This Privacy Policy sets out SouthFreo's general policy in relation to our privacy obligations to you and our management of personal information collected, used or disclosed as a result of your use of the SouthFreo web site.

At SouthFreo software, protecting your privacy and the confidentiality of your "personal information" is very important to us and is fundamental to the way we serve you.

Personal information means information or an opinion (including information or an opinion forming part of a database) we hold about you from which we can determine your identity. For example, we may collect and use your name and address details when you acquire or use particular SouthFreo products or services. Collecting and using this personal information ensures we can deliver our services to you as efficiently as possible.

At SouthFreo, we know that giving your personal information to us imposes a serious responsibility upon us.

We are committed to protecting your personal information. Where your personal information may be disclosed, and to the extent that we can, we believe in giving you a choice as to whom we may disclose your personal information, who may use your personal information and how that personal information may be used.

How we collect your personal information

Generally, SouthFreo will collect personal information directly from you, and only to the extent necessary to provide a SouthFreo product or service, including our "agency" functions, or to carry out our internal administrative operations. For example, we may collect personal information from you when you fill in an application form, deal with us over the telephone, ask us to contact you after visiting our web site or have contact with us in person. An "agency" function means a service that we provide to you on behalf of another organisation. Examples of this are SouthFreo Hosting services.We will collect personal information from you by lawful and fair means and not in an unreasonably intrusive way. The type of personal information we may collect from you generally comprises name, address, age group, gender, contact details (including phone, fax and e-mail) and information collected as a result of you using or acquiring particular SouthFreo products or services. By using southfreo software such as iiQuota and sending usage information, we may also collect information related to internet or ISP usage.

How we use and disclose your personal information

Generally, we collect your personal information in order to provide you with, or give you access to, a particular SouthFreo product or service.The personal information we collect from you ultimately allows us to provide you with better customer service. We may also use or disclose your personal information for purposes related or ancillary to the main purpose for which we collect it and where such use or disclosure would be reasonably expected by you. Some examples are:

1. •Helping us to build a relationship with you
   

2. •Internal accounting and administration
   

3. •Regulatory reporting and compliance
   

4. •Protecting you and SouthFreo from fraud
   

Helping us to identify and inform you about other SouthFreo Products and services that may be of benefit to you. Also, we sometimes outsource some of our internal functions and activities to other companies. In the course of doing this, we may disclose your personal information, such as name and address details, to enable the service provider to undertake that particular function. Our Privacy Policy requires that confidentiality agreements be in place specifically prohibiting these service providers from using or disclosing your personal information for any purpose other than the reason it was provided to them.

Occasionally, we may also collect, use or disclose your personal information for the secondary purpose of facilitating the distribution of marketing materials to you by SouthFreo or a third party. We will not do this if you ask us not to do so. There are other situations where we are compelled by law to disclose your personal information. For instance, under certain circumstances we may be compelled to provide your personal information to law enforcement agencies or the Australian Taxation Office.

Our duty of confidentiality and your consent

We have a duty to keep confidential all personal information we hold about you. Generally, our duty of confidentiality applies except where disclosure of your personal information is:

1. •compelled by law
   For example, disclosure to various government departments and agencies such as the Australian Taxation Office, and disclosure to courts under subpoena.
   

2. •in the public interest
   For example, where a crime, fraud or misdemeanour is committed or suspected, and disclosure against the customer's rights to confidentiality is justified.
   

3. •with your consent
   

Your consent is important to us. Your consent may be implied or express and it may also be verbal or written.You imply consent where we may reasonably conclude that you have given consent by the actions you take or do not take. For example, where you acquire or use a SouthFreo product, service or agency function, you consent to SouthFreo storing, using, maintaining and disclosing your personal information to the extent necessary for us to provide that particular SouthFreo product or service to you.

If you do not consent to certain uses of your personal information we may not be able to provide that particular SouthFreo product or service to you.

We reserve the right to make changes to the SouthFreo Privacy Policy and this Privacy Statement from time to time or as required by law.

