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PRIVACY POLICY

28/03/2022

This document is the Privacy Policy of Camp Australia Pty Ltd ABN 96 060 703 120
and its related entities ("Camp Australia", "we" or "us"). This Privacy Policy
applies to the collection of information in all aspects of Camp Australia's
operations including, but not limited to, enrolment, phone queries, emails sent
to Camp Australia, attendance at Camp Australia's services and the use of the
website operated by Camp Australia under the domain name
www.campaustralia.com.au ("website").

Camp Australia understands that your privacy is important to you and is
committed to respecting your rights and complying with all privacy obligations
under the Privacy Act 1988 (Cth) ("Privacy Act"), including the Australian
Privacy Principles ("Privacy Principles"), and the Education and Care Services
National Law Act ("National Law"). Camp Australia may also comply with relevant
State or Territory privacy legislation where applicable, for example in relation
to providing services to State or Territory Government agencies. The Privacy
Principles are designed to protect your privacy by regulating the way personal
information is managed. Under the Privacy Act, personal information is defined
as information or an opinion about an identified individual, or an individual
who is reasonably identifiable, irrespective of whether the information or
opinion is true or is recorded in a material form.

This Privacy Policy sets out how and when Camp Australia collects, uses and
discloses your personal information and credit information and how you may
personally access and request access to your personal information and credit
information.

The types of information Camp Australia collects may include information about
customers, government representatives, suppliers, employees, personal contacts
of corporate clients or suppliers, applicants for employment and other people
who come in contact with Camp Australia in the ordinary course of business. This
information is collected in a variety of ways, including directly from the
individual, by way of personal contact such as business activities and events,
as well as mail, telephone, email and through our website and the internet.

Camp Australia is not bound by the Privacy Act or the Privacy Principles in
relation to the handling of its own current or former employees' records, if
those records relate directly to the employment relationship.

COLLECTION OF PERSONAL INFORMATION

1. Purpose

Camp Australia collects and holds personal information about you and your child
that is reasonably necessary for or related to our activities and the services
we provide, and to fulfil administrative functions associated with these
services, including billing, entering into contracts with you and/or third
parties, collecting overdue payments and managing business relationships.
Everything Camp Australia does is centered around the optimisation of our
services and offerings to the betterment of families and children in our care.
As such, Camp Australia collects personal information of parents and guardians,
children, employees and stakeholders for the primary purposes of providing early
childhood education and care services and advocating for the well-being,
protection and development of children. Camp Australia will only use your
personal information for this purpose or a related secondary purpose for which
such personal information was collected as outlined above.

2, Kinds of information we collect

2.1 The kinds of personal information that Camp Australia collects and holds may
include, but is not limited to, your name, email address, home or work address,
telephone number, and credit card details which are encrypted for your security.

2.2 We collect personal information when recruiting personnel, such as your
name, contact details, qualifications and work history. Generally we will
collect this information directly from you. We may also collect personal
information from third parties in ways which you would expect (for example, from
recruitment agencies or referees you have nominated). Before offering you a
position, we may collect additional details such as your tax file number and
superannuation information and other information necessary to conduct background
checks to determine your suitability for working with children.

2.2 The kinds of anonymous demographic information that Camp Australia collects
and holds may include, but is not limited to, post codes, age, gender,
preferences, interests and favourites.

2.3 The kind of computer hardware and software information that Camp Australia
collects and holds may include, but is not limited to, IP addresses, browser
type, domain names, access time and referring website addresses.

2.4 Camp Australia may collect information which is considered sensitive
information. The type of sensitive information that Camp Australia may collect
and hold will be pertaining to children and may include, but is not limited to,
medical management plans, allergy management plans, incident records, children's
age, attendance records, health records and child profiles. This information is
only collected as it is required by the National Law. Where children do not have
sufficient maturity and understanding to make decisions about their personal, or
sensitive, information, we will require their parents or guardians to make
decisions on their behalf.

3. Method of collection

3.1 Camp Australia may collect your personal information from a range of sources
including: directly from you, your use of the Camp Australia website, the use of
our standard forms, completing enrolment, attendance at a Camp Australia
service, promotions and events and from your subscription to receive Camp
Australia services information.

3.2 Camp Australia may also collect personal information from suppliers,
employees, prospective employees, personal contacts, third parties such as your
child's school, publicly available resources and through the ordinary course of
business. Camp Australia also collects and uses personal information for market
research purposes to optimise the delivery of our services.

4. Failure to provide your personal information

4.1 Camp Australia will provide you with the opportunity of remaining anonymous
or using a pseudonym in your dealings with us where it is lawful and practicable
(for example, when you are making a general enquiry). Generally it is not
practicable for Camp Australia to deal with you anonymously or pseudonymously on
an ongoing basis.

