PRIVACY POLICY

This privacy policy sets out how SpinTel collects and discloses personal information. SpinTel is committed to protecting the privacy of your personal information and ensuring the public is aware of how SpinTel handles personal information.

SpinTel is bound by the Privacy Act 1988 (Act). Under the Act, SpinTel can choose to develop and be bound by a Privacy Code or elect to comply with the National Privacy Principles under the Act. SpinTel has chosen to be bound by the National Privacy Principles.

SpinTel only collects personal information that is necessary for SpinTel to conduct its business. The personal information SpinTel holds will depend on the services requested from SpinTel and the use of those services. Personal information may include:

• a) Name, address and contact details
• b) Date of birth
• c) Account name and account number held by financial institutions from which payments for services will be provided
• d) Information obtained as a result of credit checks which you authorise SpinTel to carry out
• e) Records of communications between you and SpinTel relating to services provided by SpinTel to you
• f) Call charge records
• g) Billing statements

SpinTel respects your privacy, as such SpinTel does not trade, rent or sell your personal information to any third parties. The primary purpose for which SpinTel uses personal information is to provide users with telecommunications services or to enable wholesale customers to resell telecommunications services. This includes the provision and resale of voice, data and internet services. In the course of providing telecommunications services, we may also use personal information for related purposes, which include the following:

• a) Provisioning or connecting a service
• b) Network routing
• c) Providing you with customer service
• d) Checking your credit worthiness with a credit reporting agency
• e) Billing or rebilling you for that service
• f) Investigating complaints in relation to your service
• g) Investigating and fixing faults in relation to your service
• h) Researching, developing, administering, protecting and improving our services
• i) Following up any payments that you may owe SpinTel, and
• j) Disconnecting your service

SpinTel may also use your personal information to tell you about SpinTel's other products and services provided by SpinTel in conjunction with our related bodies corporate or our business partners or associates. You may choose to opt out of receiving this type of marketing information at any time by contacting privacy@spin.net.au.

SpinTel will use personal information for the purposes set out above unless otherwise disclosed at the time of collection.

SpinTel collects personal information directly from you when you supply it to SpinTel in connection with a request for services. This includes when you:

• a) Provide personal information in your agreement with SpinTel or application for services
• b) Complete an order form
• c) Complete a credit application form
• d) Submit information on the SpinTel Customer Portal, and
• e) Complete other standard forms such as forms requesting additions, moves or changes to the services you are receiving.

SpinTel may also collect personal information about you from third parties such as:

• a) Resellers of telecommunications services
• b) Credit providers or credit reporting agencies contacted by us (or by external service providers on our behalf) in the course of carrying out a credit check
• c) Other entities which provide services to us related to the provision of telecommunications services provided to you
• d) Government agencies which administer laws regulating telecommunications service providers, or complaint resolution processes established under those laws
• e) SpinTel protects your personal information by using reasonable endeavours to ensure that any third parties make you aware of SpinTel's privacy policy

SpinTel contracts out some services such as mailing invoices and other information and correspondence, credit checking, provisioning marketing and fault fixing to external contractors or service providers. SpinTel may disclose personal information to these organisations. Any disclosure of personal information is limited to that required to provide the customer with the services that SpinTel has contracted out. At all times, parties to which SpinTel contracts services or discloses your personal information are either covered by contracts which protect your personal information or are required to comply with all relevant laws including the Act and the Spam Act 2003.

Generally, you have the right to see or obtain a copy of personal information about you that SpinTel holds. SpinTel will handle requests for access to personal information in accordance with the National Privacy Principles. To request access to your personal information, please contact our office during standard business hours. Provided SpinTel can adequately verify your identity, the person that you speak to may be able to provide you with the information required over the telephone.

If you wish to obtain a copy of any information, SpinTel will ask that you put the request in writing and either post or fax that request to us. This is to ensure that SpinTel can verify your identity. In some cases, SpinTel may need time to consider and respond to your request for access. If SpinTel needs time to consider your request, SpinTel will acknowledge that request within 14 days and respond within a maximum of30 days. SpinTel may charge you a fee for the administrative cost of providing the information. If for any reason SpinTel refuses to give you access to its information, SpinTel will let you know the reason of refusal in writing. The circumstances under which SpinTel may refuse to give you access to personal information SpinTel holds, include where giving you access would:

• a) Have an unreasonable impact on another individual's privacy
• b) Prejudice any negotiations we are having with you
• c) Prejudice an investigation of unlawful activity
• d) Prejudice activities carried out by, or for, a law enforcement body

If you believe that SpinTel holds personal information about you that you consider to be inaccurate, incomplete or out of date, you should inform SpinTel by contacting our office during standard business hours. SpinTel will amend any inaccurate, incomplete or out-of-date information. SpinTel may call you to discuss your request.

In some cases, SpinTel may not be able to provide you with telecommunications services if you refuse to provide SpinTel with the personal information SpinTel needs to perform the service. SpinTel, by law, must retain some customer information for a minimum of five years. SpinTel do not retain such information for longer than is necessary for the purposes of compliance with the law and routine administration.

You can complain about breaches of privacy in writing (email, fax or letter) or by phone to:

The Privacy Officer - SpinTel

Telephone: 1300 303 375

Email address: privacy@spin.net.au

Postal address: Level 6, 50 York Street, Sydney NSW 2000

SpinTel reserves the right to amend this policy at any time by posting an updated version on our website at www.spin.net.au.

SpinTel takes reasonable steps to protect your personal information from misuse and loss from unauthorised access, modifications or disclosure both under the Act and Telecommunications Act 1997.