A. INTRODUCTION

This Privacy Policy is Curragh’ official privacy policy and it applies to all personal information collected by Curragh. In this policy we explain how and why we collect your personal information, how we use it, and what controls you have over our use of it.

Curragh is committed to protecting and safeguarding your privacy when you deal with us and to complying with Commonwealth legislation governing privacy of personal information by businesses. We understand and appreciate that you are concerned about your privacy and about the confidentiality and security of information.

From 21 December 2001, amendments to the Commonwealth Privacy Act affect the way in which we may deal with information you provide about yourself to us. In particular the 10 National Privacy Principles set out a code of behaviour for relevant businesses in the way they must deal with such information.

B. COLLECTION OF INFORMATION

Some information provided to us by clients, customers, contractors and other third parties might be considered private or personal. Without these details we would not be able to carry on our business and provide our services to you. We will only collect such personal information if it is necessary for one of our functions or activities.

Curragh collects information in a number of ways from individual persons in different situations. In particular, personal information is collected from people in the following situations by Wesfarmers Energy Ltd:

• When web-site users fill out an on-line registration form or send an e-mail, when individuals call a call-centre established by the company, or when individuals fill out an order form for goods or services;
  
• If you contact Curragh, we may keep a record of that correspondence;
  
• When you place an order on the Wesfarmers Energy Ltd Web Site to purchase goods or services from Wesfarmers Energy Ltd we may require you to provide us with contact information including your name, address, telephone number or email address and financial information (such as credit card details);
  
• Financial information that is collected via the Web Site is used by us to bill you for products and services. Any credit card numbers that are collected are collected for the purpose of transaction approval and funds transfer. The financial information we collect from you is strictly confidential.

At or before the time the personal information is collected by us we will take reasonable steps to ensure that you are made aware of who we are, the fact that you are able to gain access the information held about you, the purpose of the collection, the type(s) of organisations to which we usually disclose the information collected about you, any laws requiring the collection of the information and the main consequences for you if all or part of the information is not collected.

C. USE OF INFORMATION COLLECTED AND DISCLOSURE OF PERSONAL INFORMATION TO OTHERS

We may use or disclose personal information held about an individual for the primary purpose for which it is collected (e.g. provision of our services, including administration of our services, notification to you about changes to our services, record-keeping following termination of our services to you and technical maintenance). We may also use such information for a purpose related to the primary purpose of collection and where it would reasonably be expected by you that we would use the information in such a way. This information is only disclosed to persons outside our business in the circumstances set out in this policy or as otherwise notified to you at the time of collection of the information.

In addition we are permitted to use or disclose personal information held about you:

• Where you have consented to the use or disclosure;
  
• Where we reasonably believe that the use or disclosure is necessary to lessen or prevent a serious, immediate threat to someone’s health or safety or the public’s health or safety;
  
• Where we reasonably suspect that unlawful activity has been, is being or may be engaged in and the use or disclosure is a necessary part of our investigation or in reporting the matter to the relevant authorities;
  
• Where such use or disclosure is required under or authorised by law (for example, to comply with a subpoena, a warrant or other order of a court or legal process);
  
• Where we reasonably believe that the use or disclosure is reasonably necessary for prevention, investigation, prosecution and punishment of crimes or wrongdoings or the preparation for, conduct of, proceedings before any court or tribunal or the implementation of the orders of a court or tribunal by or on behalf of an enforcement body.

D. LINKS

Our Web Site may contain links to other Web Sites and those third party Web Sites may collect personal information about you. We are not responsible for the privacy practices of other businesses or the content of Web Sites that are linked to our Web Site. Curragh encourages users to be aware when they leave the site and to read the privacy statements of each and every web site that collects personally identifiable information.

E. SECURITY AND STORAGE

Curragh places a great importance on the security of all information associated with our customers, clients and contractors. We have security measures in place to attempt to protect against the loss, misuse and alteration of personal information under our control.

Personal information is de-identified or destroyed securely when no longer required by us.

Curragh retains the information you provide to us including your contact and credit card details to enable us to verify transactions and customer details and to retain adequate records for legal and accounting purposes. This information is held on secure servers in controlled facilities.

Information stored within our computer systems can only be accessed by those entrusted with authority and computer network password sanctions.

No data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we strive to protect users' personal information, Curragh cannot ensure or warrant the security of any information transmitted to it or from its online products or services, and users do so at their own risk. Once Curragh receives your transmission, it makes every effort to ensure its security on its systems.

You should keep in mind that whenever you voluntarily disclose personal information online - for example, through email - that information may in some circumstances be collected and used by others. If you post personal information online that is accessible to the public, you may receive unsolicited messages from other parties in return.

