MINTEDVR Privacy Policy (Australia)

1. About this Privacy Policy

1.1 MINTEDVR LTD (MINTEDVR, we, us or our) has implemented this Privacy Policy to provide information about what kinds of Personal Information we may collect or hold, how we collect, hold, use and disclose that Personal Information, choices you have regarding our use of that Personal Information, and your privacy rights including the ability to access or correct that Personal Information. If you wish to make any inquiries regarding this Privacy Policy, you should contact us in any of the ways specified in paragraph 15.

1.2 From time to time, MINTEDVR may be related to other companies and entities (related entities). This Privacy Policy applies to the use of your Personal Information by us and by those related entities. A reference in this Privacy Policy to MINTEDVR, we, us or our is also a reference to those related entities.

1.3 Our related entities, and MINTEDVR outside Australia, may also have different privacy policies which set out additional detail or differences in their privacy practices. To the extent that those privacy policies are inconsistent with this Privacy Policy, those privacy policies will prevail over this Privacy Policy in relation to the actions of those entities.

1.4 We may also authorise third parties to operate one or more MINTEDVR franchises (Franchisees). Franchisees are independent businesses and are not related entities of MINTEDVR. We are not responsible for the collection and use practices of those Franchisees in relation to their handling of your Personal Information. Please contact your Franchisee directly to access a copy of their privacy policies and to understand their privacy practices and the options they may make available to you in relation to their collection of your Personal Information.

1.5 MINTEDVR's coaching activities are primarily run by Franchisees. As such, the collection and use of learners' Personal Information is mainly undertaken by the Franchisees. To the extent possible, we aim to minimise our direct collection, receipt or use of Personal Information collected by Franchisees. However, we monitor initial enquiries and enrollments in our Franchisees' courses, and we manage the underlying IT platforms including hosting and processing Personal Information of learners on behalf of our Franchisees. We may also assist in facilitating the transfer of a Franchisee's business to an alternate Franchisee, or to MINTEDVR, in certain circumstances.

1.6 Where applicable laws provide for exceptions or exemptions to our practices set out in this Privacy Policy, we may rely on those exceptions or exemptions in our handling of your Personal Information in relevant circumstances.

2. Personal Information

2.1 "Personal Information" is information or an opinion, whether true or not, and whether recorded in a material form or not, about an identified individual or an individual who is reasonably identifiable.

3. What Personal Information do we collect and hold?

3.1 The types of Personal Information we may collect about an individual will depend upon the nature of our interaction with them. Personal Information that we collect may include (but is not limited to) the following:

• (a) about learners, being users of our apps or our virtual reality driving simulator game software: your name, email address, contact details, content of your initial enquiry, IP address, information about your computer or device, including operating system, browser type, and device type (see further paragraph 5 below). Franchisees may also collect your identification information such as driver licence details including driver's licence number, payment details, such as your credit card or bank account details, MINTEDVR MINTDRIVER Courses attended (if applicable), and (with your consent) photographs, images or videos of learners in class for marketing and social media engagement
• (b) about staff of MINTEDVR's or our Franchisees' customers, such as schools or community groups who facilitate MINTEDVR MINTDRIVER Course group classes for learners: name, role, contact details, organisation, class times and venue details, payment details, such as your credit card or bank account details
• (c) about our Franchisees and applicants: name, email and postal addresses, phone numbers, financial details, credit worthiness, information about your business's directors and guarantors (if applicable), identification information, and other information about your business such as financial information including your ABN or ACN, assets and liabilities, investment and loan accounts, insurance application details, bank statements and utility statements, credit history, trade references, credit references or reports from a third party
• (d) about MINTEDVR Coaches: your name, contact details, geographical location (to help us identify appropriate Franchisee or coaching opportunities), MINTEDVR MINTDRIVER Course classes assigned to you, MINTEDVR training received and qualifications including appropriate working with children checks
• (e) about job applicants: name, occupation and employment details including employment status and any previous work experience, qualifications, and information from or in connection with your resume or job application such as referees
• (f) about staff of our third party suppliers or service providers: name, role, contact details, work performed for us, and
• (g) about other individuals and individuals who interact with us generally: name, contact details including email, telephone numbers and address, photographs and/or images of you from camera footage such as CCTV (if you attend our premises), and information from social media accounts and profiles.

