Twin Creeks Holdings (Australia) Limited and Twin Creeks Golf & Country Club Limited
(Twin Creeks) has developed the following Privacy Policy to ensure that any data collected and stored by or on behalf of Twin Creeks and related entities is done so in a responsible manner. Twin Creeks' commitment to its Privacy Policy ensures that individuals are made aware of when information about them is being collected, the purpose for which it is being collected, whether the information may be passed on to third parties and the identity of those parties and the rights of individuals to have some control over the way any information about them is handled and maintained.

Each employee of Twin Creeks and any external consultants engaged by the Club are expected to adhere to our privacy policy. Those employees and consultants who have access to customer information will have copies of our Privacy Policy and the contact details of Twin Creeks Privacy Officer.

We collect information in order to promote the facilities of Twin Creeks, to support current investors of the development and to improve Twin Creeks' services and commitment to open communication.

We may also obtain information about customers from third parties to identify those persons we think will be interested in specific aspects of Twin Creeks development. We use this information to offer these individuals further details of Twin Creeks' facilities and services.

Because we strongly advocate the protection of all individuals' details and personal information, we believe that the adoption and implementation of our Privacy Policy represents good business practice and will assist us in serving the interests of our members, residents, customers and the wider community.

This Privacy Policy guides our conduct in the collection, use, release and security of customer information.

The following Privacy Policy has been developed to adhere to the National Privacy Principles outlined in the Act. If you have any comments or questions about Twin Creeks' Privacy Policy, please contact our Privacy Officer. For more information about the Privacy Commissioner’s guidelines, call the Privacy Hotline on 133 363 992 (local call charge) or visit www.privacy.gov.au.

Twin Creeks' Privacy Policy

• How and why we collect personal information
• How we use personal information
• How we ensure the quality and accuracy of personal information
• Your ability to access and correct personal information
• How we protect personal information
• Children, customer information and our Internet site
• Customer information and linked Internet sites
• Changes to our Privacy Policy
• Contact us

How and why we collect personal information

We only collect customer information that is needed, and we inform customers how we use it. Most of the personal information we hold has been provided directly to us by our customers for a specific purpose.

We limit the collection of information about our customers to information which is required to provide our services, answer their queries, to provide better information, to offer new updates on aspects of our development, and to fulfil any legal and regulatory requirements. For example, Golf Membership Prospectus application forms require information which, if accepted, will be forwarded in part to the Australian Securities and Investments Commission, as well as information we require to process your application. We inform our customers about the general uses of information we collect about them, and provide additional explanation if customers request it.

We may collect certain information from third parties
We may also obtain information about prospective customers from our staff or other third parties to identify those persons whom we think will be interested in specific aspects of Twin Creeks development. We use this information to offer these individuals further details of Twin Creeks' facilities and services.

We may collect certain information when you browse our Internet site
If you are only browsing our Internet site, we do not collect personal information -such as your name, address, phone number or E-mail address . However, technology allows us to identify your movements, providing us with constructive feedback about our site so that we can identify the most effective areas and improve the less popular ones. This is done via what is more commonly referred to as "cookies", which are files that track the Internet pages you have visited but which, by themselves, cannot be used to find out the identity of any user. The only personal information cookies contain, is information you provide yourself.

We do not collect sensitive information.
Twin Creeks does not require or collect information about a person that is considered sensitive under the Act. Such information includes a person’s political, social or religious beliefs or affiliations; race, ethnic origin or national origins; sexual preferences or practices; health or medical information; lifestyle, character or reputation.

How we use personal information
Use of information for primary purpose
We use personal information primarily for the purpose for which it was collected. Because most of our information is collected from you daily, you will normally be aware of the purpose of the collection.

Use of information for a secondary purpose – providing you with a better level of service.
We may share information about you so that we can provide a better level of service to members and residents. For example, if you change address we may pass this information on to provide you with the best level of information and detail about our development. However, we will only do this in the following circumstances:

• where you have consented,
• where the secondary purpose is directly related to the primary purpose and you would reasonably expect us to use or disclose the information in such a way, or
• where we are permitted or required by law, or it is in the interests of public safety to do so.

We extend these privacy principles to our business relationships.
In some cases, we contract with other companies to perform services for us, which may involve the use of your personal information. Examples of this include trust account administrators and golfing, housing and government regulatory authorities. We provide these bodies only with such information about you as they need to perform their services. We expect the companies we select as our business partners to honour our privacy principles in the handling of customer information. Also, they are legally obliged to use information about you only to perform the services we have contracted them to provide. In selecting business partners, Twin Creeks looks at how these businesses support and administer strong and effective privacy guidelines and practices.

Use of information provided via our web site.
If you would like to register for information via our Internet site, we will need you to provide us with some personal information, including your E-mail address. We only collect information about you, which is required to process your request, and also to satisfy any legal requirements.

If you are a registered user of aspects of Twin Creeks website, we will use the online and offline information we have about you as a Twin Creeks registrant, as well as information lawfully available from other organisations, to provide information and services as required in our normal course of business.

How we ensure the quality and accuracy of personal information
We ensure that customer data is processed promptly, accurately and completely.

If you consent to our collecting, storing and using certain personal information, we will retain your personal information for a reasonable period of time.

We provide methods for you to access and correct your information
Part of our commitment to the quality and accuracy of any personal information we store, is reflected in the fact that you have the opportunity to access your personal information in order to verify that it is up to date.

You can contact our Privacy Officer at any time if you would like details of any personal information we may hold about you or if you would like us to correct it. Depending on the nature of your request, we may ask you to complete a personal data access form, and to provide adequate proof of identification.

Our right to refuse access or correction
We reserve our right to refuse your request for access or correction if, for example, we consider your request to be frivolous or vexatious, or if we are legally entitled to do so.

If we refuse your request, we will give you our reasons. If we refuse your request to correct information we hold about you, we will give you the opportunity to post a statement of your claim where we hold your personal information.

How we protect the information collected
We use information security safeguards.
Access to customer data is limited to those employees of our Club who specifically need it to carry out their business responsibilities. This extends to protecting personal information from misuse and loss, as well as from modification and disclosure.

Children, customer information and our Internet site
We do not use www.twincreeks.com.au to knowingly solicit information from or market to children or young persons under the age of 18.

Customer information and linked Internet sites
www.twincreeks.com.au contains links to other Internet sites. Twin Creeks is not responsible for the content and the privacy practices of the other Internet sites. Twin Creeks encourages you to examine each site’s privacy policies and for you to make your own decisions regarding the reliability and correctness of the material and information found.

We may make changes to our Privacy Policy
Twin Creeks reserves the right to revise this Policy at any time and those people who volunteer their personal details to Twin Creeks are deemed to acknowledge and be bound by this policy and any changes made to it. This in no way affects the protection afforded to you by the relevant laws according to which this Privacy Policy was developed.

How to contact us
If you have any other questions about Twin Creeks' Privacy Policy, please contact us at the following address:

Suite 605, Edge Cliff Centre,

203-233 New South Head Road,

Edgecliff NSW 2027

or by email at: privacy@twincreeks.com.au