At Spreadsheet Advantage we recognize the importance of protecting the privacy of personally identifiable information collected about our customers and we take care to respect your privacy when you visit our website. We are also required to comply with the National Privacy Principles contained in the Commonwealth Privacy Act of Australia as well as the requirements of the Privacy Amendment (Private Sector) Act 2000 of Australia.

This Privacy Policy sets out the approach which Spreadsheet Advantage will take in relation to the treatment of Personal Information. It includes information on how Spreadsheet Advantage collects, uses, discloses and keeps secure, individuals' Personal Information. It also covers how Spreadsheet Advantage makes the Personal Information it holds available for access and correction by the individual.

Spreadsheet Advantage may, from time to time, review and update this policy to take account of new laws and technology and changes to our operations. Any changes to this Privacy Policy will be posted on the Spreadsheet Advantage website. All Personal Information held by Spreadsheet Advantage will be governed by our most recent policy.

This policy was last updated in August 2004.

1.2 Spreadsheet Advantage collects Personal Information primarily to supply customers with the products and services. Spreadsheet Advantage also collects and uses Personal Information for secondary purposes including:

• billing and account management;
• business planning and product development; and
• to provide individuals with information about upgrades and other marketing information.

1.3 Spreadsheet Advantage will not collect sensitive information (as defined in the Privacy Act) from individuals.

1.4 Spreadsheet Advantage will collect Personal Information by lawful and fair means and not in an unreasonably intrusive or secret manner.

2.1 Spreadsheet Advantage uses Personal Information mainly for the purposes listed in 1.2 above.

2.2 Spreadsheet Advantage will obtain an individual's consent for use of Personal Information for Secondary Purposes at the time of collection, unless the use is a related Secondary Purpose which would be within the relevant individual's Reasonable Expectations.

2.3 Spreadsheet Advantage will only use Personal Information for the purpose of Direct Marketing to an individual if:

• the individual has given consent to Spreadsheet Advantage for such use of Personal Information; and
• the individual has not previously made a request to Spreadsheet Advantage to not receive further direct marketing communications.

2.4 If Spreadsheet Advantage uses Personal Information for the purpose of Direct Marketing to an individual then:

• in each direct marketing communication with the individual, Spreadsheet Advantage will draw to the individual’s attention, or prominently display a notice, that he or she may request not to receive any further direct marketing communications; and
• Spreadsheet Advantage will not charge the individual for a request not to receive any further direct marketing communications; and
• each written direct marketing communication by Spreadsheet Advantage will display the contact details for Spreadsheet Advantage.

2.5 Spreadsheet Advantage may use Personal Information to avoid an imminent threat to a person's life or to public safety. It may also use Personal Information for reasons related to law enforcement or internal investigations into unlawful activities.

2.6 Spreadsheet Advantage will not use Personal Information without taking reasonable steps to ensure that the information is accurate, complete and up to date.

3.1 Spreadsheet Advantage may Disclose Personal Information to related or unrelated third parties if consent has been obtained from the individual. This will include obtaining the individual's consent for Disclosures made under the credit reporting requirements of the Privacy Act of Australia.

3.2 Spreadsheet Advantage may Disclose Personal Information to related or unrelated third parties to enable outsourcing of functions (such as billing, customer relations management and order fulfillment), where that is Disclosure or use for a related Secondary Purpose and has been notified to individuals or where such Disclosure is within the individual's Reasonable Expectations. Spreadsheet Advantage will ensure that confidentiality agreements are in place specifically prohibiting these service providers from Using or Disclosing the Personal Information provided to them for any purpose other than the reason it was provided to them.

3.3 Spreadsheet Advantage may Disclose Personal Information to law enforcement agencies, government agencies, courts or external advisers where permitted or required by law.

3.4 Spreadsheet Advantage may Disclose Personal Information to avoid an imminent threat to a person's life or to public safety.

3.5 Spreadsheet Advantage will not Disclose Personal Information otherwise than in accordance with the exceptions set out at 3.1 to 3.4 above.

3.6 Spreadsheet Advantage does not generally sell or share its customer lists on a commercial basis with third parties but if it did, it would only do so if it had the appropriate consent of the individual involved. If the consent provided is conditional, Spreadsheet Advantage will take steps to ensure (by contract) that the use of its customer list by third parties does not exceed the scope of the consent.

5.1 Spreadsheet Advantage requires employees and contractors to perform their duties in a manner that is consistent with Spreadsheet Advantage’s legal responsibilities in relation to privacy.

5.2 Spreadsheet Advantage will take all reasonable steps to ensure that physical and electronic records containing Personal Information are stored in facilities that are only accessible by people within Spreadsheet Advantage who have a genuine "need to know" as well as "right to know".

5.3 Spreadsheet Advantage will review, on a regular and ongoing basis, its information security practices to ascertain how ongoing responsibilities can be achieved and maintained.

5.4 Spreadsheet Advantage will take reasonable steps to protect the Personal Information it holds from such risks as loss or unauthorised access, destruction, use, modification or Disclosure.

6.1 Spreadsheet Advantage will allow its records containing Personal Information to be accessed by the individual concerned in accordance with the Privacy Act of Australia. If Spreadsheet Advantage refuses access to the
individual’s Personal Information, it will provide the individual with written reasons for doing so.

6.2 Spreadsheet Advantage will correct its records containing Personal Information as soon as practically possible, at the request of the individual concerned in accordance with the Privacy Act of Australia.

6.3 Individuals wishing to lodge a request to access and/or correct their Personal Information should do so by contacting Spreadsheet Advantage at

6.4 Spreadsheet Advantage can charge a fee for processing an access request but will generally not do so unless the request is complex or is resource intensive.

7.1 Individuals wishing to make an inquiry or complaint regarding privacy should do so by contacting Spreadsheet Advantage at

7.2 The Spreadsheet Advantage website will contain a copy of this Spreadsheet Advantage Privacy Policy.

9.1 Spreadsheet Advantage will take reasonable steps to limit the amount of Personal Information it sends to unrelated organizations outside Australia.

9.2 If Personal Information about an individual must be sent by Spreadsheet Advantage outside Australia for sound business reasons, Spreadsheet Advantage will only do so if:

1. the organization receiving the information provides a binding undertaking that it will handle that information in accordance with the National Privacy Principles; or
2. the individual consents to the transfer of Personal Information.

Direct Marketing means the marketing of goods or services through means of communication including written, verbal or electronic means. The goods or services which are marketed may be those of Spreadsheet Advantage or those of an independent third party organization.

Disclosure generally means the release of information outside Spreadsheet Advantage, including under a contract to carry out an "outsourced function".

Spreadsheet Advantage means Spreadsheet Advantage Pty Ltd.

Personal Information means information or an opinion (including information or an opinion forming part of a database), whether true or not and whether recorded in a material form or not, about an individual whose identity is apparent, or can reasonably be ascertained from the information or opinion.

Primary Purpose is the dominant or fundamental reason for information being collected in a particular transaction.

Reasonable Expectation means a reasonable individual's expectation that their Personal Information might be used or Disclosed in certain ways, given the Primary Purpose.

Secondary Purpose is a purpose other the Primary Purpose for which Spreadsheet Advantage uses and Discloses the Personal Information it has collected.