3.2 We collect and record Personal Information about individuals such as:

• (a) learners including end users of our apps or simulator software, prospective learners and their representatives
• (b) staff of our or our Franchisees' customers (such as schools or community groups) who facilitate MINTEDVR MINTDRIVER Course group classes with learners (end users of our apps or simulator software)
• (c) our Franchisees and prospective Franchisees and their representatives, directors, partners, proprietors and shareholders
• (d) current and prospective MINTEDVR Coaches
• (e) our suppliers and prospective suppliers and their representatives, directors, partners, proprietors and shareholders
• (f) contractors and subcontractors and prospective contractors and subcontractors and their representatives in relation to providing goods and services to us
• (g) our employees past and present, including applicants, and
• (h) any other person who comes into contact with MINTEDVR.

4. How and when do we collect Personal Information?

4.1 We collect your Personal Information to allow us to conduct our business functions, to provide, market and sell our products and services and for the specified purposes set out in paragraph 6. In some circumstances the collection of Personal Information may be required by law.

4.2 We may collect your Personal Information in the course of providing you with goods or services, or:

• (a) when you use or buy our products or services, including through our Franchisees and MINTEDVR Coaches, via our Website (see paragraph 5), or through purchasing or using our software applications
• (b) when you provide us, or you offer or apply to supply us, with goods or services
• (c) when you provide information to us in any way (including by completing a form, disclosing information over the phone or via email, or providing us a business card)
• (d) when you request information about us, our products or our services, including through our Franchisees and MINTEDVR Coaches or via our Website
• (e) when we receive a referral about your interest in our programs from third parties such as government social services or educational agencies
• (f) when you provide feedback to us
• (g) when you visit or fill in a form on our Website (see paragraph 5)
• (h) when you register for or use an account on our Website
• (i) when you visit premises from which we operate
• (j) when you (or your employer) provide that information to us in the course of conducting or administering our relationship with you, or when you are carrying out activities in connection with our business operations
• (k) when you submit a job application to us, if applicable
• (l) when you otherwise contact us by telephone, fax, email, social media, post or in person, or
• (m) where we are otherwise required or authorised by law to do so.

4.3 Generally, when providing our products and services, dealing with our personnel, or obtaining goods and services from our service providers, suppliers or contractors, we collect Personal Information directly from the relevant individual where reasonable and practicable.

4.4 We may also collect Personal Information about you from third parties and other sources such as:

• (a) our Franchisees with whom you interact
• (b) your nominated representatives (eg family or household member, accountant, power of attorney, brokers and other professional advisors)
• (c) publicly available sources of information, or
• (d) related entities, companies and businesses of MINTEDVR,

but we will only collect your Personal Information in this way if it is unreasonable or impracticable to collect this information directly from you or if we are otherwise permitted to do so.

4.5 If the Personal Information we collect includes sensitive information, including health information, we will ask for your consent to collect sensitive information, unless the law allows us to collect it without your consent.

4.6 Where we engage with you multiple times over a short period in relation to the same matter, we may not provide you with a separate notice about privacy each time we engage with you.

4.7 If you choose not to provide your Personal Information to us for the purposes set out in this Privacy Policy, or if we do not or are unable to collect the Personal Information we require, we may not be able to provide you with requested information, products or services, or to effectively conduct our relationship with you.

5. Information collected via our Website and applications

5.1 Personal Information may be collected by us and by our third party service providers who assist us in operating our website at https://www.mintedvr.com.au/, including its subdomains and any other website we operate from time to time (collectively the Website).

5.2 We may use various technological methods from time to time to track the visiting patterns of individuals accessing our Website or using our applications, including but not limited to the methods set out in this paragraph 5.

Google Analytics

5.3 We use Google Analytics to help analyse how you use our Website. Google Analytics generates statistical and other information about website use by means of cookies, which are stored on users' computers. The information generated is used to create reports about the use of our Website. Google will store this information.

5.4 If you do not want your Website visit data reported by Google Analytics, you can install the Google Analytics opt-out browser add-on. For more details on installing and uninstalling the add-on, please visit the Google Analytics opt-out page at https://tools.google.com/dlpage/gaoptout

Click Stream Data

5.5 When you read, browse or download information from our Website, we or our internet service provider may also collect information such as the date, time and duration of a visit, the pages accessed, the IP address of your computer, and any information downloaded. This information may be used for purposes including statistical, reporting and website administration, maintenance and improvement purposes.

