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## What does this policy apply to?

This Privacy Policy covers all of the entities within the McCloy Group, including all of the Communities and the Corporate site.

McCloy Group is committed to respecting and safeguarding the personal information of the individuals with whom it deals. This ‘Privacy Policy’ sets out how we collect, store, use and disclose your personal information in accordance with the Australian Privacy Principles contained in the Privacy Act 1988 (Cth).

In addition to our general personal information management practices, section 5 of this Policy covers the way in which an individual’s personal information is treated when they access and interact with the McCloy Group website at www.mysticwindsaircharter.com.au.

Acts and practices of employers that are directly related to both employee records and an employment relationship are exempted from the Privacy Act, and are not covered by this Policy.

This Privacy Policy outlines our personal information management practices. It covers the following areas:

- Collection of personal information;
- Use and disclosure of personal information;
- Security of personal information;
- Accessing and updating personal information;
- The McCloy Group website;
- Contact details;
- Complaints; and
- Changes to this Policy.

## 1. Collection of personal information

Personal information is information or an opinion that can identify an individual or from which the identity of the individual can be reasonably ascertained. An individual’s name, address and telephone number are examples of personal information. When McCloy Group provides you with services, we may need to collect certain information from you. The type of personal information which we collect will depend upon the dealings which you may have with McCloy Group. We collect personal information provided by you or your authorised intermediaries which is reasonably necessary to:

- provide you with quality products and services;
- do all things necessary to administer, manage, develop and protect those products and services;
- consider applications and approaches which you make to us; and
- maintain your contact details.

###### Consequences if information not provided

When we ask you to provide us with personal information, if you do not provide us with that information or if that information is incomplete or inaccurate, it may:

- prevent us from providing our products and services to you;
- limit our ability to provide you with the level of service which you would normally expect from us; or
- prevent us from being able to contact you.

###### Sensitive information

We do not generally collect sensitive information about you. Sensitive information includes information or opinion relating to:

- racial or ethnic origin;
- political opinions;
- membership of a political association;
- religious beliefs or affiliations;
- philosophical beliefs;
- sexual preferences or practices;
- criminal convictions;
- membership of a professional or trade association; or
- health information.
- If we do collect sensitive information about an individual, we will only do so with the consent of that individual or otherwise in accordance with the law.

###### Indirect collection of information

We generally try to collect personal information directly from you or through your authorised intermediaries.

## 2. Use and disclosure of personal information

Personal information which is collected by McCloy Group is generally only used and disclosed for:

- the main purpose for which the information was collected; or
- related purposes, which would be within your reasonable expectations.
- We may otherwise use or disclose your personal information where the use or disclosure is required or authorised by law (for example, disclosure to government regulatory and law enforcement agencies) or in emergency situations.

If McCloy Group wishes to use or disclose your personal information in other circumstances, we will seek your consent to do so.

Members of the McCloy Group may share an individual’s personal information with their related entities. In this case, the information may only be used or disclosed by the related entity for the main purpose for which it was collected, for purposes related to the main purpose, where required or authorised by law, or for other purposes if the individual has consented.

McCloy Group does not sell personal information to companies outside McCloy Group.

We may disclose your personal information to our contractors and service providers that assist us in the operation of our business or the provision of services (for example, our internet service provider or mailing house). The McCloy Group requires these organisations to agree to comply with this Privacy Policy.

A small number of our related entities and third party service providers are located in countries outside of Australia. Our contracts with these parties generally include an obligation for them to comply with Australian privacy law and our Privacy Policy.

###### Marketing

The Spam Act 2003 (Cth) restricts the circumstances in which McCloy Group can send you commercial electronic messages (including email and SMS text messages). McCloy Group may send other advertising material to you where the advertising material is related to the purpose for which the personal information was collected. If you no longer wish to receive such promotional information from McCloy Group, you may advise us in writing. Commercial electronic messages from McCloy Group will include information about how to contact us, and unsubscribe if required. McCloy Group’s records would normally be amended within 30 days or as otherwise required by the Spam Act. Details of how to contact us are set out below.

