At Argyle Insurance Pty Ltd 48 644 441 289 (‘Argyle’), we are committed to protecting your privacy in accordance with the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles (APPs).

This Privacy Policy applies to personal information collected by us and explains how we collect, use, disclose and handle it as well as your rights to access and correct your personal information and make a complaint for any breach of the APPs. It applies to our customers, the insurance brokers we work with, and visitors to our website and broker portal.

What is Personal Information?

The Privacy Act defines personal information to mean: “information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information or opinion is true or not and whether recorded in a material form or not.”

What is Sensitive Information?

“Sensitive information” is a subset of personal information and means: “information or opinion about an individual’s racial or ethnic origin, political opinions, membership of a political organisation, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual orientation or practices, criminal record, health information about an individual, genetic information, biometric information or templates.”

What kinds of Personal Information do we collect and hold?

When we are asked to issue a quote, an insurance policy, or assess a claim we ask you (or your insurance broker/representative) for the information we need to do so.

The kinds of personal information we collect and hold vary depending on the services we are providing, but generally can include:

• Your contact information such as full name (first and last), e-mail address, current postal address, delivery address and phone numbers;

• Your date of birth;

• Insurance history;

• other information specific to our products or services such as your opinions, statements and endorsements collected personally or via surveys and questionnaires, including but not limited to your views on the products and services offered by Argyle; and

• if you are requesting products or services from us, we will collect any relevant payment or billing information, (including but not limited to bank account details, direct debit, credit card details, billing address, premium funding and instalment information)

The type of sensitive information we may collect generally includes:

• Criminal Record;

• Health information; and

• Membership of a professional or trade association.

If you are an insurance broker, we also collect:

• your name, job title, brokerage, work email address and phone number;

• records of your activity on our broker portal, such as logins, quotes, policies bound and renewals;

• how you interact with our emails, such as whether you open them and which links you click; and

• how you use our website and respond to our online advertising.

How do we Collect and Hold personal information?

We only collect personal information by lawful and fair means and where it is reasonably necessary for, or directly related to, one or more of our functions or activities.

Unless it is unreasonable or impracticable for us to do so, or as provided otherwise under this Privacy Policy, we will collect your information directly from you or your agents.

We also collect some information automatically when you use our website, broker portal or emails, through cookies, pixels and similar technologies. We explain this under ‘Cookies, Pixels and Similar Technologies’ below.

We attempt to limit the collection and use of sensitive information from you unless we are required to do so in order to carry out the services provided to you. However, we do not collect sensitive information without your consent.

We hold the personal information we collect within our own data storage devices or with a third-party provider of data storage. We discuss the security of your personal information below

The purposes for which we Collect, Hold, Use and Disclose your Personal Information

We collect, hold, use and disclose your personal information where it is reasonably necessary for, or directly related to, one or more of our functions or activities. These will usually include our insurance underwriting services, insurance intermediary services, funding services, claims management services and risk management and other consulting services.

We also collect, hold, use and disclose your personal information where it is necessary to meet our obligations at law, for example, for conducting identity checks under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) and other legislation.

For example, we usually need to collect, hold, use and disclose personal information where:

• we arrange insurance, so insurer(s) can decide whether to offer insurance or not;

• a claim is made, so the insurer can make a decision on the claim;

• you are a broker, so we can manage your portal access, support you to quote and bind policies, and keep you informed about our products.

We do not use or disclose personal information for any purpose that is unrelated to our services and that you would not reasonably expect (except with your consent). We will only use your personal information for the primary purposes for which it was collected or as consented to.

We disclose personal information to third parties who assist us or are involved in the provision of our services and your personal information is disclosed to them only in connection with the services we provide to you or with your consent. We may disclose your personal information for direct marketing purposes, which is explained in more detail below.

The third parties can include our related companies, our agents or contractors, insurers, their agents and others they rely on to provide their services and products (e.g. reinsurers), insurance reference bureaus, loss adjusters or assessors, medical service providers, credit agencies, lawyers and accountants, analytics, email and advertising service providers (such as Google and Meta), prospective purchasers of our business and our alliance and other business partners.

These parties are prohibited from using your personal information except for the specific purpose for which we supply it to them and we take such steps as are reasonable to ensure that they are aware of the provisions of this Privacy Policy in relation to your personal information.

We also use personal information to develop, identify and offer products and services that may interest you or your insurance broker, conduct market or customer satisfaction research. This includes using information about how brokers use our portal, website and emails to decide which communications, support and offers are most relevant to them. From time to time we may seek to develop arrangements with other organisations that may be of benefit to you in relation to promotion, administration and use of our respective products and services. We do not use sensitive information to send you direct marketing communications without your express consent.

If we do propose to disclose or use your personal information other than for the purposes listed above, we will first seek your consent prior to such disclosure or use.

If we give third parties (including their agents, employees and contractors) your personal information, we require them to only use it for the purposes we agreed to.