Ultimately, you are solely responsible for keeping your passwords and/or account information secret. You should be careful and responsible whenever you are online. While we cannot ensure or guarantee that loss, misuse or alteration of data will not occur, we use our best efforts to prevent this.

Your personal information delivered by our Web Site is password-protected so that you and only you have access to this personal information. We recommend that you do not divulge your password to anyone. Also remember to sign out of our Web site and close your browser window when you have completed using the services of the site.

F. ACCESS TO AND CORRECTION OF PERSONAL INFORMATION

Curragh is committed to maintaining accurate, timely, relevant and appropriate information about our customers, clients and web-site users.

So long as your request for your personal information is in accordance with the National Privacy Principles, then we will give you access to that information. Your initial queries should be directed to
Michael Bache
email: mbache@wesenergy.com.au
ph: 08 9333 0411.

Inaccurate information will be corrected upon receiving advice to this effect from you. To ensure confidentiality, details of your personal information will be passed on to you only if we are satisfied that the information relates to you.

the personal information held about you by us then we will provide reasons for such refusal.

G. COMPLAINTS

If you have a complaint about our Privacy Policy or the collection, use or safe disposal destruction of your personal information, your complaint should be directed in the first instance to us at:

Michael Bache
Wesfarmers Energy Pty Ltd
276 Leach Hwy
Myaree WA 6154

Email: mbache@wesenergy.com.au
Ph: 08 9333 0411

We will investigate your complaint and attempt to resolve any breach that might have occurred in relation to the collection, use or destruction of personal information held by us about you in accordance with the Commonwealth Privacy legislation. If you are not satisfied with the outcome of this procedure then you may request that an independent person (usually the Commonwealth Privacy Officer) investigate your complaint.

H. TRANSFER OF INFO OVERSEAS

Pursuant to the National Privacy Principles we may transfer personal information we have collected about you to someone other than you in a foreign country only if:

• We reasonably believes that the recipient of the information is subject to a law, binding scheme or contract which effectively upholds principles for fair handling of the information that are substantially similar to the National Privacy Principles; or
  
• You consent to the transfer; or
  
• The transfer is necessary for the performance of a contract between the you and us, or for the implementation of pre-contractual measures taken in response to your request; or
  
• The transfer is necessary for the conclusion or performance of a contract concluded in the interest of you between us and a third party; or
  
• (i) The transfer is for the benefit of you;
  (ii) it is impracticable to obtain the consent of you to that transfer; and
  (iii) if it were practicable to obtain such consent, you would be likely to give it; or
  
• We have taken reasonable steps to ensure that the information that we have transferred will not be held, used or disclosed by the recipient of the information inconsistently with the National Privacy Principles.

I. COOKIES

Curragh collects information from the site using “IP files” and in the near future, Curragh may consider the use of “cookies”.
A “cookie” is a message given by a web browser (which displays your chosen web pages on your computer) to a web server (which delivers the web pages to your computer). The message is stored by your browser and will be used each time you access the site that the cookie relates to.
The main objective of the cookie is to identify users and to personalise their visit to the site by customising web pages. They may also be used to estimate our audience size and patterns, to track preferences, to improve and update our Web Site; and to ensure that the correct data is being sent to your computer. If you reject the cookie or delete the cookie files from your hard drive, you can still use our site however you may be limited to some areas of our site.

Cookies are specific to the server that created them and cannot be accessed by other servers, which means they cannot be used to track your movements around the web. Cookies do not personally identify customers or passwords. Credit card information is not stored in cookies. No personal details are contained in the cookie, and they are not used to retrieve any personal information.

When you visit the Curragh site to read, browse or download information, our system will record/log your IP address (the address which identifies your computer on the internet and which is automatically recognised by our web server), date and time of your visit to our site, the pages viewed and any information downloaded. This information will only be used for the purpose of site analysis and to help us offer you improved online service. We may automatically collect non-personal information about you such as the type of Internet browsers you use or the site from which you linked to our Web Sites. You cannot be identified from this information and it is only used to assist us in providing an effective service on our Web Sites.

J. CHANGES TO PRIVACY POLICY

If Curragh decides to change its Privacy Policy, it will post changes at
www. kleenheat.com.au on this Privacy Policy page so that users are always aware of what information is collected, how it is used and the way in which information may be disclosed. As a result, please remember to refer back to this Privacy Policy regularly to review any amendments.

K. CONTACTING US

If you require further information regarding our Privacy Policy, please contact us at the following address:

Michael Bache
Wesfarmers Energy Pty Ltd
276 Leach Hwy
Myaree WA 6154

Email: mbache@wesenergy.com.au
Ph: 08 9333 0411

Should you wish to read more information on privacy legislation or the National Privacy Principles we recommend that you visit the Federal Privacy Commissioner’s website at www.privacy.gov.au.