Web Beacons

5.6 Web beacons are images that originate from a third party site to track visitor activities. We may use web beacons to track the visiting patterns of individuals accessing our Website.

Cookies

5.7 Our Website may use 'cookies' from time to time. Cookies are small text files that are transferred to a user's computer hard drive by a website for the purpose of storing information about a user's identity, browser type or website visiting patterns. Cookies may be used on our Website to monitor web traffic, for example the time of visit, pages visited and some system information about the type of computer being used. We use this information to enhance the content and services offered on our Website.

5.8 Cookies are sometimes also used to collect information about what pages you visit and the type of software you are using. If you access our Website or click-through to our Website from a link in an email we send you, a cookie may be downloaded onto your computer's hard drive.

5.9 Cookies may also be used for other purposes on our Website.

5.10 You can configure your browser to accept all cookies, reject all cookies, or notify you when a cookie is sent. Each browser is different, so check the "Help" menu of your browser to learn how to change your cookie preferences.

5.11 If you disable the use of cookies on your web browser or remove or reject specific cookies from our Website or linked sites then you may not be able to gain access to all of the content and facilities in those websites.

Advertising networks

5.12 We use network advertisers to serve advertisements on unaffiliated websites or other media (e.g. social networking platforms). This enables us and network advertisers to target advertisements to you for products and services in which you might be interested. Ad network providers, advertisers, sponsors, and/or traffic measurement services may use pixels, cookies, JavaScript, web beacons (including clear GIFs), Flash LSOs, and other tracking technologies to measure the effectiveness of their ads and to personalize advertising content to you. These pixels, cookies and other technologies are governed by each entity’s specific privacy policy, not this Privacy Policy. We may provide these advertisers with information, including Personal Information, about you.

5.13 In accordance with applicable law, we may disclose certain information (such as your email address) to Facebook Custom Audiences (for more information on Facebook Custom Audiences click here or to opt-out, go to the Facebook ad preferences page) - so that we can better target ads and content to you and others with similar interests on other websites or media (Custom Audiences). We may also work with other ad networks and marketing platforms that enable us and other participants to target ads to Custom Audiences submitted by us and others. You may also control how Facebook and other ad networks display certain ads to you, as explained further in their respective privacy policies or by using the opt-outs described below.

Third party content (eg social media links)

5.14 Some of the content on our Website may include applications made available by third parties, such as social media buttons or links that allow you to share content or links to our Website through the relevant third party platforms. These third party applications themselves may facilitate collection of information by those third parties, through your interaction with the applications and sometimes even if you do not interact directly with them. We are not responsible for the technical operation of these applications or the collection and use practices of the relevant third parties. Please visit the relevant third party websites to understand their privacy practices and options they may make available to you in relation to their collection of your Personal Information.

6. How do we use your Personal Information?

6.1 We use the Personal Information we collect about you for our business functions and activities, in order to operate our business efficiently, and to market our products and services for the benefit of our customers and users.

6.2 We may collect, hold and use your Personal Information:

• (a) to identify and communicate with you
• (b) to enable us to provide you with requested information, products or services
• (c) to refer you to a Franchisee or MINTEDVR Coach who can provide you with classes, products or services
• (d) to assist you (as a learner) in applying for, or to apply on your behalf for, a driving test
• (e) to work with government social services or educational agencies involved in assisting you to obtain a drivers licence and gainful employment
• (f) to otherwise assist our end users, customers, Franchisees and MINTEDVR Coaches by providing them with information and support
• (g) to collect and process payments
• (h) to help us to manage and enhance products or services we provide to you
• (i) to help us to manage and enhance goods and services we procure from our suppliers and subcontractors
• (j) to personalise, customise and improve your experiences on our Website or with our software applications
• (k) to manage and administer any account you may hold with us
• (l) to help transfer or transition our or a Franchisee's business in a particular region to us or to a new Franchisee, which may include providing customer and user information to a new Franchisee in order to allow them to conduct that business
• (m) to implement, promote and administer any MINTEDVR membership rewards or loyalty programs
• (n) to process and assess your application to operate a MINTEDVR franchise where you or your business are applying to be a Franchisee
• (o) to carry out debt and equipment or goods recovery functions
• (p) to promote and market our (including our Franchisees') products and services to you
• (q) to provide you with information that we believe may be of interest to you or that you may be interested in receiving, including advertising material, regarding us, our clients, and our business partners
• (r) to contact you to obtain your feedback and to find out your level of satisfaction with our or our Franchisees' products and services
• (s) to conduct research for the purposes of improving existing products or services or creating new products or services
• (t) to help us research the needs of our customers to enable us to market our products and services with a better understanding of your needs and the needs of customers generally
• (u) to protect you and us from fraud
• (v) to provide for the safety and security of our workers and onsite visitors
• (w) to help us manage our business operations
• (x) to help manage the business operations of and provide centralised IT and business support services to our MINTEDVR Coaches and Franchisees
• (y) for our and our Franchisees' business support purposes including maintenance, backup and audit
• (z) to process any job application or Franchisee application submitted by you
• (aa) to investigate and respond to any queries or complaints an individual may have, including about our Franchisees or MINTEDVR Coaches
• (ab) to investigate, review, mitigate risks associated with, and inform you of, a data or other security breach involving your personal information, and
• (ac) to comply with our statutory and legal obligations.