Direct Marketing

We may use your personal information to send you information about our products, services, events and offers, mainly to brokers. We do this by email, phone and online advertising.

We may use information about your activity on our website, broker portal and emails to decide what to send you and when. For example, we may send a reminder, or show an online ad, to a broker who has not quoted with us for some time.

You can opt out of direct marketing at any time by using the unsubscribe link in any of our emails or by emailing privacy@argyleinsurance.com. Opting out will not stop service messages about quotes, policies, renewals and claims.

Automated Decisions

[Confirm with underwriting before publishing — required from 10 December 2026 if any of the below applies.]

We use computer systems, including our quoting platform, to make or substantially help make some decisions, such as whether a quote can be offered through our broker portal or must be referred to an underwriter, and the premium and terms offered. These systems use information such as details of the property or business being insured, location, sums insured, insurance and claims history, and answers to underwriting questions. If a quote is declined or referred, your broker can ask one of our underwriters to review it.

What happens if you don’t give us your personal information?

If the required personal information is not provided, we or any involved third parties may not be able to provide appropriate services or products. If you do not provide the required personal information we will explain what the impact will be.

What do we expect from you/third parties we deal with when providing personal information about another person?

When you provide us with personal information about other individuals, we rely on you to have made them aware that you will or may provide their information to us, how we collect, use, disclose and handle it in accordance with this Privacy Policy and our relevant Privacy Statements. If it is sensitive information we rely on you to have obtained their consent to the above. If you have not done these things, you must tell us before you provide us with the relevant information.

If we give you personal information, you must only use it for the purposes we agreed to.

Unless an exemption applies or we agree otherwise, you must meet the requirements of the Privacy Act, when collecting, using, disclosing and handling personal information on our behalf.

You must also ensure that your agents, employees and contractors meet the above requirements.

How do we manage the security of your Personal Information?

We take reasonable steps to ensure that your personal information is safe. We retain personal information in hard copy records and electronically with us or our appointed data storage provider(s). You will appreciate, however, that we cannot guarantee the security of all transmissions of personal information, especially where the internet is involved.

Notwithstanding the above, we endeavour to take all reasonable steps to:

• Protect any personal information that we hold from misuse, interference and loss, and to protect it from unauthorised access, modification or disclosure both physically and through computer security measures;

• Destroy or permanently de-identify personal information in accordance with the Privacy Act.

We maintain computer and network security; for example, we use firewalls (security measures for the internet) and other security systems such as user identifiers and passwords to control access to computer systems.

Data Quality

We take reasonable steps to ensure that personal information is current, accurate, up-to-date and complete whenever we collect or use or disclose it.

Throughout our dealings with you we will take reasonable steps to confirm the details of your personal information we hold and ask you if there are any changes required.

The accuracy of personal information depends largely on the information you provide to us, so we rely on you to:

• let us know if there are any errors in your personal information you become aware of; and

• keep us up-to-date with changes to your personal information (such as your name or address).

Access to and Correction of Your Personal Information

You are entitled to have access to any personal information relating to you which we possess, except in some exceptional circumstances provided by in law.

For example, we may refuse access where the:

• information may have an unreasonable impact on the privacy of others;

• request is frivolous or vexatious;

• information relates to existing or anticipated legal proceedings and would not be accessible by the process of discovery in those proceedings;

• information would reveal our intentions in relation to negotiations in such a way as to prejudice those negotiations.

Where providing access would reveal evaluative information generated by us in connection with a commercially sensitive decision-making process, we will provide an explanation for the decision rather than direct access to the information.

If we refuse access or to give access in the manner requested by you we will let you know why in writing and provide you with details about how to make a complaint about the refusal.

If we make a correction to your personal information we may retain a copy of the previous information for our records or as required by law.

If you wish to access your personal information please write to:

Privacy Officer, Argyle Insurance Pty Ltd
GPO Box 1902, Brisbane QLD 4001
Telephone: 1300 352 727
Email: privacy@argyleinsurance.com

In most cases we do not charge for receiving a request for access to personal information or for complying with a correction request.

Do we transfer information overseas?

Any personal information provided to Argyle Insurance Pty Ltd may be transferred to, and stored at, a destination outside Australia.

We may disclose your personal information to entities overseas for purposes we believe are necessary to assist us in providing the relevant services and products. We will generally limit such use and disclosure of any personal information to the specific purpose for which it was supplied. Personal information may also be processed by third parties operating outside Australia who work for us or for one of our suppliers, agents, partners or related companies. This includes the analytics, email and advertising platforms we use, which may store information in [countries — confirm, e.g. United States].

We will generally take reasonable steps to ensure that we have arrangements in place with such overseas third parties that prevent them from using or disclosing personal information for any purposes other than our own. However, by providing your personal information to us, you acknowledge that, while we will take reasonable steps, we may not always be able to guarantee that overseas parties are subject to the requirements similar to those contained in the Privacy Act and consent to the disclosure on this basis.

