The protection of personal information in the private sector is required by the Privacy Act 1988. All employees and officers of LPC Australia Pty. Ltd. (“LPC”, or “we” or “us”) are expected to comply with the Act and LPC’s policies and procedures concerning the protection of personal information.

This policy applies to all our web pages accessible from www.lpc.com.au (the “website”) as well as any collection of personal information by LPC outside of the websites. It explains our practices with regards to collection and processing of any personal information (that is, information from which an individual’s identity is apparent or can be reasonably ascertained) that may be collected as a result of your interactions with LPC.

This policy is based on the following principles:

• Your personal information will not be shared other than in accordance with this policy, with your permission or in accordance with the Act
• We will only use your personal information for the purpose for which it was provided.

What information do we collect?

We collect a variety of information to enable us to provide services and operate our business. This information is collected by us solely for the purpose of considering your requirements or providing you with services. While you may choose to interact with us either anonymously, or by the use of a pseudonym, we may be limited in our ability to provide services and/or assess your requirements. The type of personal information we collect includes, but is not necessarily limited to:

1. Your name;

2. Your date of birth (but only to the extent that we are required to verify your position as a director/secretary of a client or potential client);

3. Your address;

4. Your contact details;

5. Your financial details, if you are intending to engage us in your personal capacity, rather than as an officer of a corporation, trust or some other legal entity.

What do we use personal information for?

Unless you agree otherwise, any personal details that you provide to us will only be used for the purpose of dealing with your request or enquiry, or to enable us to provide services to you. We do not use or disclose personal details that you provide to us for the purposes of direct marketing or any similar purposes.

Direct Marketing.

We do not sell, trade or transfer personal information to third parties for the purposes of direct marketing.

We may from time to time use personal information, to notify you of changes to our services provided to you, or to bring to your attention new or additional services which may be beneficial. All such communications will include an option for you to opt out or “unsubscribe” from receiving any future direct marketing from us

Disclosing personal information.

We may share personal information on a confidential basis with related companies and with contractors performing services for LPC. Such contractors may include, for example, information technology and telecommunications providers or professional advisers (including accountants, auditors and lawyers), credit reporting and fraud checking agencies, insurers, human resources consultants and credit providers. LPC will only make such disclosures to achieve the purpose for which the information was provided. Otherwise, LPC’s policy is not to disclose any personal information to any unrelated third party, except with consent or where we are required or permitted by law to do so.

Resumes.

If you submit a resume to us then we may disclose the resume to related companies, associates, joint venture and alliance partners (see “Disclosing Personal Information” above). LPC will only make such disclosures for the purpose of us and our associates, related companies, joint venture and alliance partners considering your application. We and our associates, related companies, joint ventures and alliance partners may keep your resume on file indefinitely for that purpose. If you consent, we may also disclose information about you for the purpose of undertaking background checks.

Security of personal information.

1. LPC takes the security of your personal information seriously and is committed to protecting it from unauthorized access and use. LPC has put in place appropriate physical, electronic and managerial policies and procedures to secure personal information. These policies and procedures include, but are not limited to:

   1. storing any electronic information on password protected and secure servers;

   2. ensuring any physical copies of personal information are kept in a secure area and archived according to LPC’s document retention, destruction and archiving policy;

   3. ensuring that all subcontractors are obliged to comply with the Act and where possible to this policy; and

   4. ensuring that any access to personal information by LPC employees, contractors and advisors is limited to those employees with a need to know that information for the provision of services.

2. Although LPC endeavours to take steps to provide a secure environment to hold your personal information, there is no guarantee that the electronic information about you is totally secure due to the nature of the internet. However, once we detect any unauthorised access or any kind of potential abuse, we will notify you and at the same time take the appropriate remedial steps as early as practicably possible.

3. LPC uses third party systems to process some of the data we collect, including some providers that are based outside of Australia such as Europe and the United States. In all instances we ensure the contractor has appropriate controls in place to comply with the standards imposed by the Act and our Privacy Policy.

4. Personal information may be retained for such periods as required by relevant laws. If LPC no longer requires personal information for any purpose, we will take steps to permanently de-identify or securely destroy the information in line with organisational procedures unless LPC is required by law or court or tribunal order to retain such information.

Access, accuracy and correction of personal information.

1. LPC will take reasonable steps to ensure that all personal information held is accurate, complete and up-to-date, accordingly LPC may from time to time contact you directly for the purposes of verifying your information.

2. You have a right to request access to your personal information and request changes. Correction requests should be made in writing to LPC’s Privacy Officer (details below). We will respond to your request to correct your personal information we hold within 10 business days after the request is made.

3. When requesting access or correction of personal information LPC will require you to verify your identity.

4. While LPC will generally comply with your request for access to personal information, LPC does have the right under the Act to refuse access in certain circumstances. If this is the case we will inform you and explain the reasons why.

Changes to our Privacy Policy.

We may amend, modify or replace this privacy policy at any time. Updates will take effect from the date the amended, modified or replacement privacy policy is published on our website.

Complaints and further information.

If you have a complaint or require further information about how LPC handles personal information or any privacy issues, please contact us at reception@lpc.com.au