## 3. Security of personal information

We take reasonable steps to protect all of the personal information we hold from misuse, loss, unauthorised access, modification or disclosure. This protection applies in relation to information stored in both electronic and hard copy form.

The McCloy Group will destroy or permanently de-identify any personal information collected which is no longer required.

External organisations which provide support services to the McCloy Group are also required to appropriately safeguard the security of the personal information which we provide to them.

## 4. Accessing and updating personal information

You may request access to your personal information or request us to correct information which we hold about you. To make a request, please put your request in writing using the contact details below. We may require proof of your identification before we can provide you with access to your personal information.

In normal circumstances we will give you full access to the personal information which we hold about you. However, in some circumstances, we may not be required by law to provide an individual with access to or to correct their personal information. If this is the case, you will be provided with the reason(s) for our decision.

We will normally provide access without charge unless you request access to a large volume of personal information or we have to access our archived records to obtain the information. In these circumstances, we may impose a fee to recover our reasonable costs.

## 5. The McCloy Group website

This section outlines the way we handle personal information which we collect when an individual uses the McCloy Group website under the domain name www.mysticwindsaircharter.com.au.

We outsource the development, maintenance and hosting of the website to third party service providers. We may disclose personal information about an individual to our third party service providers so that they can effectively provide these services.

###### Collection of personal information

An individual may visit the McCloy Group website without providing us with any personal information. However, we may collect personal information about an individual accessing the website if they use the ‘Contact us’ section of the website.

###### Use of cookies and web tracking

A cookie is a small data file that contains information about your visit to a website. This information is provided by your computer during your first visit to a web server.

The server records this information in a text file and stores this file on your hard drive. When you visit the same website again, the server looks for the cookie and structures itself based on the information provided.

Most browsers are initially set up to accept cookies. You can reset your browser to refuse all cookies or to warn you before accepting cookies. If you have set your browser to warn you before accepting cookies, you will receive the warning message with each cookie.

McCloy Group does not use cookies or web bugs to keep personal profiles of its customers’ use of the McCloy Group website.

###### Links

We may, from time to time, include links in the website to the websites of other organisations which may be of interest to you. We are not responsible for the privacy practices of these websites.

###### Website security

As with any internet transaction, the transmission of data over the internet is not completely secure. While we take reasonable steps to protect all the personal information in our possession that we have collected via the website in accordance with our general personal information management practices, we cannot guarantee the security of all data submitted to us over the internet.

###### Email

If an individual emails us, the email may contain personal information about that individual. We will treat the information in accordance with our general personal information management practices outlined in this Privacy Policy.

## 6. Contact us

If you have any questions or feedback about this Privacy Policy or your personal information, please contact the McCloy Group at:

HEAD OFFICE

Suite 1, Level 3, 426 King St

Newcastle West, NSW 2302 Australia

POSTAL ADDRESS

PO Box 2214

Dangar, NSW 2309 Australia

PHONE : +61 2 4945 7500

FAX : +61 2 4929 6472

EMAIL : admin@mccloygroup.com.au

## 7. Complaints

If you wish to make a privacy complaint, you may contact the Office using the contact details above. You will need to provide us with sufficient details regarding your complaint, as well as any supporting evidence and/or information.

We will refer your complaint to our legal team who will investigate the issue and determine the steps we will undertake to resolve your complaint. We will contact you if we require any additional information and will notify you in writing requesting the same.

If you feel that we have not adequately dealt with your complaint, you may contact the Australian Privacy Commissioner via www.oaic.gov.au.

## 8. Changes to this Policy

This is our current Privacy Policy outlining our personal information management practices. It replaces any other Privacy Policy published by us to date, whether on the website or in hard copy. We reserve the right to revise this Privacy Policy from time to time and your continued use of our website or services constitutes your acceptance of any revised Privacy Policy.