MOTTO MOTTO
PRIVACY POLICY

Privacy Policy Motto Motto respects the importance of protecting the privacy and the rights of individuals in relation to their personal information. This privacy policy tells you how we collect and manage your personal information. We respect and uphold your rights to privacy protection under the Australian Privacy Principles contained in the Privacy Act 1988 (Cth) (the Act) and we comply with all of the Act’s requirements in respect of the collection, management and disclosure of your personal information.

1. What is your personal information?

When used in this privacy policy, the term “personal information” has the meaning given to it in the Act. In general terms, it is any information that can be used to personally identify you. This may include your name, address, telephone number, email address, date of birth, profession or occupation, and your IP address. If the information we collect personally identifies you, or you are reasonably identifiable from it, the information will be considered personal information.

2. What personal information about you does Motto Motto collect or hold?

If you are a customer or prospective customer, Motto Motto may collect or hold information received as a result of any dealing, transaction or interaction with you, including but not limited to the following:

• name

• age

• date of birth

• address

• phone numbers,

• social media identifiers

• email address

• ACN or ABN

• payment details

• financial instiution account details

• credit card details

• drivers license number and state

• records of products or services or warranty supplied to or received by you

• employment application information

• any information you provide to us as a result of any dealing, transaction or interaction (for instance any feedback or requests for information)

• any information you submit for the purposes of participating in promotional programs or collected as part of the administration of any such program; or Motto Motto may also collect and hold statistical information regarding the use of our website which may include your device’s internet protocol address and the date and time of your visit.

• Any other relevant information

You must not provide us with personal information of another person, other than with our express permission. If at any time you provide the personal information of another person to us then you must ensure that that person has read and understood this policy and separately consents to that personal information being used and disclosed by us for the above purposes.

3. How do we collect your personal information?

We collect your personal information directly from you unless it is unreasonable or impracticable to do so. When collecting personal information from you, we may also collect in other ways including:

• through your access and use of our website;

• during phone calls with our representatives

• when we deliver or administer products or services

• from you agents or representatives that act on your behalf

• from third parties who you have asked or permitted to provide your personal information (including those parties from whom you purchase goods and services)

• in-store through the Motto Motto Loyalty Program;

• by phone or email, or via social media;

• by signing up to the Motto Motto email database;

• through participation in our promotions

• from marketing organisations, including through the use of purchased lists

• from publicly available sources such as the Internet and telephone directories

• from law enforcement, dispute resolution, statutory or regulatory bodies

If we receive personal information about you that we have not requested, and if we determine that we could not lawfully have collected that information had we requested it, we will destroy or de-identify the information, if it is lawful and reasonable to do so

4. Cookies

In some cases, we may also collect your personal information through the use of cookies. When you access our website, we may send a “cookie” (which is a small summary file containing a unique ID number) to your device. This enables us to recognise your device and greet you each time you visit our website without bothering you with the same requests. It also enables us to keep track of the products that you like, and the promotions that you’ve been a part of so that, if you consent, we can send you news about new exciting products and promotions that you might like. We also use cookies to measure traffic patterns, to determine which areas of our website have been visited and to measure transaction patterns in the aggregate. We use this to research our users’ habits so that we can improve our online products and services. If you do not wish to receive cookies, you can set your browser so that your device does not accept them. We may log IP addresses (that is, the electronic addresses of devices connected to the internet) to analyse trends, administer the website, track users movements, and gather broad demographic information.

5. What happens if we can’t collect your personal information?

If you do not provide us with the personal information described above, some or all of the following may happen:

• we may not be able to provide you with your favourite Motto Motto products and services to the same standard;

• we may not be able to provide you with information about products and services that you may want, including information about discounts or special promotions; or;

• we may be unable to tailor the content of our website to your preferences and your experience of our websites may not be as enjoyable or useful.

6. What does Motto Motto do with your personal information and why do we collect and hold it?

We collect personal information about you so that we can perform to provide the best possible quality of customer service and give you and your fellow customers what you want. We collect, hold, use and disclose your personal information about for the following purposes:

• to assist in providing goods and services to you;

• to assist in responding to any requests you make to us;

• to communicate promotional offers and special events;

• to assess the performance of the website and to improve the operation of the website;

• for the internal administrative, marketing (including direct marketing), planning, product development, quality control and research purposes of Motto Motto and its franchisees and associates;

• to administer any completed agreement and provide the services thereunder;

• to administer any promotions or offers;

• to process and respond to any complaint made by you;

• to comply with any law, rule, regulation, lawful and binding determination, decision or direction of a regulator, or in co-operation with any governmental authority of any country; and

• for any other purpose made known to you at the time of collection of your personal information.

Motto Motto may disclose the information collected to agents and employees of Motto Motto and/or franchisees of Motto Motto and/or their agents or employees but only for the purpose for which such information was collected. At any time, you may opt out of receiving any communications from us (other than as required for the operation of our business, e.g. regarding payment of your account). Your personal information will not be shared, sold, rented or disclosed other than as described in this Privacy Policy.