If you would like further information about whether your information will be disclosed to overseas recipients, please contact the Privacy Officer at the contact details in this Privacy Policy.

Sale or restructure of business

In the future we may consider the sale or restructure of our business or the purchase of the business of other entities. In such circumstances it may be necessary for your personal information to be disclosed to permit the parties to assess the sale or restructure proposal for example through a due diligence process. We will only disclose such of your personal information as is necessary for the assessment of any sale or restructure proposal and subject to appropriate procedures to maintain the confidentiality and security of your personal information. In the event that a sale or restructure proceeds, we will advise you accordingly.

Our Website

You are able to visit our website without providing any personal information. We will only collect personal information through our websites with your prior knowledge for example where you submit an enquiry or application online.

Email addresses are only collected if you send us a message and will not be automatically added to a mailing list.

Cookies, Pixels and Similar Technologies

A cookie is a small string of information that a website transfers to your browser for identification purposes. The cookies we use may identify individual users.

Cookies can either be “persistent” or “session” based. Persistent cookies are stored on your computer, contain an expiration date, and are mainly for the user’s convenience.

Session cookies are short-lived and are held on your browser’s memory only for the duration of your session; they are used only during a browsing session, and expire when you quit your browser.

We may use both session and persistent cookies. This information may be used to personalise your current visit to our websites or assist with analytical information on site visits.

We also use tracking pixels (sometimes called web beacons or tags) on our website, broker portal and in our emails. A pixel is a small piece of code or tiny image that sends information to us, or to the third party that provided it, when a page or email loads. We use pixels and cookies to:

• see whether our emails are opened and which links are clicked;

• understand how our website and broker portal are used;

• measure whether our marketing and advertising is working; and

• show Argyle advertising on other websites and platforms to people who have visited our website or broker portal.

Some of these pixels and cookies are provided by third parties such as [Google and Meta — confirm], who may combine this information with other information they hold about you under their own privacy policies. We do not place advertising pixels on pages where you enter claims, health, criminal history or other sensitive information.

Most internet browsers can be set to accept or reject cookies. If you do not want to accept cookies, you can adjust your internet browser to reject cookies or to notify you when they are being used. However, rejecting cookies may limit the functionality of our website. You can also turn off automatic image loading in your email program to stop email tracking, manage personalised ads through your Google and Meta ad settings, and opt out of marketing from us, including online advertising, by emailing privacy@argyleinsurance.com.

Complaints

If you do have a complaint about privacy we ask that you contact our office first to help us to assist you promptly.

In order to resolve a complaint, we:

• will liaise with you to identify and define the nature and cause of the complaint;

• may request that you detail the nature of the complaint in writing;

• will keep you informed of the likely time within which we will respond to your complaint;

• will inform you of the reason for our decision in resolving such complaint; and

• keep a record of the complaint and any action taken in the Register of Complaints.

If you have a complaint please contact us at:

Customer Relations, Argyle Insurance Pty Ltd
GPO Box 1902, Brisbane QLD 4001
Telephone: 1300 352 727
Email: complaints@argyleinsurance.com

Our Privacy Officer will then attempt to resolve the issue or complaint. We are committed to respecting your privacy and we will respond to you as soon as reasonably possible in relation to your issue or complaint.

You also have a right in limited circumstances to have your privacy complaint determined by the Australian Financial Complaints Authority (AFCA). The AFCA can determine a complaint about privacy where the complaint forms part of a wider dispute within the AFCA Terms of Reference between you and us or when the privacy complaint relates to or arises from the collection of a debt. We are bound by AFCA’s determinations, provided the dispute falls within the AFCA Terms of Reference. You can access the AFCA dispute resolution service by contacting them at:

Australian Financial Complaints Authority
GPO Box 3,
Melbourne VIC 3001
Telephone: 1800 931 678
Email: info@afca.org.au
Website: www.afca.org.au

When we make our decision, we will also inform you of your right to take the matter to the Office of the Australian Information Commissioner (OAIC) if you are not satisfied. In addition if you have not received a response from us of any kind to your complaint within 30 days, then you have the right to take the matter to the OAIC.

How to contact us and opt out rights

If you wish to gain access to your personal information, want us to correct or update it, have a complaint about a breach of your privacy, wish to withhold your consent (opt out) of providing consent to any of the uses of your information including receiving offers of products or services from us, or have any other query relating to our Privacy Policy, contact our Privacy Officer during business hours on:

Privacy Officer, Argyle Insurance Pty Ltd
GPO Box 1902, Brisbane QLD 4001
Telephone: 1300 352 727
Email: privacy@argyleinsurance.com

We welcome your questions and comments about privacy.

You can also obtain information on privacy issues in Australia on the Office of the Australian Information Commissioner (“OAIC”) website at www.oaic.gov.au or by contacting the OAIC by email at enquiries@oaic.gov.au or by calling on 1300 363 992.