website visitor

The statistics package provided by Hazletts’ ISP collates the data into information and graphs for use in understanding the usage patterns of visitors to the website.

The statistics package does not identify any individual user during this process.

Cookies:

Hazletts’ website may use cookies. Cookies are small text files that are automatically stored in a designated file on a user’s computer.

Cookies themselves do not personally identify users, although they contain a unique identifier which allows the website to customise content based on a user’s previous selections, type of browser or type of computer.

Cookies allow a web application to respond to a user as an individual. By gathering and remembering information about the user’s preferences, the web application can tailor its operation to that user’s needs, likes, and dislikes.

Hazletts’ web server does not collect a user’s e-mail address or aggregate information on what other pages on the Web the user has accessed or visited.

E-Commerce Transactions:

Website users should be aware that there are inherent risks in transmitting information across the internet.

Information submitted when engaging in an online transaction with Hazletts is passed through a registered secure server. The registered secure server used by Hazletts makes use of all available protective processes for the security of e-commerce information.

Use and Disclosure of Information:

The basic user information collected is applied to assist Hazletts in analysing web traffic and to improve the content of its website. Cookies may be used to facilitate a user’s customer interaction with Hazletts. For example, Hazletts may use a cookie on the landing page of products sold online which record the customer information that is required on the order form, and then forward this information to its internal sales tracking database.

Hazletts may from time to time disclose to third parties aggregate information on its website’s traffic profile. For example, Internet advertising companies may require this data to help Hazletts better target its advertisements on its website and/or other websites.

Note that Hazletts’ website provides links to products and services offered by other companies. The other company's website that you link to will be able to determine that you linked from Hazletts’ website.

HAZLETTS’ CLIENTS

Nature of Client Information:

When a client engages Hazletts’ services that client provides Hazletts with Information which comprises both personal contact information and payment method information.

The personal contact information collected by Hazletts includes the client’s name, address, occupation, telephone numbers, facsimile numbers, email addresses, nominated representative’s name, the nature of the business conducted by the client and the category of that business together with other Information which assists Hazletts in administering Hazletts’s database and activities, providing and promoting Hazletts’ services and fulfilling Hazletts’ legal obligations.

Hazletts may from time to time ask for Information voluntarily (for example, through surveys) to enable Hazletts to maintain and improve its services.

Objectives in collecting the Information:

Hazletts collects the Information with the objective of:

*          contacting and reporting to clients

*          assessing and processing client information

*          communicating with clients

*          forwarding important information to clients

*          organizing and coordinating meetings, functions, seminars and events

*          producing Hazletts’ publications

*          producing, maintaining and updating a database containing information about clients

*          helping Hazletts manage and enhance its services

*          complying with Hazletts’ legal obligations

Management of Information:

For so long as a person is a Hazletts client Hazletts manages information with regard to that client’s account status, choice of services and customer logs. In addition, Hazletts may store clients' electronic mail and other communications as a necessary component of the transmission and delivery of those communications.

Use of Information:

In order to achieve the aforementioned objectives Hazletts may use the Information for the following purposes:

*          to include clients on Hazletts’ client database

*          to notify details of new services and products offered by Hazletts

*          to notify details of meetings, events and seminars that may be of interest to Hazletts’ clients

*          to receive notification from third parties about events, services or products that may be of interest to Hazletts’ clients

*          to administer Hazletts’ database for client service and financial accounting purposes

*          to help create and distribute Hazletts’ publications. Some distribution lists may be contracted to external mailing houses

*          to create media releases

*          to help improve Hazletts’ website for public access and viewing

*          to inform other Hazletts’ clients, associated groups and other interested parties associated with business and commerce of Hazletts’ clients’ contact details

Hazletts use a client’s personal contact information in order to establish and provide its services for the client.

Hazletts use a client’s payment information for payment processing purposes only.

Hazletts create and maintain other information such as customer account status, choice of services and customer logs in the normal course of providing its services.

Disclosure of Information:

Hazletts may disclose the Information via Hazletts’ website, Hazletts’ publications, Hazletts’ mailing lists and other means to the following parties:

(a)        Those suppliers of services or their agents (“the Suppliers”) who assist Hazletts in providing services to its clients or who perform functions on behalf of Hazletts for the purpose of the Suppliers conducting customer satisfaction surveys.

            The Suppliers include but are not limited to the Department of Lands, the Office of State Revenue, the Department of Commerce, Sydney Water,  Australian Securities and Investments Commission  and Veda Advantage.

(b)        Any person to whom the Information may be disclosed with the authorisation of the relevant client.

Hazletts may also collect the Information from the Suppliers in which case Hazletts will deal with the Information in accordance with Hazletts’ Privacy Policy.

