Last updated: [1 June 2017]

In this Privacy Policy, a reference to:

• Objective, we, us or our means Objective Corporation Limited (ABN 16050539350) of Level 30, 177 Pacific Hwy, North Sydney, NSW, 2060, Australia, and any of its affiliates;
• You or yourmeans the person whose information may be collected and dealt with under this Privacy Policy;
• User means any person who uses our Services; and
• Services means our website (http://www.objective.com) and our Objective software solutions and services.

We take our privacy obligations seriously and have prepared this Privacy Policy to explain how we collect, hold, use and disclose information about identified, or reasonably identifiable, individuals (‘Personal Information’). It is intended to ensure the open and transparent management of your Personal Information. If you are unable to properly view or print the Privacy Policy from your web browser, we will send you a copy by regular post if you request that from our Privacy Officer. The contact details appear at the end of this Privacy Policy.

We may update this Privacy Policy from time to time and the most current version will be posted on our website. We encourage you to regularly review the Objective Privacy Policy. If we make any material changes to this Privacy Policy, we will provide notice of the revised policy on our website and, depending on the nature of the changes, may seek additional consents from you or give you the option to delete your Personal Information. Your use of any of the Services after the posting of any changes to this Privacy Policy will constitute your consent to such changes.

If you use any Services as part of an entity or organisation that has an contract with Objective (like your employer or university), the terms of that contract for the Services may restrict our collection or use of your Personal Information to a greater extent than described in this Privacy Policy.

If you have any questions or concerns about our Privacy Policy, or with the handling of your Personal Information, you can contact our Privacy Officer at the address detailed below or email your query to us via www.objective.com/about.

We collect information relating to you and your use of our Services from a variety of sources, but always do so fairly and only to the extent permitted by law. Some of this information is collected directly from you, some from your use of our Services and some from third parties. We collect Personal Information from you unless it is unreasonable or impractical to do so.

Personal Information we collect directly from you is the information that you voluntarily supply to us, which may include your name and contact details when you contact us, subscribe to our Services or apply for a job; your account details including passwords, billing details such as credit card information and personal account settings such as preferences or profiles (for example, preferred language or time zone); survey data (your answers to questions); information about the device you are using to access the Services and any other data that you directly submit to us, for example, by entering competitions or providing reviews.We only collect information that is reasonably necessary for our functions and activities, including supplying you with the Services.

If you apply for a position with us, we may also collect your employment-related information, employment history, education and qualifications.We will generally collect the information from you but may also collect information from employment agencies, your referees, and your former employers and educational institutions.

Information we collect from other sources includes:

• Data from third parties, but only if those third parties are lawfully permitted to share your information with us.
• Any external source, if you came to our website via a link on another website or an email.We record information about the source that referred you to us.
• Personal Information from social media sites, for example, if you send us a tweet on Twitter.
• Usage data about what you do when you access our Services. This may include which web pages you visit, what you click on and when.Our web servers also collect data from the device you use to access our Services, such as your IP address and possibly your location.The servers keep log files that record data each time a device accesses our servers.

We use various technologies to obtain usage data, including:

• Cookies and similar commonly-used information gathering tools which are small files placed on the User’s hard drive during a visit to a website to allow fast, easy and meaningful navigation around the site.These technologies may be used by us or our service providers to analyse and track how Users use our websites.Standing alone, cookies do not identify you, they only recognise your browser. When you give us information, we can also send cookies to remember Users’ settings and preferences.Objective uses both session-only and permanent cookies, often depending on whether the use is casual or a more complex interaction (such as by a subscriber).
• Local Storage, such as HTML5, to store user preferences. Third parties who provide advertising on our websites can personalise advertising based on your web browsing activity by using Flash cookies and HTML5 to collect and store information.We do not disclose your identity to advertisers, but the Flash cookies remember which browsers have visited the websites.
• Web beacons, which are often used in marketing emails to notify Objective when you click on a link in the email that directs you to one of Objective’s websites.

• Social media features, such as the Facebook “Like” button, which may collect your IP address, detect which page you are visiting on our website, and set a cookie.

You should be aware that your use of social media via our websites or via links to other websites is governed by the privacy policies of the third parties who operate those websites and not this Privacy Policy. We therefore recommend that you read the privacy policy of any website you visit.Objective does not review, approve or make any representations or warranties in relation to the privacy practices of any third party website and we are not responsible for the privacy policies or the content of any third party website.

Objective may provide publicly accessible bulletin boards, blogs or community forums on Objective’s websites.Any information that you choose to provide in these forums may be read, collected or used by others who visit these forums, including to send you unsolicited messages. Objective has no control over the collection, use and disclosure by third parties of Personal Information which you may choose to submit in these forums.

