Privacy

At Spear & Jackson (Australia) Pty Ltd, we recognise the importance of your privacy and understand your concerns about the security of the personal information you provide to us. We comply with the National Privacy Principles (“NPP’s”) as contained in the Privacy Act 1988. The NPP’s detail how personal
information is collected, used, stored and destroyed and how an individual may gain access to personal information held about them.

Personal information, as distinct from business information, is information, or an opinion, that identifies an individual, or from which a person’s identity could be ascertained.

This policy details how Spear & Jackson (Australia) Pty Ltd manages personal information, sets out some of your privacy rights in relation to personal information, and advises how you can contact us with privacy queries. Our policy is not aimed at curtailing the flow of business or business information, but
simply ensuring personal information is handled in accordance with the Privacy Laws.

Collecting Personal Information about you

In the course of doing business, Spear & Jackson (Australia) Pty Ltd endeavours to collect business information only. However, the collection of personal information in some instances is unavoidable. We aim only to collect personal information that is necessary to perform the services your organisation
has contracted us to provide, and advise of the consequences if it chooses not to provide the information.

The type of personal information collected will depend on the goods or services you have asked us to provide, or may be interested in, and may include names, addresses, telephone and fax numbers and e-mail addresses.

At the time personal information is collected or as soon as practicable thereafter, we will advise you of:

• Our details and how to contact us;
• The purpose for which the information is collected (unless the reason is obvious in the circumstances);
• Details of how to access to any information held about you;
• The type of organisations to which we may disclose that information;
• The legal and other consequences of you not providing the information (if any);

unless any of the above is obvious in the circumstances, or detailed on a collection form.

While we endeavour to collect personal information from the individual involved, in some instances we may also receive personal information about you from third parties. Where we receive, (and retain) or use personal information from third parties, we will contact you and advise we hold this information.

How do we use your personal information?

Spear & Jackson (Australia) Pty Ltd may use and disclose your personal information if the disclosure is necessary to complete the services we provide or in order to supply you or your organisation with goods ordered. Within Spear & Jackson (Australia) Pty Ltd, we may use and disclose your personal information for the purposes of performing our administration and other operations including accounting, risk management, record keeping and archiving.

We may also use your personal information for related purposes which you would reasonably expect, such as providing you with details about other goods or services offered by us, as well as any promotions or sales relating to our business that may be of interest to you. You can opt out of receiving this information at any time by notifying us.

In some cases we may disclose your personal information to third parties, such as contractors and service providers engaged by Spear & Jackson (Australia) Pty Ltd, but only if it is required to complete the transaction you have entered into. Additionally, we may disclose your personal information to third parties engaged by Spear & Jackson (Australia) Pty Ltd to provide functions on our behalf, such as mail-outs, marketing research, advertising and the conduct of trade promotions and other competitions. You can opt out of the disclosure of
your information in this way at any time by notifying us.

We may also disclose your personal information where we have sought your consent or as is otherwise allowed by law.

Transfer of Information outside of Australia

We will not send your personal information outside of Australia unless:

• It is necessary to complete your transaction; or
• You have provided your consent; or
• We believed on reasonable grounds that the organisation involved would only deal with your personal information in a similar manner to the requirements under the National Privacy Principles; or
• Where otherwise allowed by the Privacy Act.

Storage and Security

Personal information is stored electronically, on paper, or both. Spear & Jackson (Australia) Pty Ltd has physical, electronic and procedural safeguards for personal information and takes reasonable steps to ensure that your information is protected. Data stored electronically is protected by both internal and external firewalls, and access to electronic records is limited by passwords. Only staff with a password have access to all information on the system and files can be designated read-only or no access.

Your personal information is stored within secure premises. Externally, the premises has several barriers to unauthorised entry including secured entry and alarms. Internally, steps are taken to ensure access to personal information is limited including filing in a locked cabinet within a secured office.

Please be aware that personal information provided by e-mail may not be secure. If you have any concerns regarding the security of your personal information, when sending e-mails, please provide information in an alternate form, such as facsimile. We may record your e-mail address if you send us an e-mail.

Spear & Jackson (Australia) Pty Ltd uses secure methods to destroy or permanently de-identify your personal information when it is no longer needed. Spear & Jackson (Australia) Pty Ltd will retain personal information while it is required for any of its functions, or for any other lawful purpose.

Access & Correction

In most cases, you will be able to gain access to personal information held about you by Spear & Jackson (Australia) Pty Ltd. We may provide you with this information verbally or in writing, as may be appropriate. Where we do not agree to provide you with details of personal information we will give you reasons why.

We will take reasonable steps to amend or correct your personal information to keep it accurate and up to date. Please notify us of any changes to your personal (and business!) information.

Privacy Concerns or Complaints

If you have any queries or concerns about your personal information, or would like to make a complaint, please contact our Privacy Officer for assistance.

How to Contact Us

You can contact us at the following address:

Privacy Officer
Spear & Jackson (Australia) Pty Ltd Pty Ltd
P O Box 4400,
Dandenong South, 3162

Tel: +613 8792-9999
Fax: +613 8792-9900