Legal and policy information

Smart Energy Group Pty Ltd (ABN 83 615 998 377) and its related and associated bodies corporate ( us, we, our ) maintain a policy of strict confidence concerning your ( you, your ) personal information ( Privacy Policy ). This Privacy Policy has been developed in accordance with the Privacy Act 1988 (Cth) ( Privacy Act ). The Privacy Policy applies to the collection, storage, use and disclosure by us of your personal information. By using our services or accessing our site www.smartenergygroup.com.au you accept the terms of this Privacy Policy. This Privacy Policy applies to information provided to us whether via this Site or any other means and demonstrates how we will comply with the Australian Privacy Principles under the Privacy Act.

Although we will comply with this Privacy Policy in respect of information provided to us by persons under the age of 18 years, those persons must obtain the consent of a parent or guardian prior to using the Site and the parent or guardian will be responsible for appropriately supervising the person’s use of the Site.

Collecting personal information

The types of personal information we collect includes details such as your:

• name;
• date of birth;
• email address;
• phone number;
• residential address, images and National Meter Identifier;
• bank details;
• employment information;
• financial information; and
• identification information (such as driver’s licence).

If it is reasonable and practical to do so, we will collect personal information directly from you. This will include contact details and other information relevant to providing services to you. This may take place in a number of ways, such as when you provide your information directly to us or to one of our service providers or subcontractors.

We may also collect personal information from third parties such as your representatives, information service providers or publicly available sources of information. All personal information that we collect is reasonably necessary for the purposes relating to providing our services to you. Those purposes include:

• to conduct our business and provide our products and services to you;
• to enhance and improve our services, including via customer satisfaction and engagement surveys and data analytics;
• to assist our suppliers and contractors in the event that products need to be repaired or maintained;
• to enhance and improve the Site;
• to keep you informed of relevant upcoming events and activities, including marketing communications and offers for products and services from us or our partners;
• for our own internal administrative, research, planning, marketing and product development, include customer lead generation; and
• to allow the functions and services on the Site to be provided to you.

If someone other than you provides us with personal information about you that we did not ask for and we determine that we could have collected this information from you had we asked for it, we will notify you as soon as practicable. This notice will be given unless to do so would be in breach of an obligation of confidence. If we could not have collected this personal information, we will lawfully de-identify or destroy that personal information.

We will not collect any sensitive information from you, revealing your: race, ethnic origin, political opinions, religious or philosophical beliefs, trade union memberships or details of health or disability. Exceptions to this include:

• where you have given express consent to us to do so and the information is reasonably necessary for us to carry out our functions or activities;
• the use of this information is required or authorised under Australian law or a court or tribunal order; or
• when the information is necessary for the establishment, exercise or defence of a legal claim.

We will not collect personal information unless the information is reasonably necessary for or directly related to one, or more of our functions or activities. If we are unable to collect personal information we reasonably require, we may not be able to do business with you or the organisation with which you are connected.

Cookies

When you visit the Site, the server may attach a "cookie" to your computer's memory. A “cookie” assists us to store information on how visitors to the Site use it and the pages that may be of most interest. This information may be used to provide users of your computer with information that we think may interest the users of your computer.

If we hold other personal information about you, we may be able to link that personal information to cookie information. If cookie information is linked with personal information, we hold about you as set out above, this cookie information becomes personal information and will be treated in the same manner as the personal information to which it has been linked. If you choose, you should be able to configure your computer so that it disables “cookies” or does not accept them.

Use and disclosure of information

We may use personal information about you for the primary purpose of providing you with our services, and for which you would reasonably expect us to use that information, including sending you information about new developments, products, services and special offers by post, telephone or any form of electronic communication. We may use any email address or other personal information you provide to us at any time for this purpose. We will not disclose information that personally identifies you to any third party other than as set out in this Privacy Policy. In order to deliver the services that we provide to you, we may disclose your personal information to other organisations, only in relation to providing our services to you. Such disclosures include, but are not limited to:

• disclosing your financial information to a third party for the purposes of assessing your credit worthiness and/or eligibility for finance (where consented to);
• disclosure of your energy usage and details to energy wholesalers and retailers;
• disclosure of your address and contact details to our service providers, suppliers and contractors for the purposes of providing our services, servicing a warranty or re-attending the site for the purposes of repair or maintenance; and
• to regulators and authorities for the purpose of providing our services, including in relation to the administration or and compliance with any government schemes (such as Small-Scale Technology Certificates).

We take reasonable steps to ensure that these organisations are bound by privacy obligations in relation to the protection of your personal information.