If you provide a testimonial to be displayed on an Objective website, it may include information such as name and title.Objective will always obtain your consent prior to posting any testimonial.

If you provide us with unsolicited Personal Information which is not lawful for us to collect we will, as soon as practical, destroy that information.

If you do not provide us with the Personal Information described above, some or all of the following may happen:

• we may not be able to provide Services to you, either to the same standard or at all;
• we may not be able to provide you with information about our Services that you may want, including information about special promotions;
• we may be unable to tailor the content of our websites to your preferences and your experience of our websites may not be as enjoyable or useful; or
• if you are applying for a position with us, we may be unable to consider your application.

While Objective will not be able to provide you with a personalised experience if we cannot recognise you, we want you to be aware that various applications are available and other steps can be taken to limit tracking.

If it is lawful and practical, you may choose to not identify yourself when contacting us, or to use a pseudonym. In some cases, however, if you do not provide us with this information, we may not be able to provide you with our Services, or respond adequately to you. Our website can be accessed anonymously.Many companies offer applications that help you to visit web sites anonymously.

Various browsers, including Internet Explorer, Firefox and Safari, offer a “do not track” (‘DNT’) option that relies on a technology known as a DNT header which sends a signal to websites you visit about your DNT preferences, but you should be aware that there is no common industry standard for DNT or any consistent standard of interpreting user intent.Accordingly, DNT preferences may not always be effective.

Your web browser may be set to accept cookies automatically, but can be changed to decline them.Please note that if you decline to accept cookies, this may mean that you may not be able to take full advantage of our Services. Your browser may also offer the ability to disable HTML5, and Flash cookies can be managed using various tools available on the internet.Objective makes no representations or warranties in relation to these tools.

Further information about opting out of third party tracking can be found on numerous websites, including: http://www.youronlinechoices.com.au/opt-out/.

Security

It is important to us to keep your Personal Information private and confidential. We take all reasonable steps to ensure that your information is handled securely and in accordance with this Privacy Policy and the generally accepted practices for security of data.

Objective holds the Personal Information that it collects on systems that are owned or controlled by Objective and kept in a controlled environment with limited access. We maintain physical, electronic and administrative safeguards to protect Personal Information from loss, misuse, unauthorised access, disclosure or alteration. However, no transmission over the internet is 100% secure and, although we do our best to protect your Personal Information, we cannot completely guarantee the security of any information transmitted over the internet.

You can assist our security measures by using a complex password for logging in to our Services, and keeping that password secret.If you suspect there has been any unauthorised access or misuse of your Personal Information, please contact us immediately.Our contact details appear at the end of this Privacy Policy.

Retention

The period which Objective keeps Personal Information varies according to the nature and use of the information.In some cases, there are legal requirements to keep Personal Information for a minimum period, for example if it forms part of a Commonwealth record, must be retained by court or tribunal order or where Objective is under a contractual obligation to retain it.If there is no such legal requirement, Objective will only keep the Personal Information for so long as it is necessary for the purposes for which it was collected, or as expressly consented.If we no longer need your Personal Information, we will destroy or de-identify it.

If you apply for a position with us, and if your application is not successful in the first instance, we may retain your personal information for a limited period so that we can consider you for other positions that may become available.

We use your Personal Information for a variety of purposes, depending on the nature of the information, but always only if reasonably necessary for our business, including providing you with the Services you would expect from us.We will not use or disclose the Personal Information for a secondary purpose unless we are allowed to do so by law, you have consented to that use or disclosure, or we are legally compelled to so disclose it.

We generally use your Personal Information to:

• Allow you to create an account and log in, in order to obtain access to and use the Services and customer support.
• Contact you about your account via email, mail or telephone to tell you about certain things, such as changes to our Services or policies.
• Send you news and information (including direct marketing) about our Services that you either request from us, or we believe may interest you and you consent to us sending you these communications. You may choose to stop receiving our newsletter or marketing emails by following the unsubscribe or opt out instructions included in those emails.
• Internally analyse user behaviour so we can improve our Services. Some of these activities include monitoring, maintaining and improving our Services and features, personalising your experience, creating new services or features, preventing undesirable or potentially illegal activities and investigating any complaints about or by you.
• Evaluate your application if you have applied for a position with us.

