Harvey Norman Commercial has two items relating to your privacy when utilising our website or dealing with our business. These can both be found below:

• Privacy Policy
• Privacy Statement

Purpose of the policy

This is the official privacy policy of Blae Commercial Pty Ltd As Trustee for Blae Commercial No.2 Trust trading as Harvey Norman Commercial (“HNC”) ABN 11 530 188 684 and our related entities. This policy applies to all personal information collected by Harvey Norman Commercial via www.harveynormancommercial.com.au and any related Harvey Norman websites as noted below:

• Harvey Norman Commercial Blog
• Harvey Norman Commercial Solar
• Harvey Norman Commercial Air Conditioning
• Harvey Norman Commercial Smart Tech
• Harvey Norman Commercial Equipment
• Bowermans Commercial Furniture
• Harvey Norman Promotions

The purpose of this policy is to clearly express an up to date policy about our company's management of personal information. HNC respects the privacy of its contractors, suppliers, customers and or any other associated agents with whom HNC engage and deal with, henceforth noted as “You/Your” within this policy.

This policy is intended to enhance the transparency of our company's operations, notify you of your rights and our obligations and provide information regarding:

1. The kinds of personal information which we will collect and hold;
2. How we will collect, hold, use and disclose personal information;
3. The purpose for which we collect, hold, use and disclose personal information;
4. How you may access personal information that is held by us and seek correction of such information;
5. How you may complain about a breach of the Australian Privacy Principles (“APP”) or registered APP code (if any) that binds us and how we will deal with such complaint;
6. Whether we are likely to disclose personal information to overseas recipients;
7. If we are likely to disclose personal information to overseas recipients, the countries in which such recipients are likely to be located and if practical specify the countries in the policy.

The personal information collected is further utilised to assist in HNC's credit worthiness assessment

Acknowledgement

We acknowledge that we must take reasonable steps when handling personal information. Whilst we cannot warrant that this policy will be followed in every instance we will endeavour to follow this policy on each occasion.

Our company has taken reasonable steps to endeavour to comply with the APPs and the Act, some examples are noted below.

1. Implementation of privacy policy.
2. Staff training and education (including a handbook for our staff).
3. Use of checklists to ensure that all APPs are complied with.
4. Clear and transparent procedures regarding handling of complaints and disclosure of information.

Our policy is available on our website however should you require a hardcopy please contact us and we will provide you with a copy.

The kinds of personal information which we will collect and hold

Collection

It is our usual practice to collect personal information directly from the subject individual or their authorised representative(s).

Personal information means information or an opinion (including information or an opinion forming part of a database), whether true or not, and whether or not recorded in a material form, about an individual whose identity is apparent, or can reasonably be ascertained, from the information or opinion.

Some examples of some personal information we might collect are:

1. Name;
2. Address;
3. Contact details such as phone number, email address; and
4. Date of birth.

Identification

You may choose to interact with us using a pseudonym and/or not identify yourself.

In circumstances where we are required to do so, or are authorised by law, a court or tribunal to ask for your identification, we will request your personal information.

Further it is likely that it will be impractical for us to interact with you without some form of identification, and therefore we will request identification details from you at the beginning of each transaction.

For example we will not be able to open a commercial credit trading account or process a commercial credit application for you without obtaining identification details.

How we will collect and hold your personal information

We only collect and hold personal information by lawful and fair means.

In some circumstances, we may collect and hold personal information that has been collected from a third party or publicly available source. This will likely occur in instances where:

1. You have consented for this collection (which would usually be via our privacy statement and/or credit application form); or
2. You would reasonably expect us to collect your personal information in this way and it is necessary for us to collect this information for a specific purpose (such as investigation of a complaint).

We will take steps to hold personal information in a manner which is secure and protected from unauthorised access.

Your information may be held in either a physical form or in electronic form within our IT system. The collected information falls under several categories: Usage and preferences, Transaction information, Location information, and any other information which may be collected from interactions and or process performed within/via the HNC website.

We will take steps to protect the information against the modification, disclosure or misuse by including such things as physical restrictions, password protection for accessing electronic IT systems.

We will also endeavour to ensure that our service providers have protection for electronic IT systems and other necessary restrictions.

We will endeavour to ensure our staff are trained with respect to the security of the personal information we hold and we will restrict any access where necessary.

