This document outlines the privacy policy (“Privacy Policy”) of Refreshe Pty Ltd and how it applies to information that may be collected on the Refreshe website (“Refreshe Website”).

Definitions and Interpretation

Clients means companies or individuals to whom Refreshe Pty Ltd currently provides products or services, has provided products or services to in the past or may provide products or services to in the future.

Refreshe means Refreshe Pty Limited, (Australian Company Number 129 707 973) an Australian proprietary company limited by shares.

Refreshe Website means the whole or any part of the web pages located at www.refreshe.com.au and includes the layout, individual elements of the design, text, graphics, underlying code or any other content of the Refreshe Website.

We and Us refers to Refreshe Pty Limited and Our has a similar meaning.

Information Collected on the Refreshe Website

Visitors to the Refreshe Website do not need to disclose their identity to use the Refreshe Website.  The Refreshe Website does not collect personal information from visitors other than as set out below.

Our Internet server may automatically record details about a computer used to access the Refreshe Website (such as the IP address, domain name and browser type), the date and time of access, and details of the information downloaded. This information is used solely for internal purposes and to make improvements to the Refreshe Website.

Protecting confidential information is fundamental to our relationship with our Clients and to our business.  All information received from Clients is subject to our confidentiality obligations.  We will not disclose such information unless we have the consent of the Client or as contemplated by this Privacy Policy.

Types of Information We Collect

During the course of carrying on our business, we may collect personal information. We usually collect the following types of personal information:

• Name, address, occupation and contact details
• Interests in areas of our business
• Information about your dealings with us (in the case of Clients) or about your dealing with our Clients (in the case of third parties).

Use and Disclosure of Information

We use personal information for the purposes for which it was collected, which may include:

• Providing services to our Clients
• Managing our relationships with our Clients
• Providing our Clients with information about products or services that may interest them
• Activities in the normal course of operating our business

We may disclose personal information for the purposes for which it was collected, and also, subject to our confidentiality obligations:

• To any person in connection with us providing our products and services, such as the Client, the Client’s advisors or regulatory authorities
• To directors, employees and advisors of Refreshe
• To external service providers so that they can provide financial, administrative or other services to Refreshe
• As required by law; or
• With your consent.

E-Mail Information

We ask for your e-mail address when you register to access articles in the Latest thinking section of the Refreshe Website.  We will send an e-mail to this address (i) to confirm your registration, (ii) to advise you of news or articles that may be of interest to you, and (iii) if you request that we contact you for any other reason.

In addition, we may contact you regarding your account status and major changes to the Refreshe Website and/or to the Terms of use and Privacy policy.

You can unsubscribe from our Latest thinking articles by sending an e-mail to Contact us requesting that we remove your details from our database.

Storage and Security of Information

We will use reasonable endeavours to protect the information that we hold (including your personal information) from misuse, loss, unauthorised access, modification or disclosure and to keep this information accurate and up to date.  We will use reasonable endeavours to hold information securely in either electronic or physical form.  All directors and employees of Refreshe who have access to confidential information are subject to confidentiality obligations.

Access to Information

You may request access to personal information that we hold about you or request to be removed from any direct marketing lists held by Refreshe at any time.  To access your information or request removal from a direct marketing list, please send an email to privacy@refreshe.com.au outlining the nature of your request.


September 2008