We will share your Personal Information with third parties only in the ways that are described in this Privacy Policy or with your consent. To provide you with our Services we will usually need to disclose your Personal Information to our staff and external service providers. Service providers are only authorised to use your Personal Information as necessary to provide services to us. However, there may be occasions where we may need to disclose your Personal Information to other people or organisations, including to:

• Affiliates or associates of Objective including investors or subsidiaries, as the need to disclose may arise from a legal obligation we owe that entity.
• Sponsors and promoters when you enter any competition that we conduct or promote.
• Regulators, law enforcement agencies or other organisations that may need to be notified of or protected against fraudulent activities, or if you engage in or threaten any unlawful activity.In those circumstances, we may reasonably conclude that it is necessary to disclose your Personal Information to government agencies, your internet service provider, your employer or any other organisation. We may also be compelled by subpoena to disclose your Personal Information to a court.
• The Australian Stock Exchange due to Objective’s status as a listed company or during merger activitiesin the event of a sale of all or a portion of Objective’s assets.
• Your referees, former employers if you have applied for a position with us.

Your Personal Information is held on our secure computer systems whigh are primarily located in Australia. However, in order to provide our services to our customers we sometimes use staff located in our overseas offices and service providers located outside Australia. Overseas staff are mainly located in the United Kingdom and New Zealand.

There may be times when your Personal Information is transferred to or accessed by our affiliates or service providers in those countries or the USA (or other countries from time to time to help us to provide our services (e.g. providing software support services to our customers).

We take reasonable steps to ensure that the overseas recipients of your Personal Information do not breach the privacy obligations relating to your Personal Information.

We make all reasonable efforts to ensure that your Personal Information is accurate, up to date and complete.You can update your information at any time via the account settings page or through your profile.You may also contact us to request access to the Person Information that we hold about you and request us to correct, update or delete your information. We may charge you a fee to cover our administrative and other reasonable costs in providing the information to you.We will not charge for simply making the request and will not charge for making any corrections to your Personal Information.

There may be instances where we cannot grant you access to the Personal Information we hold.For example, we may need to refuse access if it would interfere with the privacy of others or if it would result in a breach of confidentiality.If that happens, we will notify you in writing.

You may choose to change access to, or limit the use or disclosure of your Personal Information by contacting us. However, please be aware that by limiting the use of your Personal Information by us, or its disclosure to third parties, you may also limit our ability to provide you with our Services.

Objective holds information (including Personal Information) on behalf of its customers (Customer Data).The scope and nature of Customer Data is determined solely by our customer and we do not ordinarily use that Personal Information for our own purposes. The use of Customer Data is governed by the contract with our customer.

Although Objective requires its customers to comply with the Privacy Act 1988 (Cth), it does not review, monitor or have any control over Customer Data or the way in which our customer uses this data.As such, Objective bears no responsibility in respect of any Personal Information which may form part of Customer Data, except as provided by law or as set out in the contract between Objective and its customer.If you have any concerns about the way in which an Objective customer is handling your Personal Information, you should contact that customer directly.

Objective does not sell its Services to children and our websites are designed for adult Users. We do not knowingly collect Personal Information from children. If you become aware that an individual under the age of 13 has provided us with Personal Information, please contact us at privacy@objective.com. If we become aware that a child under 13 has provided us with Personal Information, we will take steps to delete such information.

Please contact our Privacy Officer at the below addresses if you believe your privacy has been breached or if you have any complaints about our compliance with this Privacy Policy, any applicable international privacy frameworks or the Australian Privacy Act 1988 (Cth). Objective will investigate and attempt to resolve complaints and disputes regarding use and disclosure of Personal Information by reference to the principles outlined in this Privacy Policy.

We request that complaints be made in writing. Our Privacy Officer deals with complaints and any complaints should be directed to our Privacy Officer at the contact details below. We will attempt to confirm, as appropriate and necessary, with you your understanding of the complaint and what you expect as an outcome. We will let you know whether we will conduct an investigation, the details of the person investigating and the estimated completion date. After we have completed our enquiries, we will contact you to advise you of the outcome and invite your response to our conclusions. If we receive a response from you, we will take this into consideration and let you know if we have changed our view.

If you are dissatisfied with our handling of any complaint made by you about our compliance with this Privacy Policy and you are located in Australia, you may complain to the Office of the Australian Information Commissioner by contacting them at:http://www.oaic.gov.au/about-us/contact-us-page.

For disputes involving User’s Personal Information that has been received from the European Union and the dispute cannot be resolved by Objective, the matter should be referred to the Data Protection Authority of the relevant EU country.

Objective Privacy Officer Contact:

Email: privacy@objective.com

Mail:
General Counsel
Objective Corporation Limited
Level 30, 177 Pacific Hwy
NORTH SYDNEY NSW 2060
AUSTRALIA