We diligently protect both your privacy and your personal data.

We are committed to your privacy and guard your data carefully.

The online environment provides unprecedented access to information, but the convergence of communication and information technologies also brings a range of information privacy issues to the centre of public concern.

To ensure your privacy, we have appointed a Privacy Officer to monitor our compliance with the various privacy obligations imposed by law, as well as those that we voluntarily take on. We fully comply with best practice standards recommended by the Internet Industry Association (IIA).

The Privacy Officer reports to our General Counsel. Should you have any questions or complaints about privacy issues, please contact the Privacy Officer at privacy@tpcomm.com.au .

TPComm Obligations

TPComm Internet as a provider of a range of internet services, has many obligations in relation to the protection of your privacy under various Federal Government Acts of Parliament, including the Telecommunications Act 1997. For more information on our obligations with your personal particulars, visit the Australian Privacy Commissioner's website at http://www.privacy.gov.au .

TPComm has voluntarily subscribed to the Telecommunications Industry Ombudsman (TIO). For more information see http://www.tio.com.au and http://www.tio.com.au/policies/jurisdiction.htm .

What Information Do We Collect?

TPComm collects information about you at different times. Instances include:

1. Personal Information
1. needed for us to provide a service to you - you must provide this information in order to receive the TPComm Service;
2. used to inform you of TPComm products and services and/or improve your online service;
3. provided voluntarily by you for TPComm surveys, at TPComm sites, and in conjunction with third party offers;
4. available from public sources of information

1. Non-personally identifiable Information (specific or aggregated):
1. used to inform you of products and services and/or to improve your online experience;
2. used for product and market research purposes.

TPComm may use this information for a number of purposes including to verify your identity, assist you to subscribe to our services, to provide the services to you, to administer and manage the service provided, to research and develop our services and (with your continuing consent) to promote and market our services to you.

Personal Information Collected

• To provide the TPComm service to you
  
  Personal information collected and held by TPComm may include your name, date of birth, current and previous addresses, telephone/mobile phone number, email address, bank account or credit card details, occupation, driver's licence number and your TPComm username and password. We also hold details of your Service. If you choose not to provide us with certain personal information (e.g your date of birth), we may not be able to provide you with the Service.
  
  Subject to this Policy and specifically the section "How we may use your personal information" we will not disclose this personal information unless we have received your express consent to do so. The only exception to this is if it is required by law, that is, to answer a subpoena, warrant or in response to other legal processes including requests from agencies or organisations that are authorised by or under law.
  
• To inform you of TPComm products and services and/or improve your online experience.
  
  Other personal information collected may include demographic, internet usage, expenditure information and whether emails TPComm forwards to you are opened or not. This information is collected so that we can tailor specific marketing or support communications either to individuals, or to a group of TPComm customers with similar characteristics. The communications could concern TPComm products or services, or products and services provided by our business partners. These specific messages might be delivered to you by phone, letter or email.
  
  We do not track and store specific websites visited for individual customers unless required to by law.
  
• Voluntarily provided by you
  
  From time to time we may contact you and ask you to participate in surveys designed to improve our services and ensure that we are meeting our customers' needs. Such information may be used for product development, market research or customer service purposes. If you ever volunteer to be involved with a customer base survey, we use the information collected only to improve the TPComm online experience. These surveys are strictly confidential.

Non-personally identifiable information collected

TPComm may from time to time gather information that does not personally identify you which is collected and used to monitor and improve TPComm's Service as well as assist in tailoring specific messages to an unknown audience. For example:

• When you visit a web page the URL requested is automatically recorded, as is the time and date requested, and the browser software being used;
• a different banner advertisement may be presented to Broadband customers than Dial customers based on IP address; and

How We May Use Your Personal Information

In order to provide our services TPComm must use your personal information in a number of ways including disclosing it to other organisations outside TPComm in relation to TPComm providing our services to you.

These organisations may assist us with:

• customer service issues;
• mailing operations and the interaction of our customers and emails;
• billing and debt recovery actions;
• marketing and market research services;
• web site usage analysis.

All of these organisations are bound by confidentiality and privacy obligations in relation to your personal information.

We may also disclose your personal information to:

• anyone you authorise us to;
• credit reporting and law enforcement agencies;
• related companies and professional advisors;
• government and regulatory authorities and other organisations as authorised by law;
• in the event of a transfer/sale of all or part of our assets or business.

What Are "Cookies"?

A cookie is a message from a web server to your web browser, which is stored for later use. It means that when you visit the web site again, your browser recognises your preferences for that site. Cookies generally enhance your Internet experience, but if you don't want to receive them you can set your browser to alert you when one is being sent. You then have the option of accepting or rejecting that cookie.

