RONSTAN INTERNATIONAL PTY LTD

PRIVACY POLICY

Respecting your privacy

Ronstan International Pty Ltd, as a member of the Ronstan Group (Ronstan Properties (Australia) Pty Ltd, Ronstan International Inc (USA), Frederiksen Boat Fittings ApS (Denmark) and Ronstan (UK) Ltd) ("the Group") is committed to the protection of your personal information.

The systems in place in our business (and in that of our business partners including our Group members) ensure that we comply with the National Privacy Principles, the Privacy Act 1988 and all other applicable privacy laws when we collect, store, use or disclose your personal information.

Our staff are trained to respect your privacy in accordance with our privacy standards. They are committed to responsible handling of your personal information.

About our Privacy Policy

This Policy outlines how we protect your privacy. It applies to all your dealings with us, including when these are by post or facsimile, on our web site, or by some other means. This Policy also describes the sorts of personal information we generally collect, hold, maintain, use and disclose from and about you and how we do these things.

When you apply for or use our products or services, a copy of this Policy will be available to you. Every time you authorise us to collect, maintain, use and disclose your personal information, we do these things in accordance with this Policy and any privacy statement set out in the terms and conditions of those products and services.

Any privacy information we supply you, including in this Policy may be subject to change from time to time. We encourage you to check our web site at www.ronstan.com or to contact our office to keep up to date with these changes. We will not separately notify you of them.

The type of personal information we collect

The type of personal information we collect and maintain about you depends on the particular product or service for which we require the information, including those relating to your marine, architectural or industrial requirements and your freighting and insurance requirements (if relevant).

The personal information we always collect from you includes your name and generally includes:

your postal or e-mail address;
your contact telephone and fax numbers; and
your financial details (where relevant).

In certain circumstances, including if you are applying for employment with us, we also collect from you:

details of your employer's name and of your place of work (if applicable);
other information relating to your identity; and
any information we consider necessary for the above purposes.

In certain circumstances (for example, in relation to your employment application), the personal information we collect may contain sensitive information about you such as:

your membership of a professional or trade association or trade union, or
your health.

We will not collect sensitive information without your express consent or when a legal exception applies, such as when its collection is necessary to prevent a serious and imminent threat to your life or health.

How we collect your personal information

We collect most of your personal information from you personally. This may be by:

asking you to fill out an administrative or application form;
when you write to us;
when you give us your personal information over the telephone or on our or another Group member's web site;
when you deal with us directly;
when you deal with our representatives; or
when you deal through your representative.

Where lawful and practicable, you may deal with us anonymously. It is not necessary, for example, for you to give us personal information in order to make an enquiry about our products.

There may be times when we need to obtain personal information about you from someone else such as:

a credit reporting agency;
a member of your family (for example as a contact or a referee);
organisations that provide, manage or administer our products or services or assist us to do these things (for example, our suppliers, contractors and service providers, and consultants);
our insurers and underwriters;
your and our agents and representatives;
your employer (for example to verify your current or previous employment in relation to your employment application);
your doctor or other health professionals (for example, in relation to a disability which you have disclosed to us in an employment application); or
individuals and organisations from whom we buy our products or with whom we conduct our business.

This Policy applies to all of these circumstances.

Why you need to provide personal information to us

If you do not provide us with the personal information we require, we may not be able to:

process your application for employment or your request for our products or services;
administer our products and services;
keep you updated about our products and services; or
tell you about other Group products and services that may be relevant to you.

How we use and disclose your personal information

Generally, we use and disclose your personal information for purposes related or ancillary to the main reason we collect it, such as:

providing you with a product or service;
servicing our relationship;
identifying you; and
providing you (except when you tell us not to by contacting our Privacy Officer at the address below) with information about other products and services which might serve your personal or business needs.

Depending on the products and services we are providing you, we will usually disclose your personal information to one or more of the following persons who may use it only for the purposes for which we have provided it:

third parties who assist us to provide you with our products and services (including mail houses, printers of our invoices and originators of our freight documentation);
other Group entities;
our or your legal and other advisers;
organisations involved in developing and maintaining our business infrastructure including our computer, administrative and business systems;
our marketing consultants;
financial institutions (including your bank);
debt collection agencies; and
persons to whom we are required or authorised by law to disclose information where the disclosure is required in the interests of public health or safety, the protection of public revenue or the prevention or detection of crime. These include government and regulatory bodies such as the Australian Tax Office and credit reporting agencies.

