August 2003

Introduction

Please read this Privacy Policy carefully. Together with the Service Agreement, Acceptable Use Policy, and Payment Policy, they govern your use of the iAppraise web application (referred to in this document as the 'Service').

Failing to comply with these or any other policies made available to you from time to time by iComply Pty Ltd, or interfering with any other person's use and enjoyment of the Service or any other online service, may result in termination of your account.

Our commitment to you

The relationship between iComply Pty Ltd and our customers is the most important asset of our business. We strive to maintain your trust and confidence in our company, an essential aspect of which is our commitment to protect your personal information to the best of our ability. We believe that you value your privacy, so we will not disclose your personal information to anyone unless it is required by law, at your direction, or is permitted by law and necessary to provide you with our services.

Changes to our Privacy Policy

Any future changes to our Privacy Policy will be communicated to subscribers by email or through other means, prior to the changes coming into effect.

We collect data to help us operate iAppraise

When customers decide to use the Service, they register by creating a subscription account. As part of the registration process, customers must provide their business details such as name, identification numbers, address, telephone number(s), and contact personnel details.

At no time will iAppraise collect or store any information relating to users’ credit card information

Once a subscription account has been created, iAppraise automatically provides you with a User Name and Password that you must use to access and receive the Service. This is confirmed to you by email. To ensure that the highest level of security is maintained, we require that this user name and password be changed before allowing full access to the Service. Subscription details and the User name and password are retained in the iAppraise database. In addition to Subscription Account information obtained from our subscribers (as discussed below), we also collect information relating to how you use the Service (including, for example, information relating to your frequency of use, navigational information such as the uniform resource locator (URL) of the (iAppraise) Web pages you use, configuration information such as the type of Web browser you are using, your Internet Protocol (IP) address, processor type, operating system, and information relating to the length of time you use the Service.)

In the course of operating the Service, iComply Pty Ltd may sometimes use standard industry techniques to collect information about use of the Service (for example, how often subscribers use a certain part of the Service). However, we never provide third parties with information about subscriber usage characteristics in conjunction with information that might identify you.

To help potential partners understand how subscribers use our Service, we may share certain information about our Service with them. This information is normally disclosed in the aggregate, meaning that information from many subscribers is grouped together, and is disclosed in a way that does not reveal the identity of any particular subscriber.

We keep confidential any personal information that might identify you

We have not and will not sell your personal information to anyone, and we will not use any personal information collected on the Site in a manner different from that stated at the time the information is collected, without first notifying you by e-mail (at which time we would also notify you of how you can "opt out" of such use).

Some of the information we collect from subscribers could identify them personally. Such "Identifier Information" includes a person's name, business name and address, e-mail address, and business telephone numbers. We will not share any subscriber’s Identifier Information with a third party without that subscriber's consent (except as required or requested by law, regulation or governmental authority or during emergencies when we believe physical safety is at risk, or as set forth in this Privacy Policy).

We will never use any "Identifier Information" subscribers provide for purposes unrelated to the services provided, unless we notify you in advance and give you the opportunity to choose not to provide such information to us. When you provide "Identifier Information" to us as part of the Service, you will always have the opportunity to review, correct or update it through the Service, or by contacting us.

Links to other sites

We have various hyper-links displayed as part of the Service and these hyperlinked websites are not controlled by iComply Pty Ltd. These sites may send their own cookies to users, collect data, or solicit personal information. These websites have their own policies regarding privacy. You should review those policies before visiting their websites. We have no responsibility for linked websites, and we provide these links solely for the convenience and information of our subscribers. When we use third parties to perform business functions for us, we require them to treat your information confidentially

From time to time, we may form relationships with selected third parties to perform functions on our behalf such as (but not limited to) the provision of customer service and technical support to our subscribers, the processing of credit card charges for billing purposes, and the targeting and distribution of advertisements over the Service. We may disclose information about our subscribers (including Identifier Information) to such third parties in order to facilitate their performance of their functions, provided that the parties in question agree to use the confidential information with which we entrust them only for the express purpose of completing iComply Pty Ltd business, and agree not to release this information to anyone else.

We take care to maintain the security of your information

All information provided to us by our subscribers is stored on secure computers, where it is made available only to iComply Pty Ltd staff members or representatives who need it to perform their work. (For example, it may be necessary for iComply Pty Ltd staff members or representatives to examine system operational and accounting logs and other records to resolve service-related problems.) If we need to share any of your "Identifier Information" with any company performing services for us, that company must agree to confidentiality restrictions and security measures to safeguard such information.

Our Web site does not use "cookie" technology in ways that compromise your privacy.

We use a feature of your Web browser called "cookies" to automate certain aspects of our Services. Cookies are very small files that are stored on your computer and that assist us to provide the Service more efficiently. By using cookies, we can temporarily store data used during certain parts of the service. We do not use cookies to enable us to identify you or your computer, or to keep track of your preferences, what you have already seen on our site and what you haven't, or to keep details of any personalization you've done. We do not use cookies in any way that would disclose your Identifier Information to a third party without your consent.