We will endeavour to destroy and de-identify the personal information once it is no longer required.

In the event we hold personal information that is unsolicited and we were not permitted to collect it, the personal information will be destroyed as soon as practicable.

If we collect personal information about you from someone else, we will advise you as soon as practicable that this information has been collected and the circumstances which surround the collection.

The purpose for which we collect and hold personal information

We will endeavour to only collect and hold personal information which is relevant to the operation of our company.

Our purpose for collecting or holding personal information about you is so that it may be used directly for our functions or activities.

We may use your personal information for the functions or activities of our company to:

1. Assess credit applications;
2. Review existing credit terms;
3. Assess credit worthiness;
4. Collect overdue payments;
5. Assess credit guarantees (current and prospective);
6. Internal management purposes;
7. marketing;
8. Sales;
9. Business development purposes and direct marketing.

We may also collect personal information (including sensitive information) for both the primary purposes specified herein and purposes other than the primary purposes, including the purpose of direct marketing.

We may also collect personal information from other credit providers, Credit Reporting Body (“CRB”) and any other third parties for the purposes of our functions and activities including, but not limited to, credit, sales, marketing and administration.

Legislation under which HNC may be authorised or required to collect your personal information includes the Anti-Money Laundering and Counter-Terrorism Financing Act 2006, Personal Property Securities Act 2009, Corporations Act 2001, Australian Securities and Investments Commission Act 2001, Income Tax Assessment Act 1997, Income Tax Assessment Act 1936, Tax Administration Act 1953, A New Tax System (Goods and Services Tax) Act 1999, Autonomous Sanctions Act 2011 and associated regulations and rules.

Information collection and security

HNC utilises cookies and other tracking technologies within its websites and applications. Certain information can be passively collected through use of cookies, tracking technologies, widgets, internet tags and or web beacons without you actively providing the information. In such instances information collected may include but is not limited to the following: date, time, duration of visits where the information is generally not linked to the identity of the visitor. In some instances where the identity/personal information is accessible, this occurs when the visitor accesses HNC via being uniquely logged into a HNC account or a unique link is provided by HNC.

The purpose for which use and disclosure personal information

We will endeavour to only use and disclose personal information for the primary purposes noted above in relation to the functions or activities of our company.

In addition we may also use and disclose personal information (including sensitive information) for both the primary purposes specified herein and purposes other than the primary purposes, including the purpose of direct marketing. The information will also be used to assist in providing a catered service by understanding your preferences and requirements.

Unless one or more of the below scenarios has occurred, we will take necessary steps to prevent personal information from being given to government agencies or other organisations.

1. You have provided your consent.
2. You would reasonably expect that your information would be so disclosed.
3. We have informed you that that your personal information will be provided to a third party.
4. We are required by law to provide your personal information to a government agency or other organisation.
5. The disclosure of the information will prevent a serious threat to somebody's life or health.
6. The disclosure of the information reasonably necessary for the enforcement of criminal law.

Further we will endeavour to only disclose personal information for the purpose in which it was collected, unless disclosure is reasonably necessary to:

1. Assist in locating a missing person;
2. Lessen or prevent a serious threat to life, health or safety;
3. Take appropriate action with suspected unlawful activity or serious misconduct;
4. Facilitate or assist with diplomatic or consular functions or activities;
5. Assist certain defence force activities outside Australia;
6. Establish or exercise a defined legal or equitable claim; or
7. Facilitate or assist confidential alternative dispute resolution activities.

We will take steps not to disclose personal information for direct marketing purposes unless consent has been provided.

In any event you will be provided with an opt out option with respect to direct marketing should you wish to be excluded from direct marketing.

We will record this information an our opt out register.

We will endeavour not to use or disclose a government related identifier unless:

A copy of the credit reporting policy for the CRB's listed above will be available on their website or will be provided in hard copy upon request.

How you may access your personal information

You are entitled to access your personal information held in our possession.

We will endeavour to respond to your request for personal information within a reasonable time period or as soon as practicable in a manner as requested by you. We will normally respond within 30 days.

You can make a request for access by sending an email or letter addressed to our Privacy Officer, details specified below.

With any request that is made we will need to authenticate your identity to ensure the correct person is requesting the information.

We will not charge you for making the request, however if reasonable we may charge you with the costs associated with your request.

