The legal bits

1 General

1.1 OVO Energy Pty Ltd (99 62 34 75 089) ("us" or "we") respect the privacy of visitors to our websites ('Sites'), our customers and other individuals who interact with us.

1.2 We have created this privacy policy to explain how we collect, store, use and disclose personal information.

1.3 Access to our privacy policy is free. If you would like us to post you a copy of our privacy policy, or have any questions about it or its contents, please email us.

1.4 The Privacy Act 1988 (Cth) ('Privacy Act') includes thirteen (13) Australian Privacy Principles ('APPs'). The APPs regulate the way many companies collect, use, hold and disclose personal information.

1.5 We have adopted an approach that is consistent with the Privacy Act, the APPs and the APP guidelines.

1.6 Our practices and internal policies are consistent with this privacy policy and our staff are required to ensure compliance as a condition of their employment. In any third-party contracts we enter into, there is a duty to maintain personal information in accordance with this privacy policy and in a manner consistent with the Privacy Act.

1.7 From time to time we will update this privacy policy. If we do so we will update the date listed above. Any changes to this privacy policy will be consistent with our legal obligations.

2 How and why we collect personal information

2.1 The Company collects personal information in a number of ways. The most common ways we collect personal information include:

2.1.1 From application forms (online or hard copy or completed via telephone): when individuals apply to become members of clubs run by us, or subscribe to marketing or communications lists, for the purpose of providing news, information, offers and other services in accordance with the terms and conditions of the club or list.

2.1.2 From order forms (online or hard copy or via telephone): when goods and services are ordered by distributors and retailers: for the purpose of fulfilling the order and delivering the goods, and to maintain our relationship with the individual concerned.

2.1.3 From telephone, email, written and in-person enquires: for the purposes of responding to enquiries.

2.1.4 Business cards: when you enter into transactions with us or otherwise interact with us in a business context including from your business card.

2.1.5 From online or hard copy surveys: for the purpose of reviewing and analysing the results and following up on results.

2.1.6 Any messages or comments submitted to us via the Site: which may include personal information such as your name, email address and telephone number.

2.1.7 From public registers including social networks such as LinkedIn: if you have made this information available, for the purpose of obtaining your contact details.

2.1.8 From Sites through automatic processes such as cookies: Cookies are used to better understand users and improve the layout and functionality of our Sites by collecting information such as date, time and duration of visits and which pages are most commonly accessed. This tracking is conducted in such a way as to ensure the anonymity of visitors to Sites. While cookies may identify the computer, it should not identify the individual. With most internet browsers, users can erase cookies from their computer's hard drive, block all cookies or receive a warning before a cookie is stored. However, some parts of this Site may not function fully for users that disallow cookies.

2.1.9 From behind the meter: where a customer consents, we may use technology to access their devices and appliances, such as an electric vehicle or solar panels and batteries, to collect data related to consumption and performance of that device. We may use this information to provide insights and optimization services to manage the operational efficiency of the device or appliance.

2.1.10 From job applications: applications for jobs with us, either as an employee or contractor, may contain information about an individual's right to work, employment history, qualifications and ability.

2.2 Our Sites may collect other information that may or may not be personal information. For each visitor to the Site, our server automatically recognises and stores the individual's "IP address" (eg. the domain name or Internet Protocol address), the type of Internet browser being used, the address of the site that "referred" the individual to our website and clickstream data. If this information cannot be used or combined with other data to identify you, it will not be personal information.

2.3 We generally collect our customers' personal information for the purpose of providing you with any goods or services that you request, communicate with you about your account (including managing complaints), manage your credit arrangements with us, manage accounts that are overdue, participate in credit reporting systems, to update our Sites, and to improve the services or goods that we provide and to develop our business.

2.4 If you have applied to work with us we collect personal information to assess your application, undertake customer checks and comply with the law.

3 What personal information is collected?

3.1 We aim to only collect personal information that is necessary to fulfil the purpose for which you have disclosed it, or as required by law.