4.2 If you do not wish to provide your personal information to Camp Australia,
Camp Australia may not be able to provide you with our goods and services,
either to the same standard or at all pursuant to the requirements of the
National Law.

USE OF PERSONAL INFORMATION

5. Direct Marketing

5.1 Camp Australia will use or disclose your personal information to communicate
directly with you to inform you about Camp Australia's products or services,
upcoming promotions or events that may be of interest to you. Camp Australia may
conduct and contact you for the purpose of market research, even if you cease
being a customer of or otherwise stop acquiring services from us. This is to
ensure that longitudinal trends within Camp Australia are able to be identified
for the purpose of optimising our services. Camp Australia does not, and will
not, sell personal information or data to any other entity for any purposes.

5.2 If you have received direct marketing materials from us and you no longer
wish to receive direct marketing material from us, you are able to opt-out of
direct marketing or market research from Camp Australia by clicking the
unsubscribe button in the email, replying to the communication or contacting the
Customer Care Team on 1300 105 343 from 5am-9pm AEDT, 7 days a week - Closed on
National Public Holidays.

6. Managing your account

6.1 Camp Australia may use or disclose your personal information to manage your
account by undertaking tasks such as updating Camp Australia records and keeping
your contact details up to date, responding to any enquiries you make or any
complaints you lodge, or providing you with services you have requested.

6.2 Camp Australia will use and disclose your personal information for the
purpose of collecting debts owed by you and to undertake debt recovery and
enforcement activities. Such personal information may include your statement,
records of non-payment of issued statements and details of overdue monies on
your account. This information may be shared with debt collectors, credit
management agencies, the Victorian Civil and Administrative Tribunal ("VCAT")
and other tribunals and courts for the purpose of collecting outstanding debts.

6.3 Camp Australia's only ongoing data sharing arrangement is with the
Australian Government as this is a requirement in order to obtain and implement
any Federal, State or Local based Government rebate or benefit scheme, including
the Child Care Subsidy.

7. Operations of our services

Camp Australia will use your personal information for the purpose of undertaking
usual business activities during the operation of our services. In line with the
provisions of the National Law and the National Quality Framework, Camp
Australia will also use your (and your child's) personal information to ensure
the delivery of an education and care service by documenting your child's
learning and development, individual needs, interests and feedback as required
by relevant Australian Government Departments in the delivery of a quality care
service.

DISCLOSURE OF PERSONAL INFORMATION

8. Related entities, contractors and service providers

Camp Australia may disclose your personal information to our related entities
located in Australia, service providers and contractors for the purpose of
delivering a safe, fun, quality and engaging education and care service for your
child. This may include sharing information with excursion and incursion
providers, emergency services or your child's school to ensure continuity of
care for your child. Camp Australia will only disclose your personal information
for the purpose it was collected, a reasonably expected or related secondary
purpose or for other purposes explained at the time of collection.

9. Professional Advisers, administration and management

Camp Australia may disclose your personal information for a range of
administrative, management and operational purposes. This may include: for
administering billing, payments and debt recovery, planning, managing,
monitoring and evaluating our services, risk management and obtaining advice
from our professional advisers who assist in the operation of the business
including but not limited to legal advisers, business advisers and auditors.
Camp Australia will only disclose your personal information for the purpose it
was collected, a reasonably expected or related secondary purpose or for other
purposes explained at the time of collection.

10. Australian Government

10.1 Camp Australia will share your personal information with the Australian
Government and/or regulatory authorities as is required or authorised by law
including for the purpose of obtaining and implementing any Federal, State or
Local based Government rebate or benefit scheme, including the Child Care
Subsidy.

10.2 Camp Australia may disclose personal information about you or your child to
child protection agencies or family support agencies when it is reasonably
believed that a child is at risk or significant harm, as is required by the
National Law and Camp Australia's Child Protection Policy.

**11. Camp Australia may disclose personal information to the VCAT and/or other
tribunals and courts for the purpose of debt collection. Overseas disclosures

Camp Australia is an Australian based organisation and does not disclose your
personal or credit information to any overseas recipients that are not subject
to law, binding schemes and contracts which are substantially similar to the
Australian Information Privacy Principles.

SECURITY OF YOUR PERSONAL AND CREDIT INFORMATION

12. Security of your personal information

12.1 Camp Australia will take all reasonable steps as defined by the Privacy
Principles to ensure that your personal information is kept securely and is not
misused, interfered with or disclosed unless in accordance with this Privacy
Policy.

12.2 Personal information that is stored in paper form, including documentation
on site at a Camp Australia Outside School Hours Care service or Vacation Care
service, will be stored securely and in line with the Privacy Principles and
National Law. Personal information collected in paper form may be converted to
electronic form for use or storage (with the original paper-based documents
either archived or securely destroyed). All electronic records of personal
information will be kept in secure databases (including trusted third party
storage providers based in Australia).

