Purpose
The purpose of this Policy is to ensure that Atticus, an entity that is subject to the Australian Privacy Principles contained in the Privacy Act 1988 and the Privacy Amendment (Enhancing PrivacyProtection) Act 2012 (together Legislation), manages personal information in a manner that complies with the Legislation. For the latest versions of theLegislation, please see www.comlaw.gov.au This Policy sets out Atticus's management and requirements in relation to the protection and proper handling of personal information collected from individuals. It also provides individuals with the opportunity to make inquiries about Atticus estate’s compliance with the Legislation. For further information in relation to privacy, please visit the Office of the Australian Information Commissioner’s website at www.oaic.gov.au 

User’s Rights
Individuals are not required to identify themselves when dealing with Atticus unless:      
Atticus is required or authorised by or under an Australian law, or an order of a court or tribunal, to deal with individuals who have identified themselves; or it is impracticable for Atticus to deal with individuals who have not identified themselves or who have used a pseudonym. For instance, when individuals purchase real-estate properties from Atticus, it is necessary for those individuals to correctly and properly identify themselves.


Collection of Personal Information 
Atticus only collects personal information when it is reasonably necessary for Atticus’s functions or activities. The types of personal information that Atticus may collect includes, but is not limited to:·      
identity of the individual (for instance, name, address, date of birth and contact details, etc.,);·       
proof of identification of the individual;·       
financial circumstances of the individual;·       
the tax file number or other information allocated by the Australian Taxation Office to the individual;·       
personal requirements and preferences in relation to Atticus’s products or services; and·      
any other information which Atticus may be able to or be required to collect by the legislation or under an Australian law.
The circumstances for which Atticus may collect personal information include, but are not limited to:·       
when the individual becomes a purchaser or potential purchaser of Atticus’s products or services;·       
when the individual becomes a tenant or potential tenant of Atticus;·       
when the individual submits a job application to Atticus;·       
when the individual seeks Atticus’s advice in relation to investment opportunities;·       
when the individual becomes a supplier or potential supplier to Atticus;·       
when the individual attends Atticus’s office or showroom for inspections of Atticus’s products;·       
when the individual contacts Atticus directly for a specific inquiry; or·       
any other circumstances where the individual makes contact with Atticus and it is practical for Atticus to collect the individual’s personal information.
Atticus generally does not collect sensitive personal information about an individual, such as:·       
the individual’s religious background and religious views;·       
ethnicity;·       
political backgrounds or political views;·       
medical conditions; and·       
any other information which may generally be considered by the individual to be sensitive personal information.
However, Atticus may collect sensitive personal information if it is necessary for Atticus to deal with the individual and the individual has consented to Atticus doing so.
Atticus may also collect personal information about an individual from a third party who may be the individual’s agent when it is reasonably necessary to do so. Atticus will take reasonable steps to inform the individual that Atticus has the individual’s personal information unless it is obvious to the individual from the circumstances that Atticus holds such information.
Notification of Collection of Personal Information At or before the time, or, if that is not practicable, as soon as practicable after, Atticus collects personal information about an individual, Atticus will notify the individual of the following matters unless it is obvious from the circumstances:·       
the contact details of Atticus;·       
the circumstances and purpose of the collection if the individual is not aware that Atticus has the personal information;·       
the entities that the information is disclosed, when applicable;·       
any overseas recipients of that information, when applicable;·      
how the individual may access the personal information held by Atticus; and·       
how the individual may make a complaint in relation to the collection of the information by Atticus.