Please be aware that other companies may collect various types of information about you and have different privacy policies and practices.

iComply Pty Ltd takes great care to ensure its subscribers’ privacy - but not every company has comparable policies. iComply Pty Ltd cannot assume any responsibility for any other site's content or practices.

Providers of Internet sites or services have separate data and privacy practices independent of iComply Pty Ltd that govern the manner in which they use the information that you provide to them. Many Web sites use cookies to recognize you when you return to their site; some sites require that you provide information before they allow you to enter; some automatically gather information when you visit, such as what operating system your computer runs, what type of Web browser you use, what Internet access provider you use, or what other Web pages you visit; and sites vary greatly (from each other and from iComply Pty Ltd) with regard to how they use such information and to whom they disclose it. We encourage you to read third parties' privacy policies, and to exercise care each time you are asked to provide personal information at a site whose privacy policies you don't know.

Even within the iAppraise application, some of the features and content may be supplied by third parties (or jointly by iComply Pty Ltd and one or more third parties), each of which has its own privacy policies and practices, and the Site may link to some pages provided by third parties that are "co-branded" by iComply Pty Ltd and the provider. You may be asked to provide personal information when you register for certain services or promotions advertised to you as part of the Service; in such cases, the information you provide may be collected and used by a third party rather than, or in addition to, iComply Pty Ltd. Our policy requires such third parties to notify you in advance if they intend to use information you provide for purposes unrelated to the services or promotions for which you sign up, and to give you the opportunity to choose not to use their service rather than share your information with them, but we cannot assume responsibility for their compliance with our policy.

We may in the future engage third parties to serve advertisements to appear on the Service. These companies may use cookies to ensure you do not see the same advertisements too often, and these cookies also may collect information about you when you view or click on an advertisement. Such ad-serving companies are responsible for placing and reading these cookies; we do not have access to these cookies or control how they are used. In the event that we do include such services, we will provide to Subscribers appropriate information about such companies and their privacy policies.

We will not intentionally monitor or disclose any private e-mail message or online communication, although we reserve the right to monitor accounts that are believed to be acting in violation of the Service Agreement, Payment or Acceptable Use Policies, or any applicable law or regulation; to protect the integrity of our Service or the Internet community as a whole; or pursuant to request of governmental or legal authority.

You can change your Subscription account details at any time

If you want to update or correct the information in your Subscription account, just select the “Account Administration” item from the “Administration” menu that appears on every screen, make the required changes and save them. Any changes you make will be visible immediately.

iComply Pty Ltd may keep your Subscription information and other information provided by you or relating to your use of the Service for record keeping, dispute resolution or auditing purposes, to send you offers we feel may be of interest to you, or in order to comply with requests from governmental or legal authorities.

When you are ready to share your personal information, you have several ways you can give your consent.

There may be times when you do want to share personal information with an advertiser or other third party. For example, if you see an advertisement for a product that interests you, you might wish to receive more information about that product by mail - or you may want to purchase the product immediately. You might want to sign up to get e-mail on a certain topic. Or you might decide to register for a service that requires you to share some information about yourself during the registration process.

We will pass your personal information along to a third party only with your consent, and there are a number of ways in which you can give such consent. By way of example, we might obtain such consent by asking whether you are willing to have your Identifier Information disclosed to an advertiser or other third party, or by asking whether you object to the disclosure of such Identifier Information to an advertiser or other third party.

If we notify you before you give us certain information (during the account creation process or at any other time) that we intend to share the information with a third party, and following such notification you choose to provide the information, we will assume that you consent to our sharing it with the third party as stated. And if you choose to buy goods or services through the Service, we will assume that you consent to our sharing some or all of your Identifier Information with the company selling, providing, or shipping to your address the goods or services you buy.

SECURITY OF INFORMATION

iComply Pty Ltd and its service providers, including hosted web service suppliers, have security measures in place to safeguard your information.

Although many precautions are taken to protect the systems and servers used, we cannot guarantee the security of any data on any server, including "secure servers."

Your subscriber account information is password and permission protected so that only authorized users of the subscription access to this personal information.

We strongly recommend that you, and any other users authorized to access the iAppraise application, do not divulge your password to anyone, and that you change your password regularly. iComply Pty Ltd will never ask you for your password in an unsolicited phone call or in an unsolicited e-mail. When you log on to iAppraise, the User Name and Password used to gain access is encrypted. Encryption is the process of converting information into a scrambled code while it is being transmitted and then decrypting the information back to plain text at the receiving end of the transmission.

If you have any questions about any of our policies, please contact us at:

iComply Pty Ltd
P O Box 3313
Wheelers Hill
Victoria 3150
Australia