About this policy

Carpet Court Australia Ltd (ACN 001 195 697) is a floor covering specialist and retailer and has a network of stores across Australia which are operated by various franchisees who are all shareholders of Carpet Court Australia Ltd (Members). Carpet Court is part of a group of companies which include: Court International Ltd, Carpet Court (Southern) Limited and Space Flooring & Interiors Pty Ltd (the Carpet Court Group). We are committed to protecting the personal information we collect and hold about you in accordance with this policy, the Privacy Act 1988 (Cth), the Australian Privacy Principles and the Privacy (Credit Reporting) Code 2014.

In this policy, we, us and our means each member of the Carpet Court Group.

This policy outlines how the Carpet Court Group collects, uses, discloses and protects personal information of our customers, Members and job applicants, how they can request access to and correction of any personal information we hold about them and how they can make a privacy complaint. We require each of our Members to comply with this policy too.

This policy does not apply to the personal information of our employees.

The Carpet Court Group is committed to managing your personal information openly and transparently and to keeping your personal information safe. We will take all steps to fulfil this commitment, including by:

• only collecting personal information from you that we need; and
• keeping your personal information secure.

What is personal information?

Personal information is information or an opinion about an identified individual, or an individual who is reasonably identifiable:

• whether the information or opinion is true or not; and
• whether the information or opinion is recorded in a material form or not.

For example, personal information includes an individual's name, address, telephone number, email address, bank account or credit card details and other information you may give us from time to time.

Collection of personal information

Carpet Court offers retail services to customers via its franchise stores including assisting customers to choose the right flooring option, providing an extensive range of flooring options and installation (Services). As part of providing the Services, we may allow individuals or businesses to create an account or subscribe to our newsletter. We provide the Services online via our website at the domain name 'www.carpetcourt.com.au' (Website). It is our policy, in providing the Services, to further develop our Website.

We collect personal information that is reasonably necessary to provide the Services. The types of information that we usually collect include:

• information to identify you or contact you including, your name and contact details (including your address, phone number and email address);
• information about your website usage when you visit and use our Website as explained further below;
• information to confirm your identity, for example, your driver's licence number or your date of birth;
• if you are a Member, your sensitive information (such as information about your health) that you provide to us that is relevant to the performance of your business and our provision of services; and
• if you apply for a job with us, information necessary to assess your application, such as your employment history, qualifications and references.

We may collect your personal information from you when you:

• visit the Carpet Court Website;
• provide your details on our Website, including when you register to use our Website, sign up to receive a quote or subscribe to newsletters and marketing material;
• visit the Member Portal, including when you register to use our Member portal or sign up for any additional services;
• engage with us including in store, online, by telephone or email;
• interact with us on other forums;
• apply to become our Member, including if you meet with us to discuss your application;
• attend any of our functions, training or conferences;
• provide reports, updates and franchise information to us; and
• apply for a job with us. We may also collect your personal information from your referees.

We may also collect your personal information when you interact with us via our official social media pages that we control, such as Facebook, Twitter, Instagram and LinkedIn. You control the personal information we have access to through your privacy settings on the social media site.

We may collect information based on how you use the Website. Carpet Court uses 'cookies' and other similar technologies to collect non-identified/anonymous information about the users of its Website such as the number of visitors and the number of pages viewed. This information is collected to analyse and improve the Website and to record statistics on web traffic. Cookies may record information about your visit, including the type of browser and operating system you use, the previous site you visited, your server's IP address, the pages you access and the information downloaded by you. No attempt is made by us to use this information to personally identify you. The statistical data may be aggregated and used by Carpet Court or third party consultants for analysis and optimisation of our Services.

If reasonable and practicable to do so, we will collect personal information directly from you. However, given that Carpet Court stores are operated by our Members, we may receive your personal information from our Members instead.

We will only collect personal information by lawful and fair means. If you provide us with personal information about you that we have not requested, we will consider whether the information is necessary to our dealings with you. If it is not necessary, we will take steps to de-identify or destroy the information as soon as practicable.