3.2 You will typically be asked to provide contact information (such as your name, telephone number, postal address and email address) and forms of identification (such as drivers licence, passport number or medicare number). You may also be asked for demographic information (such as your age and gender) and/or profile data.

3.3 In some instances, we may need to ask you for additional information necessary to provide you with the goods or services you have requested - this may include the collection of credit information (to be collected in accordance with our terms and conditions). When we ask you for further information in addition to what you provide to us initially, we will tell you why we are collecting that information. Where we need to collect credit information from a third party in order to provide our goods and services to you, you consent to us collecting that credit information.

3.4 We aim to only collect information that is absolutely necessary to provide you with any service you have requested. If you would prefer to remain anonymous, we are happy to still deal with you, provided that we don't need to know who you are. Instances where this may be possible include where you are providing us with anonymous feedback that does not require a response.

4 Sensitive Information

4.1 The Privacy Act protects sensitive information, it is a special category of personal information. Sensitive information includes information about your health, race, or ethnic origin and religious beliefs. We will seek your consent before we collect and use sensitive information about you unless we are permitted or required to do so by law.

4.2 Some energy laws require us to collect health information in certain circumstances. For example, if you or someone else in your household requires life support equipment, you should tell us and provide confirmation from a medical practitioner (medical confirmation) so that your property may be registered as having life support equipment. We may need to disclose that there is life support equipment to your distributor to ensure additional protections are in place to prevent disconnection of your energy supply.

5 Electronic communications

5.1 In some instances, where you have provided consent, or consent is deemed to have been provided or conferred (in compliance with the APPs) we may use your personal information for the purpose of sending you marketing communications including by electronic means such as email, SMS, MMS for an unlimited period. You may opt-out of receiving such messages at any time provided such messages are sent by us. We will give you the opportunity to opt-out within the message that we send to you. You may also opt-out by contacting us (using the details provided below).

5.2 In some instances, where you have provided consent, or consent is deemed to have been provided or conferred (in compliance with the APPs) we may also send you electronic updates including via email, SMS, MMS for an unlimited period relating to products or services you have ordered, used or enquired about, to keep you informed of changes to the Site, and the products or services offered via the Site or from other production companies. You may opt-out of receiving such messages at any time provided such messages are sent by us. We will give you the opportunity to opt-out within the message that we send to you. You may also opt-out by contacting us (using the details provided below).

6 Storage of personal information

6.1 Any information we collect about you will be kept securely by us unless an event beyond our control disrupts the measures we have in place. We use a range of measures to ensure the security of the data we keep and to prevent unauthorised access, destruction, use, modification or disclosure. We have procedures in place with regards to staff access to personal information and ensure that only those staff who need to know have access to your information.

6.2 We will only store personal information for so long as it is required either to fulfil the purpose for which it was collected or to fulfil our obligations at law. We will conduct regular reviews of the personal information we hold and destroy or de-identify information no longer required.

7 Disclosure of personal information

7.1 Generally, personal information will not be disclosed to individuals or organisations outside of the Imagination Industries group without your prior consent. However, in the circumstances described below, personal information may be disclosed to:

• 7.1.1 Essential service providers: There may be other companies that we rely on to provide goods or services to you such as your distributor who operates the pipes and wires that supply energy to your property. We may be required to provide your personal information to these companies to ensure that we can deliver goods or services to you.

• 7.1.2 Law enforcement or government bodies: There are exceptions under the Privacy Act with regard to the provision of personal information to law enforcement or government bodies. When a legitimate request is sent to us by a law enforcement or government body we will comply with that request and may provide personal information about you without your consent.

• 7.1.3 Companies related to us or who take control of part or all of our business: In providing personal information to us we may provide information to companies related to us to provide our products and services. You will need to be aware of the possibility that, in future, another company may take control of part or all of our business. In that case, your personal information will be provided to that company.

• 7.1.4 Credit reporting agencies: to process new applications, assess and manage applications for credit, manage overdue accounts, and review your creditworthiness.

