Price Holyoake (AU) Pty Ltd – Privacy Policy

Privacy policy

We are bound by the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles (APPs). The APPs govern the away in which we collect, use, disclose, store, secure and dispose of your personal information and this policy explains how we handle your personal information.

“We”, “us” and “our” means Price Holyoake (AU) Pty Ltd of 95 Redwood Drive, Dingley, VIC, 3172 Australia.

You consent to us collecting, holding, using, and disclosing your personal information in accordance with this policy.

A copy of the Australian Privacy Principles may be obtained from the website of The Office of the Australian Information Commissioner at https://www.oaic.gov.au/.

What is personal information?

Personal Information is information or an opinion that identifies an individual. Examples of Personal Information we collect includes names, addresses, email addresses, phone and facsimile numbers.

What personal information do we collect and hold?

We collect information about you and your interactions with us, for example, when you purchase or use any of our products or services, call us, or visit our website. The information we collect from you may include your identity and contact details, your history of purchases and use of our products and services and details of enquiries or complaints you make.

We may collect information about how you access, use, and interact with the website. We do this by using a range of tools such as Google Analytics. We also use Customer Relationship Management (“CRM”) software, such as Salesforce and Einstein Activity Capture. This information may include:

  1. the location from which you have come to the site and the pages you have visited; and
  2. technical data, which may include IP address, the types of devices you are using to access the website, device attributes, browser type, language and operating system; and
  3. user content, such as information related to customer satisfaction surveys, customer requests or queries, and other content you may create, such as posts on our social media pages, along with any related name, username, alias, or other account information; and
  4. relationship history, which may include details of your contact with us, as well as order history.

We use cookies on the website. A cookie is a small text file that the website may place on your device to store information. We may use persistent cookies (which remain on your computer even after you close your browser) to store information that may speed up your use of our website for any of your future visits to the website. We may also use session cookies (which no longer remain after you end your browsing session) to help manage the display and presentation of information on the website. You may refuse to use cookies by selecting the appropriate settings on your browser. However, please note that if you do this, you may not be able to use the full functionality of the website.

Sensitive Information

Sensitive information is defined in the Privacy Act to include information or opinion about such things as an individual’s racial or ethnic origin, political opinions, membership of a political association, religious or philosophical beliefs, membership of a trade union or other professional body, criminal record, or health information.

Sensitive information will be used by us only:

  1. For the primary purpose for which it was obtained
  2. For a secondary purpose that is directly related to the primary purpose
  3. With your consent; or where required or authorised by law.

Why do we collect, hold and use your personal information?

We collect, hold and use your personal information so that we can:

  1. provide you with products and services, and manage our relationship with you;
  2. contact you, for example, to respond to your queries or complaints, or if we need to tell you something important;
  3. comply with our legal obligations and assist government and law enforcement agencies or regulators;
  4. keep our services safe from misuse and illegal activity; or
  5. identify and tell you about other products or services that we think may be of interest to you.

If you do not provide us with your personal information, we may not be able to provide you with our services, communicate with you, or respond to your enquiries.

How do we collect your personal information?

We will collect your personal information directly from you whenever you interact with us.

When you purchase or use our products or services, your personal information may also be processed by third parties, who work on our behalf to provide you with our services and improve upon them. This includes, but is not limited to, product registrations, providing website hosting, data analysis, information technology and related infrastructure provision, advertising, and analytic services.

How do we store and hold personal information?

We store most information about you in computer systems and databases operated by either us or our external service providers. Some information about you is recorded in paper files that we store securely.

We implement and maintain processes and security measures to reasonably protect personal information which we hold from misuse, interference or loss, and from unauthorised access, modification or disclosure.

When your personal information is no longer needed for the purpose for which it was obtained, we will take reasonable steps to destroy or permanently de-identify your personal information. However, most of the personal information is or will be stored in client files which will be kept by us for a minimum of 7 years.

Who do we disclose your personal information to, and why?

We may transfer or disclose your personal information to our related companies.

We may disclose personal information to external service providers so that they may perform services for us or on our behalf.

We may also disclose your personal information to others outside our group of companies where:

  1. we are required or authorised by law to do so;
  2. you may have expressly consented to the disclosure or the consent may be reasonably inferred from the circumstances; or
  3. we are otherwise permitted to disclose the information under the Privacy Act.