We may provide certain information about you including your personal information to our related bodies corporate.

In the event of a security incident involving unauthorised access, use or disclosure of personal information where a third party with whom we share personal information is involved, we will seek to work cooperatively with them to protect the personal information we have shared with.

Direct marketing

We may use personal information about you for the primary purpose of providing you with our services, and for other purposes for which you would reasonably expect us to use that information. This includes sending you feedback surveys and information about new developments, products, services and special offers by post, telephone or any form of electronic communication. You authorise us to use any email address or other contact information you provide to us at any time for this purpose.

You can, at any time, opt out of receiving marketing material by contacting us. You agree and acknowledge that even if you opt out of receiving marketing material, we will still send you essential information that we are legally required to send you relating to the services we provide. Once you opt out of receiving marketing material from us, you agree and acknowledge that this removal from our distribution lists may take several business days after the date of your request to be removed.

Accuracy of your information

We take all reasonable steps to ensure that your personal information held by us is accurate, up-to-date, complete, relevant and not misleading. If you believe that any of your personal information is not accurate, up-to-date, complete, relevant and not misleading, please contact us (see below) and we will take all reasonable steps to correct it within a reasonable time.

Third Parties and your information

We will only collect, store, use or disclose personal information as set out in this Privacy Policy unless we are required by law to protect our rights or property (or those of any third party), or to avoid injury to any person.

Although the Site may link directly to websites operated by third parties (Linked Sites), you acknowledge that Linked Sites are not operated by us. We encourage you to always read the applicable privacy Policy of any Linked Site on entering the Linked Site. We are not responsible for the content or practices of the Linked Sites nor their privacy policies regarding the collection, storage, use and disclosure of your personal information.

Disclosure of Information Overseas

We may transfer to people in foreign countries any of your personal information to fulfil the purposes set out in this Privacy Policy, including in locations such as the Philippines.

In many cases the transfer will be necessary for the performance of our contract with you or for the implementation of measures taken in response to a request by you or for the performance of a contract with a third party which is concluded in your interests. You should be aware that overseas recipients may not be bound by the Privacy Act and your information may not be entitled to equivalent protections overseas. By providing your personal information to us you consent to this transfer.

Your consent

By your use of the Site and our services, you consent to the collection, storage, use and disclosure of your personal information in accordance with this Privacy Policy and as otherwise permitted under the Privacy Act.

Storage and security

We will use reasonable endeavours to keep your personal information in a secure environment, however, this security cannot be guaranteed. These security measures are designed to ensure your personal information is not subject to unauthorised access, loss or misuse. If you reasonably believe that there has been unauthorised use or disclosure of your personal information please contact us (see below).

If we no longer need your personal information, unless we are required under Australian law or a court or tribunal order to retain it, we will take reasonable steps to destroy or de-identify your personal information.

Notwithstanding the reasonable steps taken to keep information secure, breaches may occur. In the event of a security incident we have in place procedures to promptly investigate the incident and determine if there has been a data breach involving personal information, and if so, to assess if it is a breach that would require notification. If it is, we will notify affected parties in accordance with Privacy Act requirements.

Variation and consent to variation

We may vary the terms of this Privacy Policy at any time. You should check this Privacy Policy regularly so that you are aware of any variations made to this Privacy Policy. You will be deemed to have consented to such variations by your continued use of the Site following such changes being made.

Access to information we hold about you

If you request access to the personal information we hold about you, we will respond to your request within a reasonable period of time and, where reasonable and practicable, give access to the information in the manner you request. This will be subject to any exemptions allowed under the Privacy Act. You may request this information by sending an email to us at info@smartenergygroup.com.au.

We may charge a reasonable fee for providing that information.

Contact us

If you have any further questions or if you wish to receive more information on our information practices and Privacy Policy, please contact our Customer Support Team at support@smartenergy.co

When contacting us you have the option to either not identify yourself or to use a pseudonym. However, this will not apply if it is impracticable for us to communicate with you that way or we are required or authorised under Australian law (or a court or tribunal order) to only deal with individuals who have identified themselves.

Use of Personal Information for Credit Checks

If you apply for credit or financing through Smart Energy, you consent to us collecting, using, and disclosing your personal information to conduct credit checks. This may include obtaining information from credit reporting bodies such as Equifax, illion, or other authorised agencies. The information we may collect includes your credit history, credit score, repayment behavior, and other credit-related details.We use this information solely to assess your creditworthiness, manage risk, and determine your eligibility for finance or payment plans. All credit-related information is handled in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles.

Date: April - 2025