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Privacy Policy - March 2014

This Privacy Policy sets out Asahi Beverages Pty Ltd "AB" commitment to safeguard your Personal Information in the course of conducting our business, and describes the purposes for which we may collect, store, use and disclose your Personal Information.

1 Some useful definitions

In the Privacy Policy:

- Personal Information means information about an individual, whose identity is apparent or can reasonably be identified from that information (for example, a person’s name, address, phone number, date of birth).

- AB means Asahi Beverages Pty Ltd ACN 004 243 994 of level 5, 111 Cecil Street, South Melbourne VIC 3205 Australia and, where those entities do not have a separate privacy policy, members of the AB Group (in particular Asahi Beverages Australia Pty Ltd ACN 011 059 939 and Asahi Beverages Services Australia Pty Ltd ACN 101 168 192).

- AB Group means any direct or indirect parent, subsidiary, or sponsor or an “Associated Entity” of AB (as that term is defined under the Corporations Act 2001 (Cth).

- Sensitive Information includes information about race, ethnicity, political opinion, memberships of political associations, religious beliefs, philosophical beliefs, membership of trade unions, sexual preference or practices, criminal records or health information.

2 Does the Privacy Policy apply to me?

Our Privacy Policy applies to all people, except AB employees, who deal with AB.

This includes consumers of AB products, individuals who participate in a game, promotion, survey or other feature conducted or operated by AB, and individuals who use the AB website. It also includes suppliers to AB, individuals or other entities that enter into sponsorship or other agreements with AB and customers who purchase AB products.

3 Privacy Laws

Our Privacy Policy is governed by Australia’s Privacy Act 1988 (Cth) (the Privacy Act).

4 When do we ask for personal information and how do we use it?

AB collects your Personal Information so that we can perform our various functions and activities.

AB may request, hold, and use your Personal Information in the following circumstances:

- to verify your identity

- to enable you to participate in promotions and other activities

- to provide you with products or services that you have requested, and to provide you with any other benefits you may subsequently be entitled to in relation to these products and services

- to manage and administer a product or service, including charging, billing and collecting debts

- to conduct checks for creditworthiness and fraud

- to provide you with news and information in relation to AB and our products and services

- to develop and improve products and services

- to promote and market to you products, services and special offers made available by us or the AB Group, licensees and suppliers

- to maintain and develop our business systems and infrastructure, including testing and upgrading these systems

- to comply with our legal obligations, including for the purpose of or in connection with legal proceedings or if necessary for establishing, defending or exercising legal rights

- for other purposes that are notified to you prior to you giving your information to us or that are authorised or required by law

- related purposes to those set out above, where you would reasonably expect us to use or disclose information for that purpose

- to tell you about other products or services that may be of interest to you

- to consider any concerns or complaints you raise with AB

We seek to collect Personal Information from you directly where it is reasonable and practical for us to do so. However, we may also collect your Personal Information from third parties such as the AB Group, credit reporting agencies, or your representatives. We may also collect Personal Information about you by other means such as through our websites, or other publicly available sources of information.

Sometimes we may also ask you to give us Personal Information about other people, such as your family or an authorised representative. If you provide us with this Personal Information, we rely on you to tell those people that you are giving their Personal Information to us, and provide them with a copy of this Privacy Policy.

5 When, and to whom, will AB disclose my personal information?

We may disclose your Personal Information to third parties (such as the AB Group or other companies and organisations outside of AB) only for the purposes set out above. We may also disclose your Personal Information where we are required or authorised by law to do so.

The third parties to whom AB may disclose your Personal Information include:

- our professional advisors (such as lawyers, accountants, and auditors) and service providers (such as marketing and PR agencies)

- organisations that we have engaged to provide services or carry out other functions on our behalf (such as outsourcing contractors, marketing, telemarketing, door-knocking services, market researchers, website usage analysts)

- credit providers and credit related service providers

- government and regulatory authorities and other organisations

We take reasonable steps to make sure that these organisations are bound by confidentiality and privacy obligations in relation to the protection of your Personal Information.

We will not sell your Personal Information.

6 Do I need to provide AB with my information?

You do not need to provide us with your Personal or Sensitive Information. However, if you do not provide us with your Personal Information we may not be able to provide you with the products or services you require.

7 How can I access and change my Personal Information?

You can contact us using our contact details listed below to request access to the Personal Information we hold about you. For security reasons, we will need you to put your request in writing. We will not typically charge you for lodging a request to access your Personal Information.

Generally we will give you full access to your Personal Information - however, there may be some circumstances when this is not possible (including for legal or administrative reasons). If we do not provide you with access to all of your Personal Information, we will tell you the reason why we have not done so.