If the ownership or control of all or part of our business changes, we may transfer your personal information to the new owner.

Do we use your personal information for marketing?

We will use your personal information to offer you products and services we believe may interest you, but we will not do so if you tell us not to. These products and services may be offered by us, our related companies, our other business partners or our service providers.

Where you receive electronic marketing communications from us, you may opt out of receiving further marketing communications by following the opt-out instructions provided in the communication.

Access to and correction of your personal information

You may access or request correction of the personal information that we hold about you by contacting us. Our contact details are set out below. There are some circumstances in which we are not required to give you access to your personal information.

There is no charge for requesting access to your personal information, but we may require you to meet our reasonable costs in providing you with access (such as photocopying costs or costs for time spent on collating large amounts of material).

We will respond to your requests to access or correct personal information in a reasonable time and will take all reasonable steps to ensure that the personal information we hold about you remains accurate, up to date, complete, relevant and not misleading.

In order to protect your personal information we may require identification from you before releasing the requested information.

Maintaining the Quality of your Personal Information

It is an important to us that your personal information is up to date. We will take reasonable steps to make sure that your personal information is accurate, complete and up to date. If you find that the information we have is not up to date or is inaccurate, please advise us as soon as practicable so we can update our records and ensure we can continue to provide quality services to you.

Complaints

If you have a complaint about the way in which we have handled any privacy issue, including your request for access or correction of your personal information, you should contact us. Our contact details are set out below.

We will consider your complaint and determine whether it requires further investigation. We will notify you of the outcome of this investigation and any subsequent internal investigation.

If you remain unsatisfied with the way in which we have handled a privacy issue, you may approach an independent advisor or contact the Office of the Australian Information Commissioner (OAIC) (www.oaic.gov.au) for guidance on alternative courses of action which may be available.

Contact details

If you have any questions, comments, requests or concerns, please contact us at:
Email: [email protected]
Telephone: +61 2 9620-9555
Mail: 12 Butterfield Street, Blacktown, NSW 2147, Australia

Changes to this policy

From time to time, we may change our policy on how we handle personal information or the types of personal information which we hold. Any changes to our policy will be published on our website.

You may obtain a copy of our current policy from our website or by contacting us at the contact details above.

Price Holyoake New Zealand Privacy Policy

At Price Holyoake we understand the importance of protecting your personal information and have created this Privacy
Policy to outline how we collect, handle, and use personal information obtained through the use of our website
and/or any products and services offered by Price Holyoake (our “Services”). We use your personal information to
provide and improve upon our Services, to enable you to navigate our site and use our Services, and to respond to
your inquiries. By using our website and/or our Services, you agree to the collection and use of your personal
information in accordance with this Privacy Policy.

The security of all personal information collected is very important to Price Holyoake. Price Holyoake values your
trust and will work to protect the security and privacy of any personal information that you provide to us. To help
you better understand Price Holyoake’s Privacy Policy, please review the questions and answers that follow below.
Should you have any questions or concerns with this Privacy Policy, please contact our Privacy Officer, Tony Horton,
by email at [email protected]; telephone +64 9 274 4144; or
by mail at PO Box 58548, Botany, Manukau 2163, New Zealand.

Contents:

  1. What is considered personal information?
  2. What information is collected by Price Holyoake?
  3. For what Purpose is personal information collected and processed by Price Holyoake?
  4. Does Price Holyoake share a user’s personal information with other companies?
  5. What are cookies and how does Price Holyoake use them?
  6. Where is a user’s personal information stored?
  7. What kinds of security procedures are in place to protect against the loss, misuse, or alteration of my information?
  8. May I review or exercise other rights regarding the personal information Price Holyoake has about me?
  9. How long does Price Holyoake keep my personal information?
  10. Will Price Holyoake’s Privacy Policy change?
  11. What about links to other sites?
  12. Does Price Holyoake collect personal information from children?
  13. How do I accept this Privacy Policy?
  14. Where can I get more information about the Price Holyoake Privacy Policy?
  15. Who may I contact if I have any questions or concerns about my personal information or this Privacy Policy?

What is considered personal information?