6.3 We may aggregate personal information for reporting, statistical and analysis purposes, and for business, product and service improvement purposes. This allows us to better inform ourselves and anticipate our customers' preferences and requirements, and to monitor and improve the effectiveness of our business, products and services. We may also de-identify information for inclusion in such aggregated databases or reports.

6.4 We reserve the right at all times to monitor, review, retain, and/or disclose any information as necessary to satisfy any applicable law, but we have no obligation to monitor the use of the Website or to retain the content of any user session.

6.5 You consent to us using your Personal Information in the above ways and as set out in this Privacy Policy.

6.6 We may otherwise collect, use or disclose your Personal Information where the collection, use or disclosure is:

• (a) in accordance with this Privacy Policy or any agreement you enter into with us, or
• (b) required or authorised by law, including without limitation the Australian Privacy Principles under the Privacy Act 1988 (Cth).

7. When do we disclose your Personal Information?

7.1 MINTEDVR may disclose, or provide access to, your Personal Information to third parties in connection with the purposes described in paragraph 6. Depending on the circumstances and the nature of your engagement with us, we may disclose your Personal Information to our related entities, to third parties that provide products and services to us or through us, or to other third parties (such as your referee(s) in connection with a job application you have submitted).

7.2 We may also disclose your Personal Information to:

• (a) any of MINTEDVR's internal divisions, business units or departments
• (b) Franchisees and their staff and MINTEDVR Coaches, so that they can respond to enquiries you have made if you are or appear to be located in the area they serve, or as otherwise relevant to that Franchisee or MINTEDVR Coach's interactions with you
• (c) your nominated representatives
• (d) other organisations or individuals who assist us in providing products and services to you
• (e) government social services or educational agencies who refer you to us or who are involved in assisting you to obtain a drivers licence and gainful employment
• (f) professional service providers and advisors who perform functions on our behalf, such as lawyers
• (g) representatives, agents or contractors who are appointed by us in the ordinary operation of our business to assist us in providing goods or services or administering our business (such as for data storage or processing, printing, mailing, marketing, planning and product or service development)
• (h) debt collecting agencies
• (i) banks, lenders, valuers, insurers, brokers, auditors, business consultants and IT service providers, and
• (j) Government, regulatory authorities and other organisations as required or authorised by law.

7.3 We may also disclose your Personal Information to our Website host or software application providers in certain limited circumstances, for example when our Website experiences a technical problem or to ensure that it operates in an effective and secure manner.

7.4 As we continue to develop our business, we may buy, merge or partner with other companies or organisations, and in so doing, acquire customer Personal Information. In such transactions, Personal Information may be among the transferred assets. Similarly, in the event that a portion or substantially all of our business or assets are sold or transferred to a third party, we may also disclose certain information including your Personal Information to a purchaser or prospective purchaser in connection with the sale or potential sale of us, our business or any of our assets, including in insolvency.

8. Overseas disclosures

8.1 Some of your Personal Information may be disclosed, transferred, stored, processed or used overseas by us, or by third party service providers. This may happen if:

• (a) our offices or related entities are overseas
• (b) we outsource certain activities overseas
• (c) transactions, information, services or products have an overseas connection, or
• (d) our computer systems including IT servers are located overseas.