Use of Personal Information

Your personal information is used to provide you with products or Services. This information may also be used for other related purposes, such as:

• to coordinate delivery of our Services to you;

• to create an account to manage your quotes, orders and projects;
• to manage our Website and Member Portal;
• to respond to your enquiries or provide you with information you have requested;
• provision to third party suppliers of our goods or services;
• identification of fraud or error;
• for reporting and legal requirements, including our internal accounting and management requirements;
• for use in promotional, loyalty or other marketing campaigns, including direct marketing of promotions, products and services that we think might be of interest to you;
• monitoring of quality control and assessing our standard of service to you;
• to consider and review any complaints you may make to us;
• for Members, to facilitate your business, trading account and so that Carpet Court can provide ongoing support to you;
• for the management of our franchise system;
• to assess your job application; and
• to better understand your preferences.

(the Related Activities)

By providing your personal information to us or by agreeing to accept the terms of this privacy policy, or both, you acknowledge your personal information will be used for the Related Activities. Each direct marketing communication we send you will include an 'unsubscribe' option.  You can also request not to receive direct marketing communications from us at any time by contacting us using the details in the 'Contact us' section of this privacy policy.

Disclosure of Personal Information

We may disclose your personal information to:

• Members;
• third party suppliers of goods and services, including delivery and installation services;
• partners in our promotional, loyalty or other marketing campaigns which we engage in from time to time;
• our agents, successors and/or assigns;
• our insurers;
• prospective Members for the purpose of meeting our disclosure obligations under the Franchise Code;
• service providers that perform a range of services on our behalf, including auditors and solicitors, information technology vendors and other consultants; and
• regulatory and law enforcement bodies.

Disclosure of personal information overseas

There may be circumstances where we need to disclose personal information that we hold about you to a third party overseas (an Overseas Recipient). This may occur, for example, where we have a database or server hosted outside Australia or where you are interacting with an application which is based overseas. The countries in which these Overseas Recipients may be located include New Zealand, the United States of America and the United Kingdom.  Prior to us disclosing your personal information to an Overseas Recipient, we will take reasonable steps to ensure that the Overseas Recipient has appropriate systems in place to ensure that your information is secure and satisfy our disclosure obligations.

How we handle credit information (credit information management policy)

If you are a Member, we may be a credit provider to you in relation to your commercial trading account with us, and we may handle your, and your guarantors', credit information (including credit eligibility information) for this purpose.

What kinds of credit information do we collect?

We collect your (and your guarantors') credit information in your trading application, in financial reports you provide us, from credit reporting bodies, and from our credit insurer and broker. The credit information we collect includes:

• identification information (such as your name, date of birth, address and driver's licence number);
• information about your trading account, including frequency of payments and unpaid or overdue amounts;
• information about your or your guarantors' credit arrangements, any information about your or your guarantors' credit worthiness, credit standing, credit history or credit capacity;
• personal insolvency information including credit exposures you may have to other credit providers;
• court proceedings information that relates to any credit that has been provided to, or applied for by you; and
• publicly available information that relates to your activities in Australia and your credit worthiness (other than court proceedings information or information that you are entered or recorded on the National Personal Insolvency Index).

What kinds of credit eligibility information do we hold?

In certain circumstances, credit eligibility information may be disclosed to us by a credit reporting body. The types of credit eligibility information we may collect includes:

• defaults;
• payment history information;
• credit inquiries;
• court judgments;
• bankruptcy information; and
• information associated with your overall credit worthiness.

This information will not be disclosed to us without your consent.

How we may use your credit information and credit eligibility information

We may use your credit information and credit eligibility information to assess your application for a commercial trading account (including assessing your credit worthiness and verifying your identity) and, if approved, establishing the ongoing operation of your trading account. We may also use this information to assess whether to accept you as a guarantor in relation to an application for commercial credit, or as otherwise required or authorised by law.