Personal information is any information that relates to an identified or identifiable individual, including as such
term is defined in the applicable law.

What information is collected by Price Holyoake?

We collect personal information through a variety of ways: your use of our Services(for example, when a user visits
the Price Holyoake website), when we provide our Services, when users download content, through the use of cookies,
interactions with our customer support, when you sign up for marketing or communications, make inquiries regarding
our Services, make a purchase, or, in certain instances, we may acquire personal information (including personal,
demographic, behavioral and indirect information) from third parties with whom we have a business relationship.

Depending on how you use or access our Services, we may collect the following personal information from you:

  • Contact Information: such as your name, email address, phone number, address, and country of
    residence;
  • Account Information: such as login credentials (related to your account), username, password,
    account profile information, and browsing history;
  • Transaction Information: such as purchase and order information, payment details, including
    debit or credit card details, bank account details, and billing address;
  • Device Information: technical information associated with the device you use to access our
    website and/or Services, such as the device type and model, system language, browser type, geographical location
    via IP address, HubSpot Analytics or Google Analytics, operating system, and technical identifiers that identify
    the device you use, such as IP address, IDFA (identifier for advertisers), and other unique identifiers;
  • Products Information: usage information such as physical and environmental surroundings of the
    location where you use any of our connected products;
  • User Content: such as information related to customer satisfaction surveys, customer requests or
    queries, and other content you may create, such as posts on our social media pages, along with any related name,
    username, alias, or other account information;
  • Physical Location: your physical location that can be derived from your IP address and your
    interactions with our emails, or your manually selected location, zip code or postal code, depending on your
    preferences;
  • Professional Characteristics: such as your trade, industry, employment status, profession, work
    or trade skill levels, employer information, and experience;
  • Demographic Characteristics: country of residence, affiliation, industry, profession, trade, and
    gender;
  • Usage Information: such as information on your browsing behavior, your purchasing patterns and
    trends, and engagement (such as how long you visit a page, what links you click on, what pages you visit, how
    many times you visit a page and how long it takes for you to come back);
  • Preferences: your preferences, based on viewed and recommended products, your preferred
    language, and your preferences regarding marketing communications and use of cookies;
  • Social Media Information: your name, email address, photo, and any other information that may be
    or you make accessible to us when you connect your social media account to your user account;
  • Relationship History: details of your contact with us, as well as order history;
  • Other Personal Information that you provide us.

To improve the quality of our Services and to provide you with a better user experience, we may combine the
information you submit with information provided by third parties. In certain cases, we also receive personal
information about you from other sources such as publicly available information or from publicly available
databases.

Google Analytics

Our website (“Site”) uses Google Analytics, a web analytics service provided by Google, Inc (“Google”). Google uses
cookies to help us analyze how visitors use the Site. The information generated by the cookie about your use of the
Site is generally transmitted to and stored on a Google server. Google uses this information for evaluating your use
of the Site, compiling reports on the Site activity, and providing us with other analytic services relating to our
Site and internet use. Google will not associate your IP address with any other data held by Google.

You may manage and opt out of Google’s use of cookies by visiting Google’s Ad settings and selecting the desired
settings in your browser. However, please note that by doing so, you may not have the full functionality of our
Site. Alternatively, you can prevent Google’s collection and use of data by downloading and installing the browser
plugin available at: http://tools.google.com/dlpage/gaoptout?hl=en and/or
opt out by visiting www.networkadvertising.org/choices/ or www.youronlinechoices.com.

For more information on how Google uses data obtained through the Site click here.

Use of Salesforce CRM and Einstein Activity Capture

Price Holyoake utilizes Salesforce Customer Relationship Management (“CRM”) software, including Einstein Activity
Capture, to improve the quality and accuracy of our customer relationship management. This technology allows us to
streamline interactions with our customers, ensuring that we provide efficient and personalized service.

  1. Data Collection and Use

    2. Salesforce CRM and Einstein Activity Capture automatically collect and log specific details of our business
    interactions. This includes information such as email addresses of correspondents, dates and times of interactions,
    calendar event details, and the content of emails and calls related to customer relationship management. We use this
    information to maintain up-to-date records of communications and to better understand our customers’ needs.