Except where we are required by law to do so (for example to a Court or to the Australian Tax Office) or the disclosure is in the public interest (such as the investigation of a crime) or in our own interest (as in a court action to which we are a party), we only disclose your personal information to others with your express or implied consent.

We generally disclose your personal information to our own and the Group's product and service developers and marketers, so that you can be kept informed of our range of products and services. You can advise us that you do not wish to receive this marketing material at any time and we will stop sending it to you. Otherwise, we rely on your express or implied consent, or the consent of your representative.

Because our Group operates throughout the world, we may need to transfer personal information off-shore to one or more Group members as part of our normal business practice, or in relation to a sale or restructuring of a Group business. These organisations will also use service providers and contractors to process your information. We impose strict security and confidentiality requirements on how these persons deal with your personal information. Group members will use and disclose your personal information only with your express or implied consent.

We will not sell, rent or trade your personal information for marketing purposes without your express consent.

Using Government Identifiers

When we collect your tax file number, or any other Commonwealth agency identifier, we use and disclose it only as required by law and not as a means of identifying your application for any product or service.

Security

The security of your personal information is important to us and we protect it from misuse, loss, and unauthorised access, modification or disclosure (regardless of whether we store it in electronic or paper form). The steps we take to do this include:

protecting our premises and systems (including our websites, computer systems and networks), from unauthorised entry;
maintaining secure storage of personal information paper documents; and
training our staff to apply and maintain our security standards and privacy policies.

Where we disclose your personal information to other people (such as our contractors and service providers), we seek to ensure that these individuals and entities keep it secure and deal with it in accordance with the National Privacy Principles or their equivalent.

Access

You can ask us to tell you what sort of personal information about you we hold, for what purposes we are storing it and how we collect, use and disclose it. You can make your request on our website or by writing to our Privacy Officer at the address below.

We will take all reasonable steps to answer your questions unless we are exempted by law from doing so, for reasons including your access would unreasonably impact on the privacy of others, or prejudice our negotiations with you in a dispute.

We will usually provide you with the information in a written form such as a photocopy or print out unless a verbal response or giving you physical access to a relevant file may be more appropriate.

We will make every reasonable attempt to respond to your request for access (where we are able or authorised to do so) within 14 days, depending on the complexity of the information you are seeking, how it is held and how you wish us (and we are able) to communicate it to you.

A charge reflecting our reasonable cost of supplying the personal information may apply to access to the personal information that you seek. We will let you know if this is the case and the time payment is required. We will not charge you for merely making an enquiry about our provision of the information.

If we are unable to meet your request for access, we will let you know why.

Accuracy

We aim to ensure that your personal information which we collect, use, disclose and store is accurate, complete and up to date. If it is not, you must promptly write to us and tell us.

We will update or add to your personal information within a reasonable time of your requesting us to do this, unless we disagree that this needs to be done, in which case, at your request, we will attach to your personal information record, a statement noting your view that it is not accurate, complete or up to date.

How long we keep your information

When we no longer need to hold your personal information for any purpose (including but not limited to providing the products and services you want or to satisfy legal obligations), we will take all reasonable steps to destroy it by secure means or permanently de-identify it, unless we have a legal obligation to retain it longer.

If you have any further questions relating to our retention, destruction or de-identification of your personal information please do not hesitate to write to us at the below address.

More Information

We are a member of the Group which includes the entities listed above. Members of the Group may change from time to time. Reference to "we/us" in this brochure means each member of the Group.

If you want to know more about our privacy policy or practices, or have any concerns or complaints about how we apply them, please contact our Privacy Officer by writing to him at the postal address or by fax as set out below.

We will respond to your enquiry or complaint as soon as is possible. We will try to resolve your complaint or address any issue (including correcting any error we have made) within 14 days of your contacting us about it.

It will assist us to help you when you contact the Privacy Officer as below, if you specify the matter/s you wish to raise:

Privacy Officer - Laine McCooke
Ronstan International Ltd Limited
PO Box 81
SANDRINGHAM, VIC 3191
AUSTRALIA
Facsimile: +61 (0)3 8599 0099

If you are dissatisfied with our response to your questions or your complaint, you have the right to discuss the matter or lodge a complaint about this with the Federal Privacy Commissioner.