We depend largely on you to provide us with accurate Personal Information. Please help us to keep our records up to date by informing us of changes to your Personal Information (such as your name and address).

If you find that any Personal Information we hold about you is inaccurate, please contact us using the contact details listed below.

8 Special note for parents about our website

At AB, we take the protection of children’s privacy seriously. We operate our websites and market our products and services (including our marketing promotions) in compliance with all applicable Australian laws. Children under the age of 13 should have the consent of their parent or guardian before providing any Personal Information to us.

We will not require or request children under the age of 13 to provide more Personal Information than is reasonably necessary in the circumstances.

If we determine that, upon collection, a person providing us with information is under the age of 13 we will not use or maintain his or her Personal Information without the consent of a parent or guardian.

As a parent, please be aware that information that is voluntarily given by children to AB on our websites or through our social media channels (such as on bulletin boards, or chat rooms) may in some circumstances be accessed by other parties to generate unsolicited emails or other contacts. In particular, we encourage all parents to instruct their children in the safe and responsible use of the internet.

9 Is my Personal Information stored securely?

We have put in place reasonable security measures to prevent loss, misuse, or unauthorised access and alterations of the personal information under our control. AB employees and service providers are required to maintain the confidentiality of any Personal Information we hold.

Unfortunately, we cannot and do not guarantee that unauthorised access to your Personal Information will not occur.

If Personal Information we hold is no longer needed for the purposes for which it was collected, we will take reasonable steps to destroy or alter that information so that it no longer identifies you.

10 Sensitive Information

We do not collect Sensitive Information about you unless we are authorised or required by law to do so, or you have consented to us collecting that information from you for a particular purpose. If you have provided us with Sensitive Information for a particular purpose, we will only use it for that purpose.

11 Will my information be transferred overseas?

We may occasionally need to transfer your personal information outside of Australia. We will only do this in specific circumstances permitted by law, including where:

- we reasonably believe that the recipient of the information is subject to privacy principles that are substantially similar principles to those contained in the Privacy Act

- we have obtained your consent to transfer your Personal Information overseas, or

- we have taken reasonable steps to ensure that your information will not be held, used or disclosed by the recipient in a way that is inconsistent with the principles contained in the Privacy Act

12 IP addresses and cookies may be used

Our websites, and those of the AB Group may make use of the IP addresses registered in the log primarily for the following purposes:

- to identify the cause of and to resolve problems caused by the server

- for the purposes of site administration

Please note that an IP address does not identify an individual.

Our websites may also make use of cookies. Cookies are information that the site sends to your browser, which are stored as small files on your hard drive. The use of cookies allows the site to record what specific pages you have visited. Websites can provide services and tailored information by using cookies together with the information provided by you.

AB websites use cookies primarily for the following purposes:

- to improve the content of our websites and e-mail to enhance your experience on our websites, and to tailor the websites to individual users

- to customise our services according to the interests of individual users

- to regulate advertising so that members are not repeatedly shown the same ads, and to make adjustments so that members view ads likely to be of interest to them.

Information obtained through the use of cookies may be statistically analysed, compiled and published. No personal information will be included in the end result of this process.

You can adjust your browser settings to block the use of cookies, or to warn that a cookie has been accepted. Most of the services provided on our websites can be accessed even if the browser blocks cookies. However, there may be some services that offer only limited access, or no access, if cookies are disabled.

13 Credit Reporting

If you apply for credit from AB, we may request a credit report about you from a credit reporting body. These reports contain information which assist us to assess your application.

AB may also request a credit report about you from a credit reporting body if you nominate to be a guarantor for another entity.

AB discloses information to the following credit reporting body:

Dun and Bradstreet (Australia) Pty Ltd

Phone: 1300 734 806

Email: PAC.Austral@dnb.com.au

Dun and Bradstreet (Australia) Pty Ltd is required by law to have a privacy policy explaining how it collects, uses and manages your Personal Information. You may contact Dun and Bradstreet (Australia) Pty Ltd for more information about how the way in which it does this.

14 Changes to the Privacy Policy

We may change this Privacy Policy from time to time. You should periodically review this page to ensure that you are familiar with the most current version of this Privacy Policy. You can determine when this Privacy Policy was last revised by reviewing the statement at the top of the Privacy Policy.

15 Concerns and complaints

If you have any concerns or complaints regarding your Personal Information, please contact our Customer Relations Centre (CRC). The CRC’s contact details are:

Phone: 1800 244 054 (9am – 5:00pm AEST weekdays)

Email: consumerrelations@schweppes.com.au