8.2 You consent to the collection, use, storage, and processing of your Personal Information outside of Australia as set out in this Privacy Policy.

8.3 In particular, your Personal Information may be disclosed to third parties in New Zealand, and such other countries in which those parties or their, or our, computer systems may be located from time to time, where it may be used for the purposes described in this Privacy Policy. In these circumstances, you consent to the collection, use, storage and processing of your Personal Information in those countries.

9. Other uses and disclosures

9.1 We may collect, use and disclose your Personal Information for other purposes not listed in this Privacy Policy. If we do so, we will generally seek to take reasonable steps to make it known to you at the time we collect or use your Personal Information, unless otherwise permitted by law.

10. Marketing

10.1 Unless you have opted out of receiving marketing from us, if you are learner, customer representative, Franchisee or MINTEDVR Coach, you consent to us using your Personal Information for sending you information, including promotional material, about us or our products and services, as well as the products and services of our related entities and Franchisees and other third parties, now and in the future. You also consent to us sending you such information by means of direct mail, email, SMS and MMS messages.

10.2 If you do not want to receive marketing information from us, you can unsubscribe in any of the following ways:

• (a) clicking on the 'Unsubscribe' or subscription preferences link in a direct marketing email that you have received from us, or
• (b) contacting us using the contact details specified in paragraph 15.

11. Storage and security of Personal Information held by us

11.1 We aim to keep your Personal Information secure. Any Personal Information that is collected via our Website or which is held on our computer systems is protected by safeguards including appropriate technical and organisational measures designed to protect that Personal Information from unauthorised access, alteration and destruction.

11.2 If we find that we no longer require or have no further need for your Personal Information we may de-identify it or remove it from our systems and destroy all record of it.

12. You can access and update your Personal Information

12.1 You are generally entitled to access Personal Information that we hold about you. If you request access to your Personal Information, in ordinary circumstances we will give you full access to your Personal Information. Depending on the nature of the request, MINTEDVR may charge for providing access to this information, however such charge will not be excessive. However, there may be some legal or administrative reasons to deny access. If we refuse your request to access your Personal Information, we will provide you with reasons for the refusal where we are required by law to give those reasons.

12.2 A request for access can be made by contacting us in any of the ways specified in paragraph 15.

12.3 We take all reasonable steps to ensure that any Personal Information we collect and use is accurate, complete and up-to-date. To assist us in this, you need to provide true, accurate, current and complete information about yourself as requested, and properly update the information provided to us to keep it true, accurate, current and complete.

12.4 Please contact us in any of the ways specified in paragraph 15 if you believe that the Personal Information is inaccurate, incomplete or out of date, and we will use all reasonable efforts to correct the information.

12.5 It would assist us to ensure we properly understand your request, and allow us to respond more promptly, if requests are made in writing and include as much detail as possible.

13. How do we deal with complaints about privacy?

13.1 If you feel that we have not respected your privacy or that we have conducted ourselves inconsistently with this Privacy Policy, please contact us in any of the ways specified in paragraph 15 and advise us as soon as possible. We will investigate your queries and privacy complaints within a reasonable period of time depending on the complexity of the complaint.

13.2 It would assist us to respond to your complaint promptly if it is made in writing. Please detail information relevant to your complaint.

13.3 We will notify you of the outcome of our investigation.

14. Updates to this Privacy Policy

14.1 We may, from time to time, review and update this Privacy Policy, including to take into account new laws, regulations, practices and technology. All Personal Information held by us will be governed by our most recent Privacy Policy, posted on our Website at: https://www.mintedvr.com.au/privacy-policy/. Any changes to this Privacy Policy may be advised to you by updating this page on our Website. We will aim to provide reasonable advance notice of such changes though this may not always be possible depending on the circumstances. We encourage you to check this page from time to time for any changes.

15. What to do if you have a question, problem or complaint, or want to contact us about our use of your Personal Information or this Privacy Policy

15.1 If you:

• (a) have a query or concern about this Privacy Policy or our Personal Information handling processes
• (b) wish to make a complaint in relation to a breach of your privacy
• (c) would like to access your Personal Information held by us
• (d) would like to update or correct your Personal Information held by us, or
• (e) would like to opt out of direct marketing,

please contact us in any of the following ways:

Email Address: team@mintedvr.com, or

Website: completing the form at https://www.mintedvr.com.au/#contact-us.