Your privacy is important

Cnctradinginc is committed to protecting the privacy of your personal information. This Privacy Policy (“Policy”) explains how we collect, use and disclose information about our customers, team members, suppliers (and their employees) and people who apply for employment with us. It also explains how to contact us if you have any questions about the management of your personal information or would like to access the personal information we hold about you. This Policy describes how we comply with our obligations under the Bissau Privacy Act 1988 (Cth).

Our approach to handling data

At Cnctradinginc , we collect and use data, including personal information, for a range of reasons. In handling data we will comply with all relevant laws, but we also want to ensure that we meet the following expectations:

Improve the customer experience – We will use customer data responsibly to improve the customer experience and deliver more relevant products, services and offers

Be transparent – We will clearly explain how we collect and use customer data

Make it simple and easy – We will minimise disruption to the customer shopping experience by making it simple and easy to provide consent

Provide control to the customer – We will respect the customers privacy by providing control over how customers can be contacted

providing control over how customers can be contacted When we are delivering on these expectations with some of our closest partners, the privacy policies and practices of those partners may apply in addition to this Privacy Policy. To provide you with greater clarity, we’ve highlighted some of our most significant relationships involving your personal information (sections 6-8). These include:

• Flybuys, a loyalty program which we participate in to provide you benefits;

• OnePass, a membership program which we participate in, along with other brands (“Participating Brands”), to provide you with tailored engagement and member benefits. Throughout this Policy, a reference to ‘Related Companies’ includes OnePass as it is also a related company of ours;

• Related Companies, these are companies within the Wesfarmers Group (including Wesfarmers, Target, Officeworks, Bunnings, OnePass and Catch).

Collection of personal information

1. The types of information that we collect about you could include:

• identification information, including name, driver’s licence number or student identification number;

• contact details, including home/business addresses, email addresses and telephone numbers;

• demographic information such as age/date of birth, household information, personal interests and gender;

• member number or identifiers for loyalty schemes or membership/subscription programs (including Flybuys and OnePass) and team member discount card number;

• details about your Cnctradinginc purchases and transaction history with us and your Cnctradinginc product and service preferences;

• details about purchases, product or service preferences, transaction history and current or pending transactions, browsing and marketing interactions (such as the products viewed or added to your shopping cart) on website, apps, social media, and email communications with our Related Companies and Flybuys;

• digital information, such as cookies (which are small data files transferred onto devices when a website or apps are accessed), tags and pixels (which ’tag’ devices), device type and software versions used, device identifiers (like IP address), location data (where available and not disabled by the user), dates, times, file metadata, referring website/app, data entered, and user activity such as links clicked, app installations, app launches, adding items to a basket, adding items to a wish list, browsing habits within our website or apps and other information as allowed in your device permissions;

• social media account names or tags (where you have engaged with us on a social media platforms);

• payment information where you have paid by credit card, debit card or “buy now pay later”, and information about your credit history;

• images from video surveillance, body cameras and other cameras used in and around our stores (including in car parks, pick up areas, store entrances and publicly accessible spaces);

• images from facial recognition software;

• inferred information and characteristics as a result of undertaking data analysis;

• information provided in surveys, feedback, complaints or commentary;

• if you apply for employment with us, details regarding your employment history, educational qualifications, referee details and similar information.

We will usually collect personal information about you directly from you. We may also collect personal information from our Related Companies and from trusted third parties such as Flybuys as described in ‘Our relationship’ sections below. We may also collect deidentified data from (and share deidentified data with) Related Companies for data analysis purposes.

Often you can deal with us anonymously or by using a pseudonym, but in this situation we may not be able to provide you with the full range of services available. For example, we will not be able to deliver products to you if you do not provide us with address details for the delivery.

