Our commitment

Intouch is committed to complying with the National Privacy Principles ("NPPs"), as set out in the Privacy Act 1988 (Cth) (the "Act"). As evidence of this commitment, Intouch has developed and implemented this Privacy Policy and undertakes to adhere to the NPPs as follows:

Collection - necessity of collection

We will only collect personal information which we need to carry out our functions and activities. Personal information which we may collect includes your name, address, age, phone number, credit card details and any other information we require to transact with you.

Collection - by us and our clients

Intouch is a contact solutions service provider. This means that other organisations hire us to place and receive communications (including phone, fax, email, mail and SMS) on their behalf (these organisation are our "Clients"). During these communications, your personal information may be collected by us and by our clients.

The identity of our clients will be disclosed to you before we collect your personal information from you. At this time, you will also have an opportunity to find out how our clients will use and disclose your personal information, how you can gain access to your personal information and other information on our clients' policies on the management of personal information.

Sometime we collect your personal information from our clients. Our clients' Privacy Statements inform you of this and of your ability to obtain a copy of our Privacy Statement.

Means of collection

We only collect personal information by lawful and fair means and in ways which are not unreasonably intrusive. For example, we may collect your personal information during a phone call, by receiving your email and through our website (www.intouchdirect.com.au).

If we contact you by phone outside normal business hours then we will always ask for your permission before we collect your personal information.

When we collect your personal information we will take reasonable steps to make you aware of your rights under the NPPs.

Because it is not always reasonable and practicable to collect personal information directly from you, we may collect your personal information from a third party. We commonly collect personal information from the following third parties in the following circumstances:

• our clients (as explained above)
• your employer
• list brokers
• people who are related to you or are your guardian or carer.

Use and Disclosure

We collect your personal information for a variety of purposes, including:

• to provide you with our own products and services
• to provide you with the products and services of our Clients
• to provide our clients with market research and other statistical information
• so that we or our client or both may market to you
• to correct and update your personal information on behalf of our Clients.

To satisfy these purposes, we may disclose your personal information to Approved Third Parties. Approved Third Parties include:

• our clients
• outside service providers of IT related services
• storage space providers
• outside service providers who update and correct your personal information
• distributors of products ordered by you
• suppliers of products ordered by you
• print houses and other organisations involved in the general administration of Intouch.

We may also use and disclose your personal information in other ways provided such uses or disclosures are allowed under NPP 2 (e.g. for public health and safety reasons).

Please note that any personal information collected by our Healthcare division will not be used or disclosed by Intouch Call Centre Services. Additionally, personal information collected pursuant to the Continence Aids Assistance Scheme will only be used or disclosed for purposes related to it.

Data Quality

When collecting your personal information, our staff will take care to ensure that it is accurate, complete and up to date, and we ask that you do the same. Therefore, when we ask your for your personal information please ensure that:

• when providing personal information over the phone, you spell any difficult words
• when completing forms you provide information for all required fields and print legibly.

If your personal information is not accurate, complete and up to date then we may not be able to provide you with our products and services.

We also ask that you contact us whenever your personal information changes or if you become aware that our records are incorrect. By contacting us we can take reasonable steps to ensure that your personal information is correct before we use or disclose it again.

Data Security

Intouch has implemented physical security and computer security measures to ensure that your personal information is kept safe from misuse and loss and from unauthorised access, modification or disclosure. We will monitor and adopt, as appropriate, new technological developments that are designed to aid in ensuring the security of your personal information. We limit access to your personal information to those of our employees who need it to carry out their responsibilities. We educate our employees about our policies and practices to ensure that they:

• store personal information so that it is not on view to the public (unless the personal information has been collected for general publication)
• maintain the integrity of their computer access passwords
• prevent unauthorised people from entering areas within our premises where personal information is stored
• do not transmit sensitive or commercial personal information by means which may jeopardise that information's security unless those means have been expressly or impliedly approved by you.

Unfortunately, no data transmission over the internet can be guaranteed as totally secure. Although we strive to protect such information, we cannot ensure or warrant the security of any information you transmit to us electronically or any information which we transmit to you electronically. Consequently, such transmissions are carried out at your own risk. Once we receive your transmission, we take reasonable steps to preserve the security of the information in our own system.

When we can no longer use or disclose your personal information then we will take reasonable steps to permanently destroy or de-identify it.