• 7.1.5 Third Party partners and companies: that we partner with to support the product and services we offer. This may include technology solutions to provide behind the meter services to you such as smart home devices, electric vehicle and distributed energy products and services.

7.2 If we disclose personal information to a third party under outsourcing or contracting arrangements (a service provider), we will take steps to ensure that they:

• 7.2.1 Have signed a binding agreement;

• 7.2.2 Handle the personal information in a manner consistent with the APPs (regardless of whether they are a small business, or would otherwise be exempt from the Privacy Act);

• 7.2.3 Only use the personal information in order to provide specific services or to perform the

• 7.2.4 Have specific functions required; and

• 7.2.5 Store the personal information securely, and only for as long as is necessary to provide the required services to perform the required functions.

8 Overseas disclosure of personal information

8.1 We may disclose and transfer your personal information outside of Australia through the use of a third party services during the collection, use or storage of personal information under this policy to places such as South Africa, the United States, the United Kingdom and Europe. We will only transfer personal information outside of Australia in accordance with the Privacy Act.

8.2 If we transfer personal information outside Australia to countries whose privacy laws may not provide the same level of protection as Australia's privacy law, we will take reasonable steps to ensure that the overseas recipients of your personal information do not breach the privacy obligations relating to your personal information and we will comply with all applicable laws relating to cross-border data disclosure.

9 Access to personal information

9.1 Under the Privacy Act, you have the right to seek access and to update or correct the personal information that we hold about you. If you wish to exercise your right under the Privacy Act to seek access to the personal information held for you, you should make the request in writing (to the address specified below).

9.2 Ordinarily we will not charge for providing access/copies of personal information we hold about you, and will generally respond to access requests of this type within 30 days. If we anticipate there being a fee (for the time we spend locating and compiling the information you have asked for) we will provide you with an estimate before proceeding. If a fee is payable it will be based on an hourly rate plus the cost of photocopying or other out of pocket expenses. For legal and administrative reasons, we may also store records containing personal information in archives. Access to these historical records may result in a charge being incurred (an estimate will be provided to you prior). Due to the nature of archive, requests for access to historical records may take longer to process than with current records.

9.3 You may correct the personal information we hold about you at any time, you should make the request in writing (to the address specified below). We do not charge a fee to correct personal information held.

9.4 On review of your request, if we agree that the personal information held is not accurate, complete and up to date, it will be corrected by the appropriate person. If we do not agree, you will be provided with the reason(s) for the views and the opportunity to make a statement of your view and have it included with the information held.

10 Complaints

10.1 You have a right to complain to us if you are concerned about your privacy, how we have dealt with your personal information or in relation to the Privacy Act.

10.2 If you are concerned about how we have dealt with your personal information you should first contact us (using the details set out below). We will endeavour to send you a written response within 10 business days.

10.3 If you are not satisfied with the way we have managed or attempted to resolve your complaint you may complain to the Office of the Australian Information Commissioner by calling them on 1300 363 992, via their website at www.oaic.gov.au or by mail to the Office of the Australian Information Commissioner, GPO Box 5218 Sydney NSW 2001.

11 Links to third-party websites

11.1 Our site contains links to third party websites for individual's convenience and information. Individuals should be aware that when they access a third-party website, we are not responsible for the privacy practices or policies of that third party and will not be liable for any use or disclose your personal information by any third party to whom your information is sent. We suggest that you review the privacy policy of each website you visit.

12 Acceptance of these terms

12.1 By using the site, you signify your acceptance of this Privacy Policy. If you do not agree with this policy, please do not use our Sites or provide us with your personal information. The OVO Energy reserves the right to modify, alter or otherwise update this policy at any time. Should the OVO Energy modify, alter or otherwise update this policy, it will prominently post notice(s) of the changes on the Sites covered by this privacy policy.

13 Contact details

• Company Name: OVO Energy

• Mailing address:

• L22, 120 Spencer Street

• Melbourne

• VIC

• 3000

• Email: hello@ovoenergy.com.au