2. The main ways we collect personal information are:

• during your order or purchase of products from us;

• when you contact or visit us, including visiting a store, making an inquiry, making a complaint or providing feedback, seeking a refund, attending an event, or if you are a supplier or service provider in connection with the supply of products and services by your business to us;

• if you access our website or apps, including by the use of cookies, tags and pixels, which may track what you view on our website or apps and also other websites/apps that you visit. Cookies, tags and pixels may also come from third party services (such as Google and Facebook) for the purpose of collecting data to enable website or app performance measurement and personalised advertising;

• if you interact with us via social media platforms;

• if you subscribe to any of our publications (including any mailing lists) or subscriptions or use any of our apps;

• if you participate in any competition or promotion that we conduct;

• through our security cameras, body cameras or other cameras used in our stores (including in car parks, pick up areas, store entrances and publicly accessible areas);

• if you use a loyalty or membership program or team member discount in connection with a transaction or Cnctradinginc account;

• if you undertake any of our induction, safety or compliance processes;

• if you submit an employment application to us;

• from publicly available sources, including from Bissau Government agencies, internet search platforms and social media platforms such as Facebook;

• from any person authorised to act on your behalf or authorised to provide your personal information to us;

• from anyone sharing information with us for loss prevention and/or law enforcement purposes; and

• from our Related Companies and Flybuys.

Use and disclosure of personal information

3. We use and disclose your personal information in connection with carrying on our business, (including to provide products and services to you and relating to our involvement in loyalty schemes or membership programs that we participate in) and in some circumstances for the businesses of the Wesfarmers group of companies.

4. We may use your personal information to:

• sell, deliver, administer, improve and personalise our products and services;

• administer our website and apps and personalise your experience on them;

• provide advice regarding our products and services to you;

• process payments and credit checks, and to provide layby services;

• manage our stores, supply arrangements and inventory;

• consider feedback and remedy complaints that you may make to us, communicate with you and operate our customer service centre;

• provide refunds and exchanges and undertake and administer product recalls;

• promote and advertise our products and services (e.g. by including your feedback in our advertising) and to undertake competitions and events;

• personalise advertising and content displayed to you (including the layout and content of our website/app, and advertisements displayed to you on or via third party websites, apps or platforms such as Facebook);

• monitor our sales of products and services and for quality control purposes, including undertaking customer surveys and analysis, or seeking feedback from customers;

• assist in determining your product or service preferences and preferred store locations or to direct you to your closest stores when using our websites or apps;

• undertake database compilation and management, data processing, data analysis and matching, market research or trend analysis (including with information obtained from our Related Companies and Flybuys) to better understand our customers’ preferences, personalise websites/apps and (where you have consented to receiving offers or direct marketing) to offer products or provide services of greater interest to you or engage in direct marketing;

• to derive insights about you in order to better understand your preferences and interests, personalise your experience, enhance the products and services you receive, and to tell you about products and services that may be of interest to you. We may also use Related Companies, Flybuys and trusted service providers to undertake the process of creating these consumer insights

• in the case of our suppliers or service providers, to manage the provision of products and services to us;

• to monitor and measure the use of our websites or apps, including web-based referral channels, data entered and digital behaviour such as links clicked;

• to assist us in ensuring security, health and safety and customer and team member protection in our stores (including car parks, pick up areas store entrances and other publicly accessible areas);

• to assist us in administering our policies, or to investigate complaints in relation to team member conduct;

• in the case of images from facial recognition software and body cameras, for loss prevention or store safety purposes;

• in the case of inferred characteristics produced through data analysis, for improving products and service offerings;

• to recruit and assess our employees or engage contractors;

• to maintain and update our records; and for purposes related to any of the above or which are disclosed to you at the time the relevant personal information is collected.

5. We work with a number of third parties in carrying on our business and may disclose your personal information to:

• third parties to facilitate the provision of products and services to you (including to facilitate repairs, replacements and customer recalls), such as product manufacturers and suppliers and logistics service providers;

• marketing, advertising and promotions services providers and event organisers in connection with our marketing, advertising and events;

• third party platforms who display advertising or content (including personalised advertising) based on your personal information or preferences (including social media platforms such as Facebook);

• third parties who provide services to us in connection with our business operations, including data monitoring, data analysis and data matching activities, monitoring trends in customer preferences or transactions and the operation and maintenance of our website/apps;

• credit reporting agencies, for example if your business is a supplier to us;