You will only be granted access to your personal information where we are permitted or required by law to grant access. We are unable to provide you with access that is unlawful.

Further we are not required to and will not, give access to personal information to the extent that:

1. We reasonably believe that giving access would pose a serious threat to the life, health or safety of any individual, or to public health or public safety; or
2. Giving access would have an unreasonable impact on the privacy of other individuals; or
3. The request for access is frivolous or vexatious; or
4. The information relates to existing or anticipated legal proceedings and the information would not be accessible in normal discovery procedures; or
5. Giving access would reveal the intentions of us in relation to negotiations and this disclosure would prejudice those negotiations; or
6. Denying access is required or authorised by or under an Australian law or a court/tribunal order; or
7. We have reason to suspect that unlawful activity, or misconduct of a serious nature, that relates to our functions or activities has been, or may be engaged in;
8. Giving access would be likely to prejudice the taking of appropriate action in relation to the matter; or
9. Giving access would be likely to prejudice one or more enforcement related activities conducted by, or on behalf of, an enforcement body; or
10. Giving access would reveal evaluative information generated within us in connection with a commercially sensitive decision-making process.

If we refuse access to the information, written notice will be provided to you setting out:

1. The reasons for the refusal (except to the extent that, having regard to the grounds for the refusal, it would be unreasonable to do so); and
2. The mechanisms available to complain about the refusal; and
3. Any other matter prescribed by the regulations.

Correction and update of personal information

Should we hold personal information and it is inaccurate, out of date, incomplete, irrelevant or misleading, or incorrect you have the right to make us aware of this fact and request that it be corrected.

If you would like to make a request to correct your information please contact our Privacy Officer on the details above.

In assessing your request we need to be satisfied that the information is inaccurate, out of date, incomplete, irrelevant or misleading. We will then take all reasonable steps to ensure that it is accurate, up to date, complete and not misleading.

It is our normal policy to resolve any correction requests within 30 days. If we require further time we will notify you in writing and seek your consent.

Should we refuse to correct your personal information, a written notice will be provided to you setting out:

1. The reasons for the refusal (except to the extent that, having regard to the grounds for the refusal, it would be unreasonable to do so); and
2. The mechanisms available to complain about the refusal; and
3. Any other matter prescribed by the regulations.

We will endeavour to notify any relevant third parties of the correct personal information where necessary and required.

Complaints

In the event that you wish to make a complaint about a failure of us to comply with our obligations in relation to the Act or the APP's please raise this with our Privacy Officer on the contact details above.

We will provide you with a receipt of acknowledgment as soon as practicable.

We will then endeavour to respond to your complaint and attempt to resolve the issues within 30 days.

In dealing with your complaint we may need to consult another credit provider or third party. If we fail to deal with your complaint in a manner that you feel is appropriate you may choose to report your complaint to an external dispute resolution scheme (EDR Scheme).

We note that we are currently not a member of any EDR Scheme and we are exempt from any requirement to be a member of any EDR Scheme until March 2015.

If you are not satisfied with the process of making a complaint to our Privacy Officer you may make a complaint to the Information Commissioner. Details of which are below.

The Information Commissioner can decline to investigate a complaint on a number of grounds including:

1. Where the complaint wasn't made at first to us;
2. If the Information Commissioner considers the complaint has already been dealt with by a recognised EDR scheme; or
3. If the complaint would be more effectively or appropriately dealt with by a recognised EDR scheme of which we are a member.

Disclosure to overseas recipients

We may choose to, if permitted by law, share and/or disclose your personal information with recipients outside of Australia.

We are required to notify you with a list of any countries which personal information may be transmitted to, or disclosed where it is practical for us to do so.

At this point in time, we do not share and/or disclose any personal information to overseas recipients.

If you have any queries regarding our credit reporting policy or wish to find out more regarding any of privacy policies, please contact our Privacy Officer on the details list above.

