Infrastructure Logic PTY Limited (Trading as OneWiFi)
(ABN 26159004065)

Privacy Policy
(Last updated 20 January 2019)

• Infrastructure Logic PTY Limited, and its related parties and associates (collectively Infrastructure Logic, we or us) are committed to protecting all personal information that we hold.
• This Privacy Policy (Policy) describes how we manage your personal information and safeguard your privacy specific to our website.
• Please read this Policy carefully. You can contact us via the contact details set out below with any questions about how we handle your personal information.
• Please note that as our business evolves, we may need to make changes to this Policy from time to time. We may notify you about changes to this Policy by posting an updated version on this website.  You should therefore check this Policy regularly.  You may also contact us via the contact details below, at any time, to request a current version of this Policy.

2. Australian Privacy Principles
   • Most private sector organisations in Australia are required to comply with the Australian Privacy Principles (APPs).
   • Infrastructure Logic is committed to implementing and maintaining suitable practices and procedures to ensure that it complies with the APPs and to enable it to deal with enquiries or complaints from individuals about Infrastructure Logic’s compliance with the APPs.

2. How do we Collect and Hold Personal Information?
   • Infrastructure Logic holds personal information collected from its existing and prospective shareholders, contractors, job applicants, employees, and individuals who deal with Infrastructure Logic in the course of Infrastructure Logic’s business activities, including without limitation individuals who provide products or services to Infrastructure Logic or sign-up to receive products or services from Infrastructure Logic and individuals who Infrastructure Logic engages with in order to perform services for or provide products to its clients and industry partners.
   • Without limitation, this may include personal information that is collected through the following means:
     • our websites (see Section 5 below for further details);
     • in the course of performing services for, or supplying products to, our clients;
     • social media;
     • use of mobile devices;
     • requests to sign-up to online products or services;
     • orders for products or services;
     • employment applications;
     • third party service providers;
     • requests for information, or to join a mailing list;
     • provision of customer service and support;
     • responses to surveys or research;
     • entries into competitions or trade promotions.
   • If you do not provide us with the information we request, we may not be able to fulfil the applicable purpose of collection, such as to supply products or services or assess your application for employment.
   • Infrastructure Logic collects personal information about individuals directly from the relevant individuals, unless it is unreasonable or impracticable to do so.
   • If practicable, Infrastructure Logic provides disclosure as required under the Privacy Act prior to, or at the time of, collection. Where this is not practicable, the disclosures are provided as soon as practicable after the time of collection.  Where Infrastructure Logic collects personal information about individuals from sources other than the individual themselves (for example, via Infrastructure Logic’s outsourced service providers), Infrastructure Logic takes reasonable steps to ensure that the individual has been made aware of matters covered by disclosures required under the Privacy Act.

2. What Kind of Personal Information Do We Collect and Hold?
   • The kind of personal information we collect and hold will depend upon the circumstances in which the information is collected, your relationship with us and/or the type of products and services you supply to, or request from, us.

2. Information Collected When You Use Our Website
   • We may collect some information from you when you use our websites.
   • This will include personal information that you submit to us via the websites. Examples might include, but are not limited to: when you complete an online form such as an application form or ask for a disclosure document for our products, when you register for a newsletter, leave feedback about a website or products or services supplied via a website, partake in a competition or complete a survey, make an enquiry or register to receive information on featured or special deals available through a website.
   • When you visit one of our websites, our server places small pieces of data known as “cookies” on your hard drive. Cookies are pieces of information that are transferred to your computer when you visit a website for record-keeping purposes.  Cookies collect information that includes the server your computer is logged onto, your browser type and how you gained entry to the website.  Therefore when you browse one of our websites information is recorded about that use, such as how you have used the website, the time and date of your access, the pages of the website that are accessed and the time spent on the website.
   • Most internet browsers are set to accept cookies. However, if you do not wish to receive any cookies you may set your internet browser to refuse to accept cookies.  This may mean that you will not be able to take full advantage of the products and services on the website.
   • We use cookies to provide us with aggregated, anonymous, information on how people use our websites and to help us to know what our customers find interesting and useful in our websites. We do not link this information back to other information that you have provided to us.
   • Our websites may contain links to third party websites. These linked sites are not under our control and we are not responsible for the content of those sites nor are those sites subject to this Policy.  Before disclosing your personal information on any other website we recommend that you examine the terms and conditions and privacy policy of the relevant site.  Infrastructure Logic is not responsible for any practices on linked websites that might breach your privacy.