Direct marketing and your privacy

From time to time we may use the personal information we collect from you to identify particular SouthFreo products and services which we believe may be of interest and benefit to you. We may then contact you to let you know about these products and services and how they may benefit you.

If you do not wish to receive direct marketing information from SouthFreo, please tell us. Please note however that your instructions to one part of our business may take a little time to flow through to the rest of SouthFreo.

Quality, accuracy and correction of your personal information

If we have accurate personal information about you, it enables us to provide you with the best possible service. SouthFreo takes reasonable steps to ensure the personal information we collect, use and disclose is accurate, complete and up-to-date. If you find that the personal information we hold about you is inaccurate, incomplete or out-of-date, please contact us immediately and we will take reasonable steps to ensure it is corrected. Where SouthFreo does not agree with your view about the accuracy of the information and if you ask us to do so, we will take reasonable steps to note your claim where that information is stored and accessed.

Security of your personal information

SouthFreo takes reasonable steps to protect your personal information from loss, misuse, unauthorised disclosure or destruction. SouthFreo has in place generally accepted standards of technology and operational security in order to keep your personal information safe.

Web site security and privacy

The internet has dramatically changed the way we do business. It allows SouthFreo to provide our products and services to you from the convenience of your own home or office.

We understand that you may be concerned about the confidentiality and security of the personal information we collect from you online. Accordingly, we have systems in place to ensure our online dealings with you are as secure and confidential as your dealings with us in person, or on the telephone.

www.southfreo.com WebSite

The type of personal information we collect on our website depends on how you make use of the site.

When you visit the site, our host, records your server address, domain name, the date and time of the visit and the pages viewed. This information may be collected by using cookies (data sent to your web browser, which generally allows our site to interact more efficiently with your computer). If you disable the use of cookies, your use of our site may be affected. Information collected about your visit to our site is retained for statistical and website development reasons and is not in a form which would enable us to identify you.

When visiting our site, you will not be required to provide us with any personal information unless you decide to participate (for example commenting on a blog entry or sending an email). The information provided may also be retained for product planning purposes, and unless you tell us that you don’t want it used for direct marketing purposes, may be used for those purposes.

Links to other sites

The SouthFreo site contains links to other sites. In addition, some of the content appearing on the SouthFreo web site may be supplied by third parties, for example, by framing third party web sites or the incorporation through "framesets" of content supplied by third party servers.

While SouthFreo will always endeavour to engage in business arrangements with commercial entities of good repute and ethical business practices, we are ultimately not responsible for the privacy practices or the content of such web sites. However, our contractual arrangements with these parties seek to ensure that an equivalent level of privacy protection is afforded to you. We encourage you to read and understand the privacy policies on those web sites prior to providing any information to them.

Access to your personal information

SouthFreo will, upon your request, and subject to applicable privacy laws, provide you with access to your personal information held by us. However, we ask that you identify, as clearly as possible, the type/s of information requested.

SouthFreo will deal with your request to provide access to your personal information in a reasonable time - usually within 30 days of receipt of your request.

We will not charge you for lodging such a request but we may recover from you our reasonable costs incurred in supplying you with access to this information.

In certain circumstances, the law permits us to refuse your request to provide you with access to your personal information. Factors affecting your right to access include where:

1. •access would pose a serious threat to the life or health of any individual
   

2. •access would have an unreasonable impact on the privacy of others
   

3. •the request is frivolous or vexatious
   

4. •the information relates to a commercially sensitive decision making process
   

5. •access would be unlawful, or
   

6. •access may prejudice enforcement activities, a security function or commercial negotiations.
   

Further information on privacy

Should you require more specific details concerning our privacy practices please contact us directly.

Or you can obtain further general information about privacy protection from the Office of the Federal Privacy Commissioner by:

1. •calling their Privacy Hotline on 1300 363 992, or
   

2. •visiting their web site at www.privacy.gov.au, or
   

3. •by writing to:
   The Federal Privacy Commissioner
   GPO Box 5218
   Sydney NSW 1042