12.3 Camp Australia will destroy or de-identify your personal information where
it is no longer necessary to retain it (other than for the purposes of market
research, unless you decide to opt out of market research) or to fulfill the
purposes for which it was collected or as required by law.

13. Security of your credit information

13.1 In addition to taking all reasonable steps as defined by the Privacy
Principles to ensure that your credit information is kept securely and is not
misused, interfered with or disclosed, Camp Australia will encrypt this
information.

13.2 Camp Australia will retain your credit information for any periods required
by law or where we need to retain that information for the purpose it was
collected, after which it will be destroyed and/or deleted.

ACCESS, CORRECTION AND COMPLAINTS

14. Access to, and correction of, your personal information

14.1 You are entitled to request access to your personal information held by
Camp Australia by contacting the Customer Care Team on 1300 105 343.

14.2 We will take reasonable steps to ensure that the personal information we
collect, use or disclose is accurate, complete or up to date. You can help us to
do this by letting us know if your personal details change. You are able to
manage your personal information including updating, changing or removing
personal information via the Parent Portal, accessible on the Camp Australia
website. You can also call the Customer Care Team on 1300 105 343 to update,
change or remove personal information.

14.3 Camp Australia may deny your request to access or correct your personal
information in limited circumstances, in accordance with the Privacy Principles.
In these circumstances, we will provide you with a reason for our decision, and,
in the case of a request for correction, we will include a statement with your
personal information about the requested correction.

15. Complaints regarding the handling of your personal information

15.1 You are able to make a complaint with regards to the collection, disclosure
or retention of your personal information by contacting the Customer Experience
Manager on 1300 105 343 or by post to Level 1, 207-213 Waverley Road, Malvern
East, VIC 3145.

15.2 The Customer Experience Manager will first consider your complaint to
determine whether there are simple or immediate steps which can be taken to
resolve the complaint. We will generally respond to your complaint within a
week.

15.3 If your complaint requires more detailed consideration or investigation, we
will acknowledge receipt of your complaint within a week and endeavour to
complete our investigation into your complaint promptly. We may ask you to
provide further information about your complaint and the outcome you are
seeking. We will then typically gather facts, locate and review relevant
documents and speak with individuals involved. In most cases, we will
investigate and respond to a complaint within 30 days of receipt of your
complaint. If the matter is more complex or our investigation may take longer,
we will let you know.

15.4 If you are not satisfied with the response to your query or with the
resolution of your request or complaint, you may make a further complaint to the
Office of the Australian Information Commissioner ("OAIC"). The OAIC can be
contacted by telephone on 1300 363 992 or by using the contact details on the
website www.oaic.gov.au.

USE OF OUR WEBSITE

16. Use of Cookies

16.1 Camp Australia uses ‘cookies' to provide a secure, personalised experience
on the Camp Australia website. Cookies are small data files that a website is
able to place on a user's computer hard drive or in its memory to record aspects
of that user's experience of the website.

16.2 You have the ability to accept or decline cookies, most browsers
automatically accept cookies however you can modify your browser settings to
decline cookies if you prefer.

16.3 The Camp Australia website uses cookies in two different ways:

(1) When you are browsing any part of the Camp Australia website we will use a
cookie that is stored on a computer's hard drive to track which areas of the
site are accessed. This cookie does not allow us to identify any individual; and

(2) When you register and sign in to the secure, personalised parent portal on
the Camp Australia website, we will send you a secure cookie that will maintain
the security of your session. This secure cookie will be stored in your
computer's memory rather than on your hard drive, and will only last for the
duration of the session.

17. Use of clear gifs

The Camp Australia website uses clear gifs for technical spacing purposes
however we do not use clear gifs or web beacons to track user activity.

18. Links

The Camp Australia website may contain links to other websites operated by third
parties. We make no representations or warranties in relation to the privacy
practices of any third party website and we are not responsible for the privacy
practices or the content of any third party website. Third party websites are
responsible for informing you about their own privacy practices.

VARIATIONS AND UPDATES TO THIS PRIVACY POLICY

19. Variation and update of the Privacy Policy

19.1 Camp Australia will review this Privacy Policy regularly, and may make
changes from time to time. If so, Camp Australia will update this Privacy Policy
on the Camp Australia website to reflect those changes. The updated version of
this Privacy Policy will be effective from the date of posting on the Camp
Australia website. We recommend that you visit our website regularly to keep up
to date with any changes.

19.2 This Privacy Policy was last updated in March 2021.

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In the spirit of reconciliation, Camp Australia acknowledges the Traditional
Custodians of country throughout Australia and their connections to land, sea
and community. We pay our respect to their Elders, past, present and emerging
and extend that respect to all Aboriginal and Torres Strait Islander peoples
today.

All rights reserved copyright © 2022 Camp Australia



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