2. What are the Purpose for Which We Collect, Hold, Use and Disclose Personal Information?
   • We will only collect personal information that is necessary for one or more of our functions or for a purpose disclosed to you in this Policy, or around the time of collection of your personal information.
   • Infrastructure Logic collects, holds, uses and discloses your personal information as required in order to perform its various roles as, amongst other things, a listed company, an employer, a service provider, a customer and an investor.
   • We collect, hold, use and disclose personal information for the purposes of running our business. Without limitation, this includes the following purposes:
     • to collect, hold, use and disclose shareholder information to assess applications for shares, provide information to (and respond to queries from) shareholders, keep proper company records and administer the company;
     • to collect, hold, use and disclose personal information from contractors, job applicants and employees to facilitate normal employment/contractor engagement and business management and human resources functions (noting that we will not use employment related information for direct marketing purposes, or disclose such information to clients or industry partners);
     • to process and assess employment applications;
     • to collect, hold, use and disclose personal information from individuals involved in Infrastructure Logic’s business in order to facilitate the relevant business activities;
     • to provide our products and services (including our online and mobile services);
     • to obtain products and services from our suppliers;
     • so that we can seek feedback or contact you in relation to our products and services;
     • to administer, and otherwise carry out obligations in relation to, and enforce, contracts to which we are party;
     • to undertake research and surveys and to create and analyse statistical information;
     • to conduct competitions and trade promotions;
     • to anticipate and resolve problems with our products and services;
     • to enhance our service offering;
     • to process and respond to enquiries and requests, improve our operations, and communicate with users about our products, services and businesses;
     • for legal purposes, including so that we can meet our legal obligations including compliance with any applicable law, regulation, governmental process or industry code;
     • investigating and/or cooperating with authorities in connection with legal issues, or security or law enforcement investigations; and
     • to undertake a merger, acquisition or sale of the whole or part of our business or assets or other corporate restructuring.

7. Direct Marketing
   • We may also use your personal information to help us develop other products and services and, with your consent or where otherwise permitted by law, to provide you with information about other products and services offered or distributed by Infrastructure Logic or to provide you with information, or permit our clients to provide you with information, about other products and services including by means of direct marketing.
   • If you are receiving promotional information from us and no longer wish to receive such information, you should contact the Infrastructure Logic Privacy Compliance Officer on (02) 9195 4197 or email to [email protected] during business hours or by using the unsubscribe facility that we include in our commercial electronic messages.
   • Infrastructure Logic, and our advertisers, may use information we collect from you and about you to help deliver relevant ads to you when you use our, or our clients’, websites.

7. How Might We Disclose Your Personal Information?
   • When Infrastructure Logic collects your personal information, it seeks to inform you of the categories of third parties to whom your personal information is likely to be disclosed either by the information provided in this Policy or otherwise.
   • We may disclose personal information to our related parties and affiliates.
   • Please note that we contract out some of our functions (for example, registry services, mailing, and hosting service providers) to external service providers. We also obtain products and services from a range of third party service providers, including without limitation professional advisors and financial institutions.
   • We may disclose your personal information to these third party service providers but only so that they can provide relevant products or services to us, or on our behalf, or process transactions you have requested us to transact on your behalf.
   • Infrastructure Logic seeks to ensure that providers of outsourced services and other third party service providers are subject to contractual provisions for the protection of personal information disclosed to them by Infrastructure Logic.
   • We work to deliver a range of information products and services to our clients and work together with a range of industry partners (including, without limitation venues, websites and other businesses that obtain our services to assist them to analyse consumer behaviour and engage with consumers, as well as advertisers and marketing companies). We may disclose personal information to such entities.
   • We may also disclose personal information to law enforcement bodies, courts, dispute resolution bodies, counterparties to disputes and otherwise in connection with legal processes.
   • In the event of a merger, acquisition or sale of the whole or part of our business or assets, or other corporate restructuring, we may disclose personal information as part of that transaction.
   • It is unlikely that personal information will be disclosed to overseas recipients. However, if and when personal information is collected in circumstances where such overseas disclosures are likely, Infrastructure Logic will, if practicable, outline the countries in which the overseas recipients are located.
   • Prior to the disclosure of personal information to a person overseas, we will take reasonable steps to ensure that such overseas third party undertakes to treat your personal information securely and to protect your personal information in a manner consistent with this Policy and the Australian Privacy Principles.

7. Data Security
   • We will use our reasonable endeavours to store your personal information securely and to secure it against unauthorised access.
   • In particular, Infrastructure Logic has taken steps to promote physical security, computer security, communications security and personnel security and staff have received appropriate training in dealing with individuals’ privacy.
   • Despite our reasonable endeavours, you should be aware that we are unable to guarantee the security of any personal information that is transmitted to us. Accordingly, if you transmit personal information to us this is at your own risk.
   • If we determine that personal information is no longer needed for any relevant purpose, we will take reasonable steps to destroy or permanently de-identify that personal information, unless we are required by law to retain it.

7. Contacting Us and Making Complaints
   • If you wish to contact us in relation to our privacy practices, our contact details are as follows:

Attention: Infrastructure Logic Privacy Compliance Officer
Telephone: (02) 9195 4197
In writing: Infrastructure Logic Privacy Compliance Officer, Infrastructure Logic PTY Limited, Suite 1603, Level 16, 115 Pitt St, Sydney NSW 2000
Email: [email protected]

• If you wish to make a complaint about our privacy practices or a breach of Australian privacy laws (including the APPs or any applicable registered APP code) you may contact us using the contact details set out above. We will seek to respond to your complaint as soon as possible.
• If you are not satisfied with how we resolve a complaint that you have raised, you may contact the Office of the Australian Information Commissioner.

11. Further Information on Privacy
    • You may obtain further information regarding privacy issues in Australia by visiting the Australian Office of the Information Commissioner’s website at www.oaic.gov.au.