1. This privacy statement encompasses consents, notifications and disclosures under or in relation to the Privacy Act 1988 (as amended by the Privacy Amendment (Enhancing Privacy Protection) Act 2012) (Act) in relation to your dealings with Blae Commercial Pty Ltd As Trustee for Blae Commercial No.2 Trust trading as Harvey Norman Commercial ABN 11 530 188 684 and our related entities (the Supplier).
2. The terms of this statement operate concurrently with any pre-existing privacy statement, authorisation or notification, whether contained in our credit application, terms and conditions of trade or otherwise, save to the extent of any inconsistency in which case the terms of this privacy statement shall prevail.
3. For the purpose of this statement , the terms "personal information", "sensitive information", "credit eligibility information", "credit information", "commercial credit purpose", "credit guarantee purpose", "consumer credit purpose", "credit reporting body", "credit provider", "credit reporting information", "credit reporting code" carry the same meaning as under the Act and the term "Information" means personal information, sensitive information, credit eligibility information, credit reporting information and credit information, both severally and collectively.
4. The Supplier may collect personal information about the Addressee(s) for the Supplier's primary purposes which include the assessment of a credit application, reviewing existing credit terms, assessing credit worthiness, collecting overdue payments, assessing credit guarantees (current and prospective), internal management purposes, marketing, sales and business development purposes and direct marketing.
5. The Addressee(s) consent to the Supplier collecting, using and disclosing personal information (including sensitive information) for both their primary purposes specified herein and purposes other than the primary purposes, including the purpose of direct marketing.
6. The Supplier may collect, and may already have collected, Information from the Addressee(s), other credit providers, credit reporting bodies and other third parties for the purposes of its functions and activities including, but not limited to, credit, sales, marketing and administration. If the Information was not collected by the Supplier it may restrict or impede upon the Supplier trading with, extending credit to, continuing to extend credit to or extending further credit to the Addressee(s) or their related bodies corporate.
7. The Addressee(s) consent to the Supplier obtaining and making disclosure of Information about the Addressee(s) from and to a credit reporting body and/or another credit provider for a commercial credit related purpose and/or a credit guarantee purpose and/or a consumer credit purpose and/or another related purpose. The Supplier notifies the Addressee(s) that it may use and/or disclose credit eligibility information under section 21G of the Act.
8. The Supplier may provide personal information about the Addressee(s) to any or all of the credit reporting bodies nominated below. The Supplier intends to disclose default information to any or all of the credit reporting bodies listed below. The Addressee(s) consent to such disclosure. The Supplier's credit reporting policy contains a statement of notifiable matters in accordance with s21C of the Act and items 4.1 and 4.2 of the Credit Reporting Code in respect of disclosure to credit reporting bodies including what the information may be used for, what the Supplier may disclose and the Addressee(s)' right to request limitations to the use of their information.

   Veda Advantage Level15, 100 Arthur Street NORTH SYDNEY NSW 2060 Tel: 1300 92 1621	Creditor Watch Level13,109 Pitt Street SYDNEY NSW 2000 Tel: 1300 501 312
   NCILevel 2,165 Grenfell St ADELAIDE SA 5000 Tel: 1800 882 820	Experian Level 6, 549 St Kilda Road MELBOURNE VIC 3004 Tel: 03 9699 0100
   Dun & Bradstreet Level 2, 143 Coronation Drive MILTON QLD 4064 Tel: 07 3360 0600

    
9. The Supplier may disclose Information to, and about them and the Addressee(s) hereby acknowledge that they consent to the disclosure of such information to the Supplier's employees , subsidiaries , employees , agents and related bodies corporate, past, present or prospective credit providers of the Addressee(s) or their related bodies corporate, including for the purpose of that person considering whether to offer to act as guarantor or offer security for that credit, and/or overseas recipients and recipients who do not have an Australian link.
10. By reason of the Addressee(s)' consent to the disclosure to overseas recipients hereunder, APP 8.1 will not apply to the Supplier's dealing with the Addressee(s)' Information. 
11. A full copy of the Supplier's privacy policy and credit reporting policy can be obtained from the Supplier's website (details above) or by making a request in writing directed to the Supplier's privacy officer. The Supplier's privacy policy and credit reporting policy contain information about how to access and seek correction of Information, or how to complain about a breach of the Act, APP, code(s) and how the Supplier will deal with any such complaint. 
12. The Addressee(s) will be deemed to have acknowledged and accepted the terms of this privacy statement by either signing and returning this statement , failing to provide written notification to the Supplier within 14 days of receipt of this statement that its terms are not accepted, continuing to trade with the Supplier after receipt of this Statement or, if the Addressee(s) are directors or guarantors of a customer , by not taking steps to prevent the customer from continuing to trade with the Supplier after receipt of this statement.