7. Who can we disclose your personal information to? We may disclose your personal information to:

• Our employees, our franchisees, contractors or service providers for the purposes of operation of our website or our business, fulfilling requests by you, and to otherwise provide products and services to you including, without limitation, third party payment providers, web hosting providers, IT systems administrators, mailing houses, couriers, payment processors, data entry service providers, electronic network administrators, debt collectors, and professional advisors such as accountants, solicitors, business advisors and consultants;

• our suppliers and other third parties with whom we have commercial relationships, for business, marketing, and related purposes; and

• any organisation for any authorised purpose with your express consent.

8. Direct marketing materials

We may send you direct marketing communications and information about our products and services that we consider may be of interest to you. These communications may be sent

in various forms, including mail, SMS and email, in accordance with applicable marketing laws, such as the Spam Act 2003 (Cth). You consent to us sending you those direct marketing communications by any of those methods. If you indicate a preference for a method of communication, we will endeavour to use that method whenever practical to do so. In addition, at any time you may opt-out of receiving marketing communications from us by contacting us using the contact information in clause 15 of this privacy policy or by using opt-out facilities provided in the marketing communications and we will then ensure that your name is removed from our mailing list. We do not provide your personal information to other organisations for the purposes of direct marketing.

9. How can you access and correct your personal information?

You may request access to personal information we hold about you by writing to the Motto Motto Privacy Officer at the address specified in clause 14 of this privacy policy. Where we hold information that you are entitled to access, we will endeavour to provide you with a suitable range of choices as to how you access it (eg emailing or mailing it to you). There may be instances where we cannot grant you access to the personal information we hold. For example, we may need to refuse access if granting access would interfere with the privacy of others or it if would result in a breach of confidentiality. If that happens, we will give you written reasons for any results. If you believe that personal information we hold about you is incorrect, incomplete or inaccurate, then you may request us to amend it. We will consider if the information requires amendment. If we do not agree that there are grounds for amendment, then we will add a note to the personal information stating that you disagree with it.

10. What is the process for complaining about a breach of privacy?

If you believe that your privacy has been breached, please contact our Privacy Officer using the contact information in clause 15 of this privacy policy and provide details of the incident so that we can investigate it. We request that complaints about breaches of privacy be made in writing, so we can be sure about the details of the complaint. Our Privacy Officer deals with privacy complaints and any complaints should be directed to our Privacy Officer using the contact details in clause 15 of this privacy policy. We will attempt to confirm with you, as and when it is appropriate and necessary, your understanding of the conduct relevant to the complaint and what you expect as an outcome. We will inform you whether we will conduct an investigation, the name, title, and contact details of the investigating officer and the estimated completion date for the investigation process. After we have completed our enquiries, we will contact you, usually in writing, to advise the outcome and invite a response to our conclusions about the complaint. If we receive a response from you, we will assess it and advise if we have changed our view.

Security

We take reasonable steps to ensure your personal information is protected from misuse and loss and from unauthorised access, modification or disclosure. We may hold your information in either electronic or hard copy form. Personal information is destroyed or de-identified when no longer needed. As our website is linked to the internet, and the internet is inherently insecure, we cannot provide any assurance regarding the security of transmission of information you communicate to us online. We also cannot guarantee that the information you supply will not be intercepted while being transmitted over the internet. Accordingly, any personal information or other information which you transmit to us online is transmitted at your own risk.

12. Contacting us

If you have any questions about this privacy policy, or any concerns or a complaint regarding treatment of your privacy or a possible breach of your privacy by us, please contact us, preferably in writing, using the details set out in this clause 12. We will treat your requests or complaints confidentially. Our representative will contact you within a reasonable time after receipt of your complaint to discuss your concerns and outline options regarding how they may be resolved. We will aim to ensure that your complaint is resolved in timely and appropriate manner. Our contact details are as follows:

• Motto Motto Support Office

• Web: https://www.mottomotto.com.au/locations/

• Email: contact@mottomotto.com.au

• Phone: (07) 38540888

• Post: Unit 1/279 St Pauls Terrace, Fortitude Valley, 4006

13. Do you want to contact us anonymously?

You can certainly contact us anonymously. If you choose not to be identified, however, we are limited in our ability to provide you with the services or information you require

14. Are you not satisfied with our response?

If you are not satisfied with the result of your complaint to us, you can refer your complaint to the:

• Office of the Australian Information Commissioner

• Phone: 1300 363 992

• Post: GPO Box 5218, Sydney NSW 2001

• Online form: oaic.gov.au (Privacy Complaint Form)

15. Change to our Privacy Policy

We may change this privacy policy from time to time. Any updated versions of this privacy policy will be posted on our website. Please review it regularly. This privacy policy was last updated on 07 April 2020.

16. Miscellaneous

References to “Motto Motto” or “we” are references to Motto Motto Holdings Pty Ltd (ABN 31 629 988 496). Although we always intend to observe this policy, it is not legally binding on Motto Motto in any way. From time to time we may regard it as necessary or desirable to act outside the policy. Motto Motto may do so, subject only to any other applicable contractual rights you have and any statutory rights you have under the Act or other applicable legislation.