Hazletts will not otherwise disclose the Information unless it has reason to believe that disclosing the Information is necessary to identify, make contact with or bring legal action against someone who may be causing harm or interference with the rights or property of Hazletts, its clients or third parties or where Hazletts has a bona fide belief that the law requires such disclosure.

Hazletts also will not, except for the reasons stated below, disclose to third parties the contents of any electronic mail or other electronic communications that Hazletts stores or transmits for its clients. The circumstances under which Hazletts will disclose such electronic customer communications include those circumstances in which:

(a)        it is necessary in order to provide services to the client;

(b)        it is necessary in order to protect the legitimate interests of Hazletts and its clients;

(c)        it is required to be disclosed in compliance with interception orders, warrants, or other legal process that Hazletts determines in its sole discretion to be valid and enforceable; or

(d)        it is necessary to be disclosed to a law enforcement agency when the contents are inadvertently obtained by Hazletts and in Hazletts’ sole opinion appear to pertain to the commission of a crime.

Hazletts disclaims any intention to censor, edit or engage in ongoing review or surveillance of communications stored on or transmitted through its facilities by clients or third parties. Hazletts will, however, review, delete or block access to communications that may harm Hazletts, its clients or third parties. The grounds on which Hazletts may take such action include, but are not limited to, actual or potential violations of Hazletts' Terms of Use.

Clients may opt out of receiving newsletters and/or notices of new or upgraded products from Hazletts by sending a request to privacy@hazletts.com.au. When making this request, clients must identify their domain name and contact information.

Please note, however, that Hazletts reserves the right to send at its sole discretion bulletins and other important information regarding its services.

Sensitive Information:

In some limited circumstances Hazletts may collect “sensitive information”.

Sensitive information will be used and disclosed only for the purpose for which it was provided or a directly related secondary purpose, unless the client agrees otherwise or where certain other limited circumstances apply (for example, where required by law).

Consequences of not providing Information:

A client may elect not to provide the Information to Hazletts or to consent to Hazletts using the Information. However, should a client so elect, Hazletts will be unable to provide services to the client in an accurate, comprehensive and efficient manner.

Access to and modification of the Information:

A client has the right to have access to and to modify the Information relating to that client. This can be done by the client submitting a request in writing to R. Hazlett & Co., Level 4, 122 Castlereagh Street, Sydney NSW 2000 or GPO Box 96 Sydney NSW 2001 or by contacting Hazletts on either of the following:

*          Telephone: (02) 9261 5211

*          Facsimile:  (02) 9264 7752

Prohibition on Use of Information:

Clients and website users are prohibited from:

(a)        using the Information other than for their own internal business purposes;

(b)        on-selling, sub-licensing, disclosing or otherwise providing the Information in any other form to any third party;

(c)        altering the format, meaning or substance of the Information supplied; and

(d)        making copies of the Information otherwise than is reasonably required for back-up purposes provided that such copies include a Proprietary Notice and are secured so as not to be accessible or used by unauthorised persons for any purpose other than back-up procedures.

DISCLAIMER

Hazlett’s website contains information, data, documents, pages and images (“the Data”) prepared by, but not limited to, the Department of Lands, the Office of State Revenue, The Department of Commerce, Sydney Water, the Australian Securities and Investments Commission and Veda Advantage.

Although the Data has been formulated with all due care, Hazletts does not warrant or represent that the Data is free from errors or omissions or that it is exhaustive.

The Data is made available on the understanding that Hazletts and its employees and agents shall have no liability (including but not limited to liability by reason of negligence) to the users of Hazletts’ website for any loss, damage, cost or expense, whether direct, indirect, consequential or special, incurred by or arising by reason of any person using or relying upon the Data and whether caused by reason of any error, omission or misrepresentation in the Data or otherwise. Users of Hazletts’ website will be responsible for making their own assessment of the Data and should verify all relevant representations, statements and information with their own professional advisers.

Furthermore, whilst the Data is considered to be true and correct at the date of publication, changes in circumstances after the time of publication may impact upon the accuracy of the Data. The Data may change without notice and Hazletts is not in any way liable for the accuracy of any information printed and stored by a user.

Hazletts takes no responsibility for the accuracy, currency, reliability and correctness of any information included in the Data provided by third parties nor for the accuracy, currency, reliability and correctness of links or references to information sources (including Internet sites) outside of Hazletts’ website. These external information sources are outside the control of Hazletts and it is therefore the responsibility of the Internet users to make their own decisions about the accuracy, reliability and correctness of information found on those external Internet links.

 
In addition to the Data, Hazletts’ websites provide links to other Internet sites. These external information sources are outside the control of Hazletts and it is therefore the responsibility of the Internet users to make their own decisions about the accuracy, reliability and correctness of information found on those external Internet links.

Hazletts Privacy Policy and Collection Statement