Privacy Statement

1. General Data Protection Regulation ("GDPR")

Upon the implementation of the GDPR on 25 May 2018, Cunneen Premier Locksmiths has updated the way it uses and collects personal data from residents in the EU. This involves identifying Cunneen Premier Locksmiths' data protection officer ("Privacy Officer"), how clients can contact the Privacy Officer and identifying the process of transferring client's personal information. Cookies notices on our website ensure clients have adequate protection in providing consent for us to hold their personal data.

2. Types of Personal Information That Is Collected, Used, Processed & Held

Cunneen Premier Locksmiths collects personal information for a variety of reasons. This personal information is collected in the normal course of business and relates to Goods and/or Services provided by Cunneen Premier Locksmiths to clients. We do not collect information that is not relevant or sensitive in nature unless required in the normal course of business.

The personal information that is collected may include, but is not limited to:

• Full name
• Address
• Date of birth
• Credit references if applicable
• Publicly available information relating to the client's activities
• Driver's license details
• Medical insurance details (if applicable)
• Electronic contact details including email, Facebook and Twitter
• Next of kin and other contact information where applicable

The client acknowledges that provided the correct Privacy Act disclosures have been made, Cunneen Premier Locksmiths may conduct a credit report on the client to evaluate creditworthiness.

All personal information is held in a secure manner. To the best of our knowledge, all computers and servers have the required security protections in place to safeguard personal information.

We use cookies on our website. Cookies are small files stored on your computer designed to hold a modest amount of data specific to a particular client and website. Where cookies are not strictly necessary for the provision of our services, we ask you to consent to their use on your first visit.

If you use our website for purchases or orders, we may collect:

1. IP address, browser, email client type and other similar details;
2. Tracking website usage and traffic; and
3. Reports available to us when we send an email to the client.

If you consent to our use of cookies and later wish to withdraw consent, you may manage your browser privacy controls, including removing cookies from your history when you leave the site.

Cunneen Premier Locksmiths also regularly conducts internal risk management reviews to ensure that our infrastructure is secure and any identifiable risks have been mitigated.

3. Procedures and Responding to Potential Breaches of Privacy

In accordance with the Act, Cunneen Premier Locksmiths is aware of its responsibilities to notify clients in the event of a potential data breach that may cause serious harm. For clients located in the EU, potential data breaches will be safeguarded by the provisions of the GDPR.

Personal information may be collected and processed by any of the following methods:

• Credit application forms
• Work authorisation forms, quote forms or other business documentation
• Publicly available databases
• Websites such as Sensis, Facebook, Google etc.
• By verbally asking you for information as part of normal business practices

Where relevant under the GDPR, the Privacy Officer shall carry out a data protection impact assessment prior to processing where the processing is likely to result in a high risk to the rights and freedoms of natural persons. The assessment is carried out in accordance with Article 35(7) of the GDPR.

By agreeing to our Terms and Conditions of Trade (which includes this privacy policy), you consent to the collection, processing, use and disclosure of your personal information. You may withdraw your consent at any time by contacting our Privacy Officer by telephone or email.

4. Purposes for Which Information Is Collected, Held, Used and Disclosed

Disclosure to Third Parties

Cunneen Premier Locksmiths will not pass on your personal information to third parties without first obtaining your consent, unless such information is required for the supply of Goods and Services via any associated franchisees outside of the client's present location.

In accordance with the Act and GDPR (where relevant), personal information can only be used for:

1. Accessing a credit reporter's database to assess your credit account, ongoing facility or to notify a default.
2. Checking trade references on the prescribed form.
3. Marketing products and services provided by Cunneen Premier Locksmiths.
4. Day-to-day business purposes such as complying with tax requirements, accounting or legal matters.

5. How an Individual May Access Personal Information Held

You have the right to request a copy of all information about you that we hold. You also have the right to request that incorrect, outdated or inaccurate information is corrected. Any such requests should be directed to the Privacy Officer.

Cunneen Premier Locksmiths will destroy personal information upon your request, or when it is no longer required, except where it is required to fulfil performance of services or is required to be maintained by law.

6. Complaints About a Breach of the GDPR

You can make a complaint to our internal dispute resolution team regarding an interference with or misuse of your personal information by contacting us by telephone or email.

We will respond to that complaint within 7 days of receipt and take all reasonable steps to make a decision within 30 days. If you are not satisfied with the resolution provided, you can complain to the Privacy Commissioner.

7. Disclosure to Overseas Recipients

Cunneen Premier Locksmiths shall not disclose information about the client to third-party overseas recipients unless the client has provided consent. We will notify you if circumstances change regarding overseas disclosure and will comply with the Act and the GDPR in all respects.

Unless otherwise agreed, we do not disclose personal information for the purpose of direct marketing. You have the right to request that we do not disclose any personal information for direct marketing purposes.

8. Privacy Officer (Responsibilities)

Cunneen Premier Locksmiths has appointed an internal Privacy Officer to manage privacy matters. The Privacy Officer is familiar with the GDPR and assists with any complaint made to the Privacy Commissioner.

Complaints

If a privacy complaint is received the Privacy Officer will:

• Take ownership of the complaint and ensure it is dealt with in a timely manner.
• Acknowledge receipt within 24 hours and advise the complainant of their rights.
• Fully investigate the complaint.
• Respond, with findings, to the complainant within 20 days of receipt.
• Keep a record of all complaints received for ongoing review of policies and procedures.

The Privacy Officer shall ensure that Cunneen Premier Locksmiths' documentation complies with the Privacy Act and Credit Reporting Privacy Code at all times.