Use or Disclosure of Personal Information
Atticus generally holds personal information about an individual that was collected for a particular purpose (Primary Purpose) and will not use or disclose the information for another purpose unless:·       
the individual has consented to the use or disclosure of the information; or·       
a circumstance listed in paragraph 5.2 applies in relation to the use or disclosure of the information.
Atticus may use the personal information for a purpose other than the Primary Purpose if:·       
the individual reasonably expects Atticus to use or disclose the information for a purpose other than a Primary Purpose;·       
the use or disclosure of the information is required, or authorised by, or under anAustralian law, or an order of a court or tribunal;·       
a permitted general situation exists in relation to the use or disclosure of the information by Atticus;·       
Atticus reasonably belies that the use or disclosure of the information is reasonably necessary for one or more enforcement-related activities conducted by, or on behalf of, an enforcement body; or·       
the individual has consented to Atticus doing so.Atticus may use or disclose personal information for a purpose including, but not limited to:·       
delivery products or providing services as requested;·       
assessing the suitability of the applicant;·       
communicating with the individual;·       
assisting with Atticus’s operation and management decisions;·       
improving and enhancing Atticus’s products and services, including analysing customer feedback and consumer expectations;·       
monitor Atticus’s staff performance and service standards; and·       
complying with the Legislation and any other relevant Australian law. 
Atticus may disclose personal information to other Atticus-related entities (together Atticus Entities) and 
external parties in certain circumstances, including but not limited to:·       
Atticus’s suppliers and service providers who provide systems, maintenances, and products which enable and support Poly’s business activities;·       
Atticus’s financiers, lenders and insurers;·       
business partners for the purpose of relevant regulatory approvals;·       
Australian regulatory bodies or other government agencies as agreed to or required byAustralian law; and·       
any other relevant parties which Atticus may be required under the Legislation or otherAustralian law to provide the information.
Whenever paragraph 5.4 is applicable, Atticus will do so diligently for the protection of the personal information and will require the recipients of the personal information to acknowledge and agree to Atticus’s Privacy Policy, with further restrictions imposed on the recipients for the use and storage of the personal information disclosed by Atticus. Atticus will not sell personal information to external entities for profit. 


Direct Marketing
Atticus may use or disclose personal information (other than sensitive personal information) about an individual for the purpose of direct marketing if:·       
Atticus collected the information from the individual;·       
the individual would reasonably expect Atticus to use or disclose the information for that purpose;·       
Atticus provides simple options to the individual who may easily request not to receive direct marketing communications from Atticus; and·       
the individual has made such a request from Atticus.
Atticus may use or disclose sensitive personal information about an individual for the purpose of direct marketing if the individual has consented to the use or disclosure of the information for that purpose. 
If Atticus uses or discloses personal information about an individual:·        
for the purpose of direct marketing by Atticus;
for the purpose of facilitating direct marketing by other entities;
the individual may:·       
if paragraph 6.3 (a) applies — request not to receive direct marketing communications from Atticus;
and· if paragraph 6.3(b) applies — request Atticus not to use or disclose the information for the purpose referred to in paragraph 6.3(b); 
and· request Atticus to provide its source of the information.
If an individual makes a request under paragraph 6.4, Atticus will give effect to the request within a reasonable period after the request is made. Cross-border Disclosure of Personal Information Atticus may disclose personal information to parties outside of Australia as Atticus is a foreign-owned entity and has affiliates globally. Atticus will limit the disclosure of personal information under circumstances that are necessary, and will do so in accordance with the Australian Privacy Principles. 
Atticus will also take necessary reasonable steps to ensure that the recipients of personal information have an appropriate data management mechanism in place.


Security of Personal Information
Atticus will take reasonable steps in the circumstances to protect the personal information:·       
from misuse, interference and loss; and·       
from unauthorised access, modification or disclosure.
If:·       
Atticus holds personal information about an individual;·       
Atticus no longer needs the information for any purpose for which the information may be used or disclosed by Atticus; and·       
Atticus is not required by or under the Legislation or an Australian law, or an order of a court or tribunal, to retain the information, Atticus will take such steps as are reasonable in the circumstances to destroy the information or to ensure that the information is de-identified.


Access to Personal Information
An individual can make a request in writing to Atticus to access that individual’s personal information which maybe held by Atticus, provided the individual provides Atticus with proof, to Atticus’s satisfaction, of the identity of the individual making the request. Atticus may impose a charge for processing such request if it is necessary for Atticus to expend time and resources to answer the request – otherwise, making the request is free of charge.If the request to access personal information is not permitted by the Legislation or an Australian law, Atticus will deny the request and provide the individual with a reason for such decision. 

Correction of Personal Information
An individual can make a request in writing to Atticus to change the personal information held by Atticus about that individual that the individual believes to be inaccurate, out-of-date, incomplete, irrelevant or misleading. If Atticus is of the view that the personal information should not be changed, Atticus may refuse to do so by providing the individual with reasons for such a decision.If the individual disagrees with Atticus’s view in paragraph 10.2, the individual can request a statement to that effect to be linked to the individual’s personal information and Atticus must make keep that statement so linked.

Complaints 
Atticus has an internal complaints management system to deal with complaints in relation to the handling of any individual’s personal information. Changes in the Future Atticus reserves the right to change this Privacy Policy at any time and will notify the changes by posting an updated version of this Privacy Policy on its website.

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