  2. Purpose of Data Processing

    3. The data collected through Einstein Activity Capture is used to enhance our ability to respond promptly and
    accurately to customer inquiries, maintain consistent communication, and ensure that our customer service remains
    efficient. By automatically associating business interactions with customer profiles, we can provide a more tailored
    experience to each customer.

  3. Data Storage and Retention

    4. The data captured by Salesforce and Einstein Activity Capture is securely stored on Salesforce servers, adhering to
    their privacy and security standards. Information is retained only as long as necessary for customer relationship
    purposes, after which it is either archived or deleted according to our data retention policies.

  4. Third-Party Data Sharing

    5. Any data collected through Salesforce CRM is used exclusively for internal purposes and may be shared with partners
    only as necessary to fulfill our business operations. Under no circumstances is this information sold or shared with
    third parties beyond what is required for our customer relationship functions.

  5. User Rights

    6. Individuals have the right to access, correct, or delete their personal data in our CRM system. For any requests
    regarding your personal data, please contact our Privacy Officer, Tony Horton, by email at
    [email protected]; telephone +64 9 274 4144; or by mail at PO Box 58548, Botany, Manukau 2163, New Zealand.

We are committed to respecting your privacy and managing your data responsibly. This section of our privacy policy
may be updated as necessary to reflect changes in our use of technology and our data management practices.

For what purposes is Personal Information collected and used by Price Holyoake?

We use your personal information to the extent necessary to achieve the following purposes, which are further
described below:

  • Provision of Services
  • Process Orders and Returns
  • Provide Customer Service
  • Marketing Communications and Tailored Content
  • Improve our Products and Services
  • Keep Our Services Safe from Misuse and Illegal Activity
  • Comply with Legal Obligations

Provision of Services

In order to provide and improve our Services, we use your personal information to provide the Services to you in a
personalized and efficient way, including: 1) opening and arranging access to your registered account, and updating
and maintaining the information in your account; 2) utilizing the functionality of any smart devices, including
geolocation-based requests (such as physical and environmental surroundings of the location where the products are
being used); and 3) sending you administrative information related to your account, such as changes in our terms,
conditions, and policies.

We will engage in these activities for the purposes of managing our contractual relationship with you, and/or to take
steps (at your request) prior to entering into a contract.

Process Orders and Returns

We utilize your personal information for processing your orders and returns, including warranty and product
registration, related payments, exchanges or refund requests.

We will engage in these activities to manage our contractual relationship with you, and/or to take steps at your
request prior to entering into a contract.

Provide Customer Service

We process your personal information to follow-up on your customer service requests, provide services, and maintain
our relationships with our clients, such as providing assistance and handling your inquiries or complaints.

We engage in these activities to manage our contractual relationship with you.

Send You Marketing Communications and Tailor Our Content for You

We use your Personal Information to identify your preferences and tailor our content and recommendations for you,
send you personalized advertising and marketing related communications about our Services and new products, and
provide updates or news about our company.

If we have an existing or prior relationship, we may send you communications about products and Services that are
similar to products and Services you requested information about or purchased before. You will always be able to opt
out from these marketing communications.

We may obtain your consent in certain instances, including when legally required to do so, to send you marketing
emails using the information described above. We will use your personal information to ensure that the marketing
content is tailored to your interests. If you no longer wish to receive these marketing communications, you are free
to unsubscribe at any time by selecting the “Unsubscribe and Manage Preferences” option at the bottom of any of our
marketing communications, by emailing us at [email protected]; by calling us at +64 9 274 4144; or by mail
at PO Box 58548, Botany, Manukau 2163, New Zealand.

Where applicable, we have a legitimate business interest in sending you marketing communications and organizing and
communicating promotions.

Improve Our Products and Services

We use your personal information to improve the efficiency of our Services, to develop new products and Services, to
identify usage trends, and to determine the effectiveness of our marketing campaigns. We may also use your personal
information for quality and training purposes.

Where applicable, if we process your personal information to improve our products and Services, we do this to
continuously improve our products and Services to ensure that you have the best experience possible. Where legally
required, we will obtain your consent for such processing activities.