• third parties who provide other administrative and operational services to us in connection with our business, including financial institutions, security services providers, market research or feedback collection companies, IT service providers, payment processers and collectors, mailing houses and card manufacturers;

• our professional advisers to enable them to provide services to us;

• third parties necessary to assist us in investigating and preventing any potential, suspected or actual breaches of policy or law, fraudulent activities, loss prevention activities;

• law enforcement agencies, government agencies or other third parties, where required under or authorised by law;

• other persons notified to you at the time the relevant personal information is collected; and

• our Related Companies and Flybuys who may use that information to undertake data analytics and matching to enable them to better understand your requirements and preferences, and (if you interact with that business) to personalise and improve their offer to you and to offer products or providing services to you or send direct marketing to you (where you have consented to receiving offers or direct marketing from them);

• in special circumstances – for example, if we were to sell our business or part of our business, your information may be disclosed to potential purchasers and their advisers as part of that process;

• from time to time we may provide aggregated and de-identified information to other business partners for various purposes.

Our relationship with Flybuys

6. As a participant in Flybuys we may collect from Flybuys and other Related Companies that are participants in Flybuys (and share and combine personal information with Flybuys and other Related Companies that are participants in Flybuys) the personal information of Flybuys members (including contact details, transaction information, interactions with Flybuys and insights from interactions with Flybuys and other Related Companies that are participants in Flybuys):

• to allow us to engage with them and provide more personalised and targeted advertising when they use our website/apps, social media and other platforms;

• to allow us to personalise the communications, marketing offers, customer surveys and trading updates that we send;

• to enable us to improve product offerings, service offerings, advertising and offers based on member shopping and browsing habits;

• to develop aggregated insights about the preferences of Flybuys members who shop with us;

• for data analytics including for insights and strategic and operational decision making;

• for product safety-related matters (including recalls);

• for other purposes where you have provided consent to Flybuys or us; and

• for other purposes described in flybuys’ Privacy Policy.

We will also collect personal information about Flybuys members who are Cnctradinginc customers from those customers and from other sources set out in this Policy, and may combine the personal information that we receive from Flybuys with other personal information we collect about the customer.

We may retain personal information about a customer who is a Flybuys member after they have ceased to be a Flybuys member (or after we have ceased to be a Flybuys participant) if we need to use the information for a reason set out above or any other lawful purpose.

Our relationship with OnePass

7. As a Participating Brand in OnePass we may collect from OnePass and other Participating Brands (and share and combine personal information with OnePass and other Participating Brands) the personal information of OnePass members (including contact details, historical and future transaction information, historical and future interactions with OnePass and other Participating Brands and insights from interactions with OnePass and other Participating Brands):

• to allow us to engage with them and provide more personalised and targeted advertising when they use our website/apps, social media and other platforms;

• to allow us to personalise the communications, marketing offers, customer surveys and trading updates that we send;

• to enable us to improve product offerings, service offerings, advertising and offers based on shopping and browsing habits;

• to develop insights about the preferences of OnePass members;

• for data analytics including for insights and strategic and operational decision making;

• for product safety-related matters (including recalls);

• for other purposes where they have been notified, provided consent to OnePass or us, or which are otherwise permitted by law; and

We may combine the personal information received from OnePass with other personal information we collect from or about you. That combined information may be shared with OnePass and its Participating Brands in accordance with our Privacy Policy and the OnePass Privacy Policy.

We may retain personal information about our customers after they cease to be a OnePass member (or after we have ceased to be a OnePass Participating Brand) for the uses set out in this Privacy Policy or any other lawful purpose.

Related Companies

8. As mentioned in this Policy we exchange and combine personal information with our Related Companies to enable us and them to undertake a range of important functions. The personal information that we exchange and combine with our Related Companies includes:

• details about your purchases and transaction history with Cnctradinginc and Related Companies, product and service preferences, and details about purchases and transaction history with us and the Related Companies.

