PRIVACY POLICY - MARCH 2024

The Trustee for We Are Phoenix Unit Trust (We Are Phoenix PTY LTD), trading as We Are Phoenix is committed to providing quality services to you and this policy outlines our ongoing obligations to you in respect of how we manage your Personal Information. This Privacy Policy contains important information about how we use your personal information. We respect the privacy of individuals who interact with our business and where you choose to provide us with information about yourself, you trust us to act in a responsible manner with that information.In this privacy policy, references “We Are Phoenix”, “us”, “we” or “our”, are all references to We Are Phoenix.

We have adopted the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth) (the Privacy Act). The NPPs govern the way in which we collect, use, disclose, store, secure and dispose of your Personal Information.A copy of the Australian Privacy Principles may be obtained from the website of The Office of the Australian Information Commissioner at https://www.oaic.gov.au/.If you have any questions, comments or concerns about any aspect of this policy or how We Are Phoenix handles your information please email our team at info@wearephoenix.com.au.

WHAT IS PERSONAL INFORMATION AND WHY DO WE COLLECT IT?
We collect personal information from you in several ways; you may share information with us, or we may collect it using other means. In this section we explain the different ways we collect personal information from you and some ways in which that information will be used.

REQUESTING INFORMATION FROM US AND RESPONDING TO YOUR QUERIES:
We process contact information such as name, email address, telephone number or postal address, preferences, and other declared personal information about you when you provide it to us. For example, when you fill out online forms, subscribing to our services, call, or text us, enquire about our services.

INTERACTING WITH US VIA SOCIAL MEDIA CHANNELS:
We process information relating to you when you interact with us through social media platforms such as Linkedin, Facebook and Instagram.

REGISTERING FOR AND ATTENDING OUR:
a. Experiential Marketing and Product Launches
b. Famils, Incentives and Conferences
c. Public and Outdoor Events
d. Corporate Experiences
e. Exhibition and Trade Shows

If you choose to attend one of our events, we collect your personal information that you share with us to provide you with details of the event and manage your attendance. For in-person events, we may ask you to provide us with accessibility information, if appropriate. This includes the use of our customised event apps (e.g. Michelin Passion Experience 2025), developed with EventsAir in collaboration with Centium Software.

UPDATING YOU ON DEVELOPMENTS AND INITIATIVES:
We may process your contact information to keep you informed of updates and developments in our business.

INTERACTING WITH OUR WEBSITE:
When you visit our website we may collect details of your website visit, including name, email, phone number, IP address (a unique identifier for your computer or other device), website URL and mobile device ID.

APPLYING FOR A JOB AT WE ARE PHOENIX:
We process information provided by you in relation to submitting a job application to We Are Phoenix (this may include sensitive personal information for example ethnic origin).

VISITING OUR OFFICE:
We may collect information such as contact information (including name, email address, telephone number) and CCTV footage in respect to your visit to our office address.

INTERACTING WITH US AS A CLIENT OF WE ARE PHOENIX:
When interacting with us as a client, we process information we may receive from you or from others in relation to our provision of services to our clients.

INTERACTING WITH US AS A SUPPLIER OR PARTNER TO WE ARE PHOENIX:
We process information in relation to you as an individual if you provide services to us (or if you work for a company that provides services to us).

SENSITIVE INFORMATION
Sensitive information is defined in the Privacy Act to include information or opinion about such things as an individual's racial or ethnic origin, political opinions, membership of a political association, religious or philosophical beliefs, membership of a trade union or other professional body, criminal record or health information.

Sensitive information will be used by us only:
- For the primary purpose for which it was obtained.
- For a secondary purpose that is directly related to the primary purpose.
- With your consent; or where required or authorised by law.

THIRD PARTIES
We may send your personal information to other group companies, affiliates and third parties to help us process your personal information for the purposes set out in this policy. We may disclose your personal information if we or any of our assets are the subject of a sale or similar corporate transaction. We will ensure that the third parties who receive your personal information are required to keep it confidential.

We may disclose personal information to third parties when we reasonably believe we are required by law, and in order to investigate, prevent, or take action regarding suspected or actual unlawful or otherwise prohibited activities, including, but not limited to, fraud.

WHERE DO WE SEND YOUR INFORMATION?
We operate as an international company and therefore we may transfer your personal information to countries around the world outside of Australia. We will, where the country to which your data is transferred has not been found to provide an adequate level of protection, put in place appropriate safeguards (we use standard contractual clauses) to ensure your information is protected.

DISCLOSURE OF PERSONAL INFORMATION
Your Personal Information may be disclosed in a number of circumstances including the following:
- Third parties where you consent to the use or disclosure; and
- Where required or authorised by law.

SECURITY OF PERSONAL INFORMATION
Your Personal Information is stored in a manner that reasonably protects it from misuse and loss and from unauthorized access, modification or disclosure. When your Personal Information is no longer needed for the purpose for which it was obtained, we will take reasonable steps to destroy or permanently de-identify your Personal Information. However, most of the Personal Information is or will be stored in client files which will be kept by us for a minimum of 3 years.

CHILDREN'S PRIVACY
We do not knowingly collect personal information from or about any person under the age of 16. If you are under 16 years old and wish to ask a question or use this site in any way which requires you to submit your personal information, we request a parent or guardian to do so on their behalf.

ACCESS TO YOUR PERSONAL INFORMATION
You may access the Personal Information we hold about you and to update and/or correct it, subject to certain exceptions. If you wish to access your Personal Information, please contact us in writing.

In order to protect your Personal Information we may require identification from you before releasing the requested information.

MAINTAINING THE QUALITY OF YOUR PERSONAL INFORMATION
It is important to us that your Personal Information is up to date. We will take reasonable steps to make sure that your Personal Information is accurate, complete and up-to-date. If you find that the information we have is not up to date or is inaccurate, please advise us as soon as practicable so we can update our records and ensure we can continue to provide quality services to you.

HOW TO CONTACT US
If you wish to exercise any of your rights in relation to your personal information or if you have any queries about how we use your personal information, please let us know by contacting us at the following address: We Are Phoenix Level 1, 19-21 Toorak Rd South Yarra, VIC 3141 or by email at info@wearephoenix.com.au.

POLICY REVIEW AND CHANGES
We review this privacy policy on a regular basis to ensure that it is up-to-date with our use of your personal information, and compliant with applicable data protection laws. We reserve the right, at our discretion, to revise this privacy policy at any time.