Privacy

JBWere Pty Ltd (JBWere), Invia Custodian Pty Ltd (Invia) and the NAB Group understand and appreciate that you are concerned about the privacy of personal information that JBWere, Invia and the NAB Group may collect about you. JBWere and Invia are subsidiaries of the National Australia Bank Limited. NAB Group means the National Australia Bank Limited and its subsidiaries and includes JBWere and Invia. Throughout this statement, ‘us’, ‘we’ and ‘our’ refers to JBWere, Invia and the NAB Group or either of them as the case may be.

We are committed to providing you with high quality financial services in a secure and confidential manner. We comply with the National Privacy Principles as required under the Commonwealth Privacy Act.

Our privacy statement sets out, for your information:

• Personal information we may collect
• Use and disclosure of personal information
• Security of personal information
• Access and updating of personal information
• Changes to our privacy statement
• How you can contact us

In addition to the provisions of this privacy statement, there may also be specific and additional privacy provisions in our documents that relate to certain products and services provided by JBWere and Invia. These specific and additional provisions may also relate to your privacy protection and you should review them carefully. In the event of any inconsistency between the provisions of this privacy statement and those other specific and additional provisions, the specific and additional provisions will prevail.

Personal information we may collect

The personal information that we collect about you will depend on the NAB Group services and products that you use. The information collected may include your name, postal or email address, date of birth, financial details, tax file number or other information the organisation considers necessary. Generally, we will not collect any personal information that identifies you as an individual unless you knowingly provide it to us. Circumstances in which we may collect your personal information from third parties include:

• for payment purposes at your direction
• to verify identity and for customer due diligence purposes
• for the prevention and detection of money laundering and terrorist financing, and
• where we are required or authorised by law.

If you browse the JBWere website, read or download information, our system will record the date and time of your visit, the pages viewed and the information downloaded. In addition, when you visit the site again, our server will look for any cookies and structure itself based on the information provided. (A cookie is a small data file placed on your computer by the site's server. A cookie contains information about your visit to the site. A cookie identifies your computer to our web server when you visit the site.) We do not use the cookie to collect or store personal information about you. The site uses browser cookies to improve the speed and reliability of our security system. It is recommended that you turn off any cookie warnings in your browser before using the site, otherwise you may not be able to use the full functionality of the site.

Use and disclosure of personal information

Any personal information we collect from you may be made available to, or used by, your advisor, any member or affiliate of the NAB Group or any entity carrying out functions on behalf of NAB Group for purposes related to the purpose for which the personal information was collected.

For example, your personal information may be used for:

• enabling the NAB Group to provide products, services or information to you in accordance with your requests or reasonable expectations
• enabling the NAB Group to ascertain whether or not it has other services or products which may foreseeably meet your needs, and to notify you about these unless you have told us not to
• the NAB Group's research, planning, product development, risk assessment, risk modeling and marketing
• identity verification and customer due diligence purposes
• prevention and detection of money laundering and terrorist financing, and
• any other purpose required or authorised by law.

We will disclose personal information to third party entities carrying out functions on behalf of the NAB Group on a confidential basis only. This includes NAB Group organisations offering:

• banking and finance products or service - other organisations to which personal information is usually disclosed are card producers, card schemes, credit and fraud reporting agencies, debt collection agencies, mortgage insurance companies, your guarantors, organisations involved in valuing, surveying, or registering a security property or which otherwise have an interest in such property, purchasers of debt portfolios, underwriters, re-insurers and other organisations involved in our normal business practices (such as securitisation)
• financial planning or broking services or personal investment products - other organisations to which personal information is usually disclosed are superannuation and managed funds organisations and their advisors, organisations in which you invest and other organisations involved in our normal business practices (such as securitisation)
• trustee or custodial services - other organisations to which personal information is usually disclosed are superannuation and managed funds organisations and their advisors and other organisations involved in our normal business practices, and
• life insurance products or general insurance products - other organisations to which personal information is usually disclosed are medical professionals, medical facilities, health authorities, assessors, underwriters, reinsurers and fraud detection agencies and other organisations involved in our normal business practices.

You should note that personal information we collect from or about you may also be disclosed to third parties if that disclosure is required or authorised by law.

If we transfer personal information outside Australia, we comply with transborder data flow privacy standards under the Privacy Act, for example, by taking reasonable steps to protect the information being held, used or disclosed by the recipient inconsistently with the National Privacy Principles.

In certain circumstances, failure to provide us with your personal information may mean we are unable to continue to deal with you. For example, we may need to collect personal information from a credit reporting agency, your representative (such as a legal advisor), your financial advisor, your employer or publicly available sources of information.

Security of personal information

The NAB Group takes reasonable steps to preserve the security of personal information it collects. All stored client information is protected from unauthorised access through the use of secure passwords and user logons or other security procedures.

We take reasonable steps to preserve the security of personal information we collect via the JBWere website. Your username and password are encrypted for privacy during transmission using the Secure Sockets Layer (SSL) protocol. In addition, your account information is password and user ID protected and we recommend you do not divulge your password or user ID to anyone. Unfortunately, no data transmission over the internet can be guaranteed as totally secure. Accordingly, although we strive to protect such information, we cannot ensure or warrant the security of any information you transmit to us or receive from our online products or services and you do so at your own risk. Once we receive your transmission, we take reasonable steps to preserve the security of information on our own system. From time to time the site may contain links to other websites, and we are not responsible for the privacy practices or the content of these websites.

Access and updating of personal information

The NAB Group takes reasonable steps to make sure that the personal information which we collect, use and disclose is accurate, complete and up-to-date.

You are able to make a request to access and update the personal information that we hold about you. Please provide us with as much detail as possible to assist us to retrieve the personal information which you have requested. In accordance with privacy laws a fee may be charged to cover our costs of providing access to you. To amend personal information that JBWere, Invia or the NAB Group holds, you should contact your advisor or the Investor Service team on 1300 366 566.

Changes to our privacy statement

This privacy statement may change from time to time, so please refer to it regularly. Any information collected after an amended privacy statement has been posted on the site, will be subject to that amended privacy statement.

How you can contact us

If you have any questions or feedback about this statement or any privacy issues concerning the JBWere Privacy Statement, please contact the Privacy Officer, JBWere, GPO Box 2050, Melbourne VIC. 3001 at any time in writing.

April 2012