Openness

We promise to be honest and open with you about the actual use of information that is collected about you and the type of personal information about you that we keep. You may enquire about the use or type of information we hold by contacting our Privacy Officer. Our Privacy Officer's contact details are as follows:

Privacy Officer

PO Box 2082, Milton, Queensland, 4064

P +61 7 3858 6444

F +61 7 3858 6411

E privacy@intouchdirect.com.au

This Privacy Policy is publicly available to anyone who asks for it.

Access and Correction

We will allow you to access the personal information we keep about you provided you satisfy us of your identity. To satisfy us of your identity you may need to provide us with appropriate documentation such as a drivers license or passport.

If you wish to improve the accuracy, correct or update your personal information then you can do so by contacting our Privacy Officer. Our Privacy Officer's contact details are set out above under the heading Openness.

Our website:  www.intouchdirect.com.au provides you with the facility to access and update the personal information you provide to become a member of that site.

We reserve the right to refuse you access to your personal information or to improve its accuracy, correct or update it if allowed to do so under the NPPs.

We also reserve the right to charge a reasonable fee for providing access to your personal information.

Identifiers

We will not use Commonwealth Government identifiers as our own identifier for you. If we do collect Commonwealth Government identifiers then we will only use them in accordance with NPP 7 Identifiers. We may use your company name or ABN (as defined in the A New Tax System (Australian Business Number) Act 1999) to identify you.

Anonymity

In most circumstances we will be unable to transact with you unless you provide us with the personal information we request. However, if it is lawful and practicable for us to transact with you anonymously (e.g. if you pay by cash and receive our goods or services in person without the need for delivery to you or after sale service) then we will allow you to do so.

Please note that failure to provide full and complete personal information that we request may result in a limited ability on our part to offer or deliver complete services to you.

Overseas Data Flows

Unless we are satisfied that requirements of NPP 9 Overseas Data Flows are met, we will not transfer personal information to someone, other than you or ourselves, who is in a foreign country.

Generally speaking NPP 9 only allows personal information to be sent to someone in a foreign country if that person is legally obliged to handle that personal information in accordance with the NPPs or similar laws.

Sensitive Information

Intouch operates the Continence Aids Assistance Scheme (CAAS) under contract to the Commonwealth Government and provides other services on behalf of other government organisations. In operating the CAAS and in providing other government related services, INTOUCH may need to collect sensitive information relating to your health so that we can provide you with the products and services you require.

Sensitive information that is collected will never be used for direct marketing purposes.

We will only use and disclose that sensitive information as allowed under the NPPs.

Our website and cookies

Apart from the personal information you supply to us through our website, our website may collect information from visitors that is not personally identifiable. This information may include details about your operating system, browser, domain name, and specific web pages you access on our site. We only collect this information in the aggregate and only use it to improve our website.

We may use cookies to personalise and simplify your access to and use of our Web site. A cookie is a piece of data stored on your hard drive, which allows us to recognise your computer. This information is used to authenticate or identify whether you are registered on our website, without requiring you to re enter details each time you log on to our website. Cookies are not linked to any personally identifiable information whilst on our site, but can allow us to attract the interest of customers and enhance your online experience. Cookies can assist by allowing you to navigate freely on our website without the need to re register, therefore saving you time.

If at any time you do not wish to accept cookies or wish to delete existing cookies, you may manually configure your browser to refuse cookies or may manually delete existing cookies from your hard drive. However, by deleting or refusing to accept cookies, you may frustrate or encumber your access to or use of areas of our Web site.

Our website uses technology to log the IP address, browser type and version, machine and operating system. This information can be used to customise the site to best suit your habits.

Your IP address may be used by our web systems to track your session, across an ecommerce transaction for instance. At no point is your IP address linked to personally identifiable information. It is used however to gather broad demographic information gathered during standard web server logging.

Complaints resolution

We are committed to providing you with a fair and responsive system for handling and resolving complaints. You have a right to complain and to have your complaint handled efficiently. We believe that in receiving your complaint we are provided with a valuable opportunity to improve the services we deliver to you and maintain your confidence in us and our services.

If at any time you wish to lodge a complaint in respect of the handling, use or disclosure of your personal information then please contact our Privacy Officer. Our Privacy Officer's contact details are set out above under Openness.