Keep Our Services Safe From Misuse and Illegal Activity

We may use your personal information to keep our Services safe from misuse and illegal activity. This includes
conducting security audits, verifying that our internal processes function as intended and are compliant with legal,
regulatory or contractual requirements, monitoring for and prevention of fraud, and verifying that your use of our
Services is compliant with our terms and conditions of purchase and is in no other way inappropriate or illegal.

Where this is the case, we process your Personal Information as necessary for the fulfilment of our statutory duties
and obligations and, where applicable for the preservation of our legitimate interests or the legitimate interests
of our partners or a third parties to prevent misuse and illegal activity, such as fraudulent transactions.

Comply With Legal Obligations

We use your personal information as necessary to comply with our legal obligations. This may include instances where
we receive a reasonable request from law enforcement agents or representatives, judicial authorities, governmental
agencies or bodies, including competent data protection authorities. For example, we may be required to collect and
transfer your personal information to our financial institution or payment service provider to allow your financial
institution and the payment service provider to comply with their legal obligations, such as obligations under
applicable anti-money laundering and counter-terrorism financing legislation.

Similarly, we may share your personal information, after considering your privacy interests and other factors, with
law enforcement or judicial authorities as evidence or if there are justified suspicions of any unlawful act or
crime committed by you through our Services or other interactions with us. Such action may be necessary to conform
to legal requirements or comply with legal processes, including laws outside of your country of residence; to
enforce or apply our terms of use and other agreements, including for billing and collections purposes; to protect
our property rights and safety or property rights and safety of a third party, our affiliated companies, or the
public in general; or to stop any activity that we consider illegal, unethical or legally actionable. When we
process or share your personal information for these purposes, we do this to comply with our legal obligations.

Does Price Holyoake share a user’s personal information with other companies?

When you purchase or use our products or Services, your personal information may also be processed by third parties,
who work on our behalf to provide you with our Services and to improve them. This includes, but is not limited to,
product registrations, providing website hosting, data analysis, information technology and related infrastructure
provision, advertising, and analytic services.

Price Holyoake may from time to time share personal information with individuals or other companies, as follows:

  • For the purpose of sales and providing our Services through manufacturing and distribution representatives.
  • For other parties to process personal information on our behalf. We may provide personal information to trusted
    persons or businesses, such as our subsidiaries and affiliates, contractors, service providers, and other third
    parties we use to support our website and the provision of our Services.
  • When we have a good-faith belief that access, use, preservation, or disclosure of your personal information is
    reasonably necessary: (a) to satisfy any applicable law, regulation, legal process, or enforceable government
    request; (b) to enforce applicable terms of service, including investigation of potential violations thereof;
    (c) to detect, prevent, or otherwise address fraud, security, or technical issues; or (d) as required by law, to
    protect against harm to the rights, property, or safety of Price Holyoake software, its users, or the public.
  • We may share with third parties certain pieces of aggregated, non-personal information, such as the number of
    users who viewed a certain page on our website, for example, or how many users clicked on a particular
    advertisement.

We will only engage third parties for the processing of your personal information to the extent this is necessary to
achieve the purposes as set out above. Our third-party processors are only allowed to process your personal
information on our behalf and upon our written instructions. We select our processors with due care and
contractually oblige them to observe the safety and integrity of your personal information.

What are cookies and how does Price Holyoake use them?

When you visit Price Holyoake’s website, a small file called a “cookie” is placed on your computer automatically to
collect information. A cookie is a small text file containing a unique identification number that is transferred
from a website to the hard drive of your computer so that the site administrator may identify your computer and
passively track its activities on the website. This unique number identifies your web browser to our computer system
whenever you visit Price Holyoake’s website.

Cookies allow Price Holyoake to automatically remember your web browser when you visit our website. To help serve you
better, Price Holyoake generally uses cookies to measure statistics such as audience size and traffic patterns.

You may adjust your web browser preferences to alert you when a cookie is sent or received or to refuse certain
non-essential cookies altogether. Keep in mind that certain sites and services will not function properly if you set
your browser to refuse all cookies.

Where is a user’s Personal Information stored?

Your information, including personal Information, is processed at Price Holyoake’s operating offices and in any other
places where the parties involved in the processing are located. This means that this information may be transferred
to and maintained on computers or servers located outside of your province, state, country, or other governmental
jurisdiction where the data protection laws may be different than those from your jurisdiction but will be subject
to safeguards comparable to those in your home jurisdiction.