Third Party Offers and Subscriptions at the TPComm Site

From time to time TPComm may form relationships with other organisations to bring you special offers, competitions and subscriptions. For any third party offer or subscription, we require as a matter of policy that the third party clearly states their intentions with any information gathered, and attaches their privacy policy as a hyperlink to the offer or subscription.

The terms and conditions of the offer should also be clearly stated.

Please read this information carefully, and understand that it is your own choice should you choose to disclose your personally identifiable information to the third party. The information that you offer to the third party is voluntary.

How To Access, Correct or Update your Personal Information at TPComm

Only authorised persons have access to your personal information, which we keep in a secure environment. We realise it is important for you to be able to control your personal details.

If you call TPComm by telephone, before any customer personal information is revealed or discussed you must correctly answer the verification of identity questions as a security measure.

Whilst TPComm undertakes all reasonable steps to protect your personal information, sending and receiving information over the Internet is always at your own risk. No guarantee can be given that information sent over the Internet is completely and 100% secure.

How Do We Protect Your Personal Information?

High technology is used to ensure your sensitive information is secure and is protected from unauthorised access or improper use. For example, you will note that while using some features of the TPComm website and online services such as Online Account Management, you need to submit a password before you gain access.

Your personal password is confidential and is encrypted to ensure its secrecy. With your password, you are able to edit your personal details via the Member Services pages.

Particularly sensitive information such as your credit card number is not stored in a server that is connected to the Internet. All transmission of data for the purposes of billing and collections is done via encrypted transmission between TPComm and the bank.

Unsolicited Commercial Email (UCE) or "Spam"

Spam is now dealt with under the Spam Act, 2003. TPComm Internet does not and has never supported or condoned the practice of sending spam. We have configured our mail servers so they cannot be directly used by a third party to send unsolicited commercial email or used as a staging post for an email attack on TPComm members or any other group. We require our members to do the same to prevent their mail gateways being abused in a similar fashion.

Marketing mail from TPComm will comply with the Spam Act and will always have a functional "unsubscribe" mechanism. You can send us a message telling us you would prefer not to receive the mail again and we will respect your wishes.

Emails relating to a pre-existing business relationship such as billing and service communications are not spam. These communications include but are not limited to, the regular monthly TPComm customer newsletter, three welcome letters and any billing information we forward to you by email. These emails are not "spam" within the meaning of the Spam Act because either they are purely factual in nature or it is a contractual obligation of the TPComm service to receive them.

These communications are an essential part of providing our service and you agree to these when you join our service as a part of the terms and conditions.

Children's privacy

We do not market to children or knowingly collect personal information about children without parental consent.

Children should always ask a parent before sending any transmission over the Internet. Parents should ensure they monitor and control their children's use of the Internet.

Pointers to Protect Your Privacy

• TPComm Internet will never request your entire credit card details in an email. Do not ever submit your entire credit card details in email format.
• Never offer credit card details in a chat room, via instant messaging services or in any other IRC environment.
• TPComm Internet undertakes all reasonable steps to ensure the privacy and safety of children using the Internet. Your children's privacy is very important to us, however the best way to ensure your children's safety is to supervise their Internet usage.
• We comply with the Broadcast Services Act 1992, which requires TPComm to provide an approved content filter for customer use. The filter restricts access to Internet sites that contain content classified as "prohibited" by the Australian Broadcasting Authority.
• Always close your browser and log out once you have finished surfing the Internet to prevent other people gaining access to your information and correspondence.
• TPComm Internet has no control over other web sites we may link to, and we take no responsibility for the conduct of these companies. Always read the Terms and Conditions when using other web sites.
• Keep your passwords and account details secret. If unauthorised access of your account occurs please inform us immediately.
• Beware of posting personal information in public forums such as Internet chat groups or newsgroups. If you voluntarily disclose personal information it may be collected and used by others.

• to obtain a consumer credit report about you, and/or to allow the credit reporting agency to create or maintain a credit information file containing information about you.
• Identity particulars - your name, sex, address (and the previous two addresses) date of birth, name of employer, and drivers licence number.
• your application for credit or commercial credit - the fact that you have applied for credit and the amount.
• The fact that TPComm is a current credit provider to you.
• loan repayments which are overdue by more than 60 days, and for which debt collection action has started.
• advice that your loan repayments are no longer overdue in respect of any default that has been listed.
• information that, in the opinion of TPComm you have committed a serious credit infringement (that is, fraudulently or shown an intention not to comply with your credit obligations).
• dishonoured cheques - cheques drawn by you for $100 or more which have been dishonoured more than once.
• that credit provided to you by TPComm has been paid or otherwise discharged.



Privacy Officer Contact

Should you have any questions or complaints about privacy issues please contact the TPComm Privacy Officer at privacy@tpcomm.com.au .