1 Policy Statement

(a) Dragonfly Thinking (Company) is committed to protecting your privacy. This policy explains how we manage personal information within our organisation.

(b) The Company may make changes to this policy from time to time, to take into account changes to our standard practices and procedures or where necessary to comply with new laws and regulations.

2 Kinds of Personal Information Collected

(a) The kinds personal information that the Company collects and holds about you may include:

(i) identifying information, such as your name, title, position, and employer

(ii) contact information, such as your postal address, email address and mobile number

(iii) social media handles and other social media profile information that you make

available to us or to the public

(iv) financial information, such as credit card, bank account or other payment details

(v) details of any products or services that the Company provides to you

(vi) information about how you use the products and services the Company provides

(vii) records of our communications with you, including any messages you send us

(b) Without this information the Company may not be able to provide you with our products or services (or with all of the features and functionality offered by our products or services) or to respond to queries or requests that you submit to us.

3 How Personal Information is Collected

(a) The Company collects personal information about you in the following ways:

(i) when you order products or services from us

(ii) when you submit a query or request to us

(iii) when you respond to a survey that the Company runs or fill in forms on one of our

websites

(iv) by tracking your use of our websites and applications

(v) from public sources

(vi) from third parties who are entitled to disclose that information to us

(b) Where the Company collects personal information from you, the Company will generally do so directly ourselves. However, in some cases the Company may collect personal information from a third party, such as through your representatives, contractors who provide services to us, or third parties who refer you to us because they think you may be interested in our products or services.

4 Purposes for which Personal Information is Used

(a) The Company uses personal information that is collected about you for the following purposes:

(i) to verify your identity when you are dealing with us

(ii) to determine your eligibility for any of our products or services

(iii) to enable us to provide our products and services

(iv) to answer your queries and requests

(v) to comply with our legal and regulatory obligations

(vi) to carry out market analysis and research

(vii) to monitor use of our products and services

(viii) to assess, maintain, upgrade and improve our products and services

(ix) to carry out education and training programs for our staff

(x) to manage and resolve any legal or commercial complaints or issues

(xi) to carry out planning and forecasting activities and other internal business processes

(xii) to keep you informed about our activities, including by sending out newsletters

(b) The Company may from time to time use your personal information in order to send you marketing materials about products or services that you may be interested in (including in some cases products and services that are provided by a third party). You can opt-out of receiving marketing communications from us by following the “unsubscribe” link in the communication.

(c) The Company may also use and disclose your information for other purposes as authorised by you, or in accordance with your requests or instructions.

5 People to Whom Personal Information may be Disclosed

(a) The Company may share personal information about you with:

(i) your representatives, advisers and others you have authorised to interact with us on

your behalf

(ii) our staff who need the information to discharge their duties

(iii) related entities within our corporate group

(iv) our business partners, agents and service providers

(v) payment system operators and financial institutions

(vi) prospective purchasers of all or part of our business or shares in our company or a

related entity

(vii) professional advisers who we engage to provide advice on our business

(viii) government authorities who ask us to disclose that information, or to other people

as required by law

(ix) our directors and contractors for the purposes of providing our services, responding

to your requests, and meeting legal requirements

(x) other third parties where you have consented to the use or disclosure of your

personal information to those third parties.

(c) In some cases the people to whom the Company discloses your personal information may be located overseas and may be subject to different privacy regimes. The Company will never sell your personal information to any third party.

6 Cookies

(a) The Company uses cookies to monitor and observe your use of our websites, compile aggregate data about that use, and provide you with a more effective service (which may include customising parts of our websites based on your preferences and past activities on those websites).

(b) "Cookies" are small text files created and stored on your hard drive by your internet browser software, in order to hold relevant information about the web page you are currently viewing.

(c) Most internet browsers have a facility that will allow you to disable cookies altogether - please refer to your browser's help menu to find out how to do this.

(d) While you will still be able to browse our websites with cookies disabled on your internet browser, some website functionality may not be available or may not function correctly.

7 Storage and Security of Personal Information

(a) The Company takes reasonable steps to ensure that any of your personal information which is held is accurate, complete and up-to-date. These steps include promptly updating personal information when advised that the information has changed, checking our contact lists for accuracy, and providing individuals with a simple means to update their personal information.

(b) The Company stores personal information for as long as it is needed for the purpose for which it was collected or as required by law. The Company generally stores the personal information that is collected in electronic databases, some of which may be held on our behalf by third party data storage providers.

(c) Sometimes the Company also keeps hard copy records of this personal information in physical storage facilities. The Company uses a range of physical and technical security processes and procedures to protect the confidentiality and security of the information that is held, and the Company updates these from time to time to address new and emerging security threats.

8 Access and Correction

(a) If you want to access any of the personal information that is held about you or to correct some aspect of it (e.g. because you think it is incomplete or incorrect), please contact us using the contact details on the website.

(b) To protect the integrity and security of the information that the Company holds, the Company may ask that you follow a defined access procedure, which may include steps to verify your identity.

(c) In certain cases the Company may charge you an administration fee for providing you with access to the information you have asked for, but we will inform you of this before proceeding.

(d) There may be cases where the Company is unable to provide the information you request, such as where it would interfere with the privacy of others or result in a breach of confidentiality. In these cases the Company will let you know why it cannot comply with your request.

9 Complaints

(a) The Company tries to meet the highest standards in order to protect your privacy. However, if you are concerned about the way in which the Company is managing your personal information and think the Company may have breached the Australian Privacy Principles, or any other relevant obligation, please contact us using the contact details on our website.

(b) Complaints must be lodged in writing. The Company will deal with the matter within a reasonable time, and will keep you informed of the progress of our investigation.

(c) If the Company has not responded to you within a reasonable time or if you feel that your complaint has not been resolved satisfactorily, you can contact us to discuss your concerns.

(d) You are also entitled to make a complaint to the Office of the Australian Information Commissioner (OAIC). Contact details can be found at the OAIC's website