Your consent to this Privacy Policy followed by your submission of such information and/or your use of this website
and/or our Services represents your agreement to that transfer.

What kinds of security procedures are in place to protect against the loss, misuse, or alteration of your
information?

We take reasonable administrative, physical, and electronic measures to safeguard your personal information from
unauthorized access or inappropriate use by third parties. Please be aware, however, that no method of transmitting
and storing information over the internet is completely secure. Accordingly, we cannot guarantee the absolute
security of any information.

You are ultimately responsible for the security of your personal computer. Please take care when using and storing
information on it. Price Holyoake recommends that you do not divulge your passwords to anyone.

May I review or exercise other rights regarding the personal information Price Holyoake has about
me?

Price Holyoake provides its users the ability to access, update, and correct their personal information in their user
profiles or that Price Holyoake otherwise has on record at any point provided that Price Holyoake can authenticate
the user’s identity. To review your personal information, or to make another request, such as accessing, objecting
to processing, changing your consent options, editing, restricting, deleting personal information, or asking us
about our privacy practices, you can contact us by emailing [email protected]; telephone at +64 9 274 4144;
or by mail at PO Box 58548, Botany, Manukau 2163, New Zealand. We will respond to your request within 20 working
days from the date that your request was received. In limited circumstances we may extend this timeframe, but we
must tell you why we would require an extension and when we will provide you the information requested.

You may also lodge a complaint with the Privacy Commissioner if you consider that Price Holyoake’s processing of
personal information infringes applicable law.

How long does Price Holyoake keep my personal information?

Personal information is kept by Price Holyoake until it is no longer required or a request is made by the individual
to have their personal information removed. Once personal information about a customer is no longer required by
Price Holyoake to fulfill the purposes for which it was collected, it is shredded or disposed of in a manner that
safeguards its confidentiality.

Will Price Holyoake’s Privacy Policy change?

We may make changes to this Privacy Policy from time to time, so please review it periodically. We will update the
effective date of the Privacy Policy at the time a change is made. We will notify you of any changes by posting the
changes on our website or our Services or notifying you by email. The revised Privacy Policy will become effective
when we notify you of the revised Privacy Policy. Your use of the Services following these changes means that you
accept the revised Privacy Policy.

What about links to other sites?

This policy applies only to information collected within the Price Holyoake website or through our Services that link
to this policy. Although the Price Holyoake websites may contain links to other websites, Price is not responsible
for privacy policies that these other websites are governed by. It is recommended that when visiting any other
website, users thoroughly review the privacy policy governing such websites before submitting any personal
information.

Does Price Holyoake collect personal information from children?

Our Site is not directed to children under 16 and we do not knowingly collect personal information from children
under 16. If we learn that we have collected personal information of a child under 16 without verification of
parental consent, we will take steps to delete such information from our files as soon as possible. The
Holyoake.com, HolyoakebyPrice.nz, HolyoakebyPrice.au and, PriceIndustries.com websites are not intended for use by
children. If you are under 16 years of age, you should not use our Services nor provide any information to Price
Holyoake in any manner, including the use of this website.

How do I accept this Privacy Policy?

By using the Holyoake.com, HolyoakebyPrice.nz, HolyoakebyPrice.au or PriceIndustries.com websites or Services, you
signify your acceptance of this Privacy Policy. If you do not agree or are not comfortable with any policy described
in this Privacy Policy, you should immediately discontinue use of the Price Holyoake website and our Services.

Where can I get more information about the Price Holyoake Privacy Policy?

For additional information related to this Privacy Policy, you can contact the Privacy Officer by
emailing [email protected]; telephone at +64 9 274 4144; or by mail at PO Box 58548, Botany, Manukau 2163,
New Zealand.

Who may I contact if I have any questions or concerns about my personal information or this Privacy Policy?

You may address all communications to our Privacy Officer by emailing the Privacy Officer
at [email protected]; telephone at +64 9 274 4144; or by mail at PO Box 58548, Botany, Manukau 2163, New
Zealand. Please include your name, phone number or email in all communications and state clearly the nature of your
request.

Last Updated (Effective Date): 17th of February, 2025