What kinds of "CP derived information" do we derive from credit eligibility information?

The kinds of CP derived information that we usually derive from credit reports includes a score based on information obtained from the credit report and a risk profile analysis.

How we may disclose your credit information and credit eligibility information

We may disclose your credit information to credit reporting bodies for the purpose of obtaining information about your credit rating and establishing and operating your trading account. We may also disclose credit information to a credit reporting body, including in circumstances where your account is overdue or unpaid, for the purpose of listing a default on your credit file.  The credit reporting body may then include that information in credit reporting information that they provide to other credit providers to assist them to assess your credit worthiness.  Where lawful, we may also disclose your credit information or credit eligibility information to our credit insurer and broker.

Handling your credit information

We otherwise handle your credit information in accordance with this privacy policy.  In particular, please refer to the following sections of this policy:

• About this policy
• Disclosure of personal information overseas
• Storage and protection of personal information
• Access and correction of your personal information
• Complaints
• Contact us
• Changes to our privacy policy

Storage and protection of personal information

Carpet Court stores your personal information in hard copy and electronically.  Electronic information may be stored by a third party storage provider.

Carpet Court takes, and requires its Members to take, reasonable steps to:

• ensure that the information we collect, use and disclose is accurate, complete and up to date; and
• protect your personal information from misuse, interference, loss, unauthorised access, modification and disclosure; and
• destroy or de-identify personal information that is no longer needed for a permitted purpose or required by law to be retained.

You should take reasonable steps to ensure the security of information you provide to us or receive from us over the internet.

Access and correction of your personal information

If you would like to access your personal information, you should contact us in writing using the details in the 'Contact us' section of this privacy policy. Subject to certain exceptions, we will provide you with access. We will endeavour to acknowledge such requests within 14 days of receiving the request and provide the requested information within 30 days.

If you believe that we hold inaccurate or outdated information about you, you should notify us in writing by contacting us at the contact details in the 'Contact us' section of this privacy policy.  We will take reasonable steps to correct the information so that it is accurate, up-to-date, complete, relevant and not misleading. If the information is credit information or CP derived information, we will take reasonable steps to correct the information within 30 days of you making this request, or such longer period as you have agreed in writing.

We may need to verify your identity before responding to your access or correction request.

In certain circumstances, we may not be able to correct or provide you with access to your personal information.  In these circumstances we will write to you to explain  why (unless this would be unreasonable) and how to complain.

Complaints

If you consider that Carpet Court has breached your privacy, you may make a complaint in writing to Carpet Court at the contact details below.

We will endeavour to acknowledge the complaint within 14 days of its receipt (or 7 days, if the complaint relates to how we handled your credit information or credit eligibility information) and investigate the complaint and respond to you advising the outcome of the investigation within 30 days or as soon as practicable.

If you are not satisfied with our response, you may take your complaint to the Office of the Australian Information Commissioner.

Contact us

If you have any questions about this privacy policy, if you wish to complain about how Carpet Court has handled personal information about you or if you wish to access or correct your personal information, please contact our privacy officer:

Email: privacy@carpetcourt.com.au

Post: Carpet Court Australia, Locked Bag 50, Mount Waverley BC, 3149, VIC

Phone: 03 9244 7999

Changes to our privacy policy

This privacy policy is subject to change at any time.  Please check our Website regularly for any changes.  By continuing to use the Website, engaging our Services and providing us with personal information, you will be deemed to have accepted any changes to the Carpet Court privacy policy.

Contacting you

From time to time, we may contact you to inform you of important news, or new products and services. If you no longer wish to receive these messages, please contact us, and we will remove your name from our mailing list. Alternatively, click the unsubscribe link on the email to be immediately removed from our mailing list.

Australian Government privacy information

To find out more about privacy issues and legislation in Australia, please visit the website of the Office of the Australian Information Commissioner at: www.oaic.gov.au