• information about your use of Cnctradinginc and Related Company websites and apps (using cookies, tags and pixels) including your searches and search history on them, and the products you have viewed, added to cart and/or purchased;

We may use this personal information (and disclose it to our Related Companies):

• to undertake data analytics and matching to enable us to better understand your requirements and preferences and for insights and strategic and operational decision making;

• to personalise the appearance of our website and apps, to invite you to complete a product review or send you targeted and personalised news, offers and promotions of our products and services;

• to send direct marketing or personalised communications to you (where you have consented to receiving direct marketing or personalised communications) and to allow us to better us to personalise the communications, offers, surveys and updates that we send;

• to display targeted advertising;

• for product safety-related matters (including recalls);

• to develop aggregated insights about the preferences of our customers;

• to enable us to improve product and service offerings, advertising and offers based on member shopping and browsing habits;

• for other purposes where you have provided consent to us; and

• for other purposes described in this Policy,

and our Related Companies may use it for the similar purposes relating to their operations.

Transfer of information overseas

9. Some of our service providers may be located overseas or may store information (including your personal information) that we provide to them overseas. We may also provide your personal information to Cnctradinginc affiliates operating Cnctradinginc overseas and to our Related Companies that are located overseas. Therefore, the personal information you provide to us may be held overseas. We require overseas recipients to use personal information only for the purpose provided and to implement confidentiality and data protection arrangements. Your information may also be stored on computer servers located outside of Bissau. Any offshore disclosures will be to entities located in the United States of America, the United Kingdom, European countries and the Asia Pacific region (including but not limited to China, India, Bangladesh, Singapore, Vietnam and Hong Kong).

Marketing, advertising and customer insights

10. From time to time, we may also use and disclose the personal information we collect about you (including directly from you, and also from third parties such as our Related Companies and Flybuys) to contact you or send you direct marketing and personalised communications, to personalise the appearance of our website and apps to you, to invite you to complete a product review, to send you targeted and personalised news, offers and promotions of our products and services and provide targeted advertising content to you (including through third party websites, apps and social media platforms such as Facebook).

11. Generally, we will provide direct marketing and personalised communications to you where you have requested or consented to receiving them. If you do not wish to receive direct marketing or personalised communications you can opt-out by contacting us at the address listed below, by using the unsubscribe link or opt out details provided in the direct marketing communication or in the case of online advertising by changing your browser options in the digital platforms you use such as Google or Facebook.

12. The third parties who assist us in marketing and advertising to you or the device you use may use cookies, pixels or tags, to obtain information about your preferences when you access online platforms, apps or websites other than Cnctradinginc’s website/apps. Your preferences collected in this manner may be disclosed to us. You can manage your preferences regarding targeted online advertising directly through the digital platforms you use, such as Google or Facebook.

Cnctradinginc is working with Google to improve online shopping experience across devices

13. If you are signed into your Google account when you use Cnctradinginc Online, then Google may also combine data from your Google account with data about your use of Cnctradinginc Online, to help identify you to be shown relevant Cnctradinginc advertising online, across your devices. This is done using a Google service called Remarketing with Google Analytics, which links Google Analytics cookies (set by Cnctradinginc ) with Google advertising cookies (set by Google). Google Analytics helps website owners measure how users interact with website content. For more information:

Security and storage

14. Cnctradinginc will take reasonable steps to protect the security of your personal information that we hold. We have security measures in place to protect personal information under our control from misuse, interference, loss, unauthorised access, modification or disclosure. For example,Cnctradinginc seeks to ensure that personal information held electronically by or for Cnctradinginc is held on secured servers in controlled facilities.

Accessing and correcting your information and questions

15. You can request access to your personal information, or request that your information be corrected, by contacting us at the address below.

16. If you have a question about this Policy or wish to make a complaint about the way we have collected, used, held or disclosed your personal information, please contact us at the address below. We may need to contact you for further details.

17. If you wish to make a formal complaint, please make your complaint in writing to our Privacy Officer. We will consider your complaint promptly and contact you to seek to resolve the matter. If we have not responded to you within a reasonable time, you are entitled under the Privacy Act 1988 (Cth) to make a complaint to the Office of the Bissau Information Commissioner to resolve that complaint.

Changes to this Policy

19. Cnctradinginc may update this Policy from time to time. We may let you know of significant changes to this Policy by posting a notification on our website. The current version of this Policy will always be available on our website and was last updated in May 2022.