PACE Program Pty Ltd

Privacy Policy

Effective Date: 14 July 2026

1. Privacy Commitment

PACE Program Pty Ltd ("PACE", "we", "our" or "us") is committed to protecting your privacy and handling your personal information responsibly and transparently.

This Privacy Policy explains how we collect, hold, use, disclose and protect your personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).

A copy of the Australian Privacy Principles is available from the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au.

2. What is Personal Information?

Personal information is information or an opinion about an identified individual, or an individual who is reasonably identifiable.

Examples of personal information we may collect include:

• Name

• Position or job title

• Organisation or business name

• Business address

• Email address

• Telephone number

• Information relating to buildings, facilities or projects

• Correspondence with PACE

• Information submitted through applications, assessments or enquiries

• Any other information voluntarily provided to us.

We generally do not seek to collect personal information that is unrelated to the operation of the PACE Program.

3. How We Collect Personal Information

We collect personal information directly from you whenever reasonably practicable.

Information may be collected when you:

• submit an enquiry through our website;

• complete an Expression of Interest or Program Application;

• participate in a PACE Assessment;

• communicate with us by telephone, email or correspondence;

• attend meetings or presentations;

• subscribe to newsletters or program updates;

• download publications or resources;

• interact with our website; or

• otherwise provide information to us.

Where appropriate, we may also obtain information from:

• authorised representatives;

• publicly available sources;

• government registers;

• professional advisers;

• industry partners; or

• other parties authorised by you.

4. Why We Collect Personal Information

We collect personal information for purposes including:

• determining eligibility for the PACE Program;

• conducting engineering assessments;

• administering the PACE Program;

• communicating with applicants and participants;

• preparing reports and recommendations;

• providing customer support;

• improving our services;

• complying with legal and regulatory obligations;

• maintaining program records; and

• providing information about PACE products, services and publications where appropriate.

We will only use personal information for the purposes for which it was collected or for related purposes that you would reasonably expect.

5. Program and Technical Information

As part of administering the PACE Program, applicants and participants may provide technical, operational or commercial information relating to their facilities.

This information may include:

• building information;

• HVAC system details;

• engineering assessments;

• energy consumption information;

• operational data;

• performance reports;

• technical documentation; and

• supporting evidence submitted during the assessment process.

PACE Program Pty Ltd uses this information solely for purposes associated with:

• assessing eligibility;

• undertaking engineering assessments;

• administering the Program;

• verifying performance;

• maintaining program records;

• complying with contractual and legal obligations; and

• improving the operation of the Program.

PACE does not disclose confidential technical information except where authorised by the participant, required by law, or necessary for approved service providers engaged to support the Program.

6. Sensitive Information

Sensitive information has the meaning given in the Privacy Act.

PACE Program Pty Ltd generally does not collect sensitive information.

If sensitive information is required for a legitimate purpose, we will only collect and use it:

• with your consent;

• where required or authorised by law; or

• where otherwise permitted under the Privacy Act.

7. Website Analytics and Cookies

Our website may use cookies, analytics services and similar technologies to:

• improve website functionality;

• understand website usage;

• measure website performance;

• enhance user experience; and

• assist in maintaining website security.

Analytics information generally does not identify individual users unless they choose to provide personal information.

Most web browsers allow cookies to be disabled or managed through browser settings, although some website functionality may be affected.

8. Disclosure of Personal Information

We may disclose personal information to:

• employees and authorised representatives;

• contractors and consultants;

• engineering service providers;

• information technology providers;

• cloud hosting providers;

• professional advisers;

• regulatory authorities;

• government agencies;

• auditors;

• parties authorised by you; or

• where disclosure is required or authorised by law.

PACE Program Pty Ltd does not sell personal information.

9. Overseas Disclosure of Personal Information

PACE Program Pty Ltd uses reputable cloud-based technology providers to operate and administer the PACE Program.

Accordingly, personal information may be stored, processed or backed up on servers located outside Australia or accessed by service providers operating in other countries.

These providers may include services used for:

• customer relationship management;

• website hosting;

• cloud storage;

• document management;

• email services;

• analytics;

• productivity software; and

• customer support systems.

PACE Program Pty Ltd takes reasonable steps to ensure overseas service providers protect personal information through contractual obligations, recognised security standards or other appropriate safeguards.

10. Security of Personal Information

PACE Program Pty Ltd takes reasonable technical, administrative and physical measures to protect personal information from:

• misuse;

• interference;

• loss;

• unauthorised access;

• modification; and

• disclosure.

Security measures may include:

• secure cloud services;

• access controls;

• authentication procedures;

• encrypted communications where appropriate;

• secure backups; and

• restricted staff access.

Although no electronic system can be guaranteed completely secure, we continually review and improve our security practices.

11. Data Breach Response

PACE Program Pty Ltd maintains procedures for responding to suspected or actual data breaches.

Where a data breach is likely to result in serious harm, we will respond in accordance with the Notifiable Data Breaches Scheme established under the Privacy Act.

Where required, we will notify affected individuals and the Office of the Australian Information Commissioner.

12. Retention of Personal Information

We retain personal information only for as long as reasonably necessary to:

• administer the PACE Program;

• satisfy legal, regulatory and contractual obligations;

• resolve disputes;

• maintain business records; and

• protect our legal interests.

When personal information is no longer required, it will be securely destroyed or permanently de-identified where appropriate.

13. Access and Correction

You may request access to personal information we hold about you and request correction if you believe it is inaccurate, incomplete or out of date.

Requests should be made in writing using the contact details below.

Before releasing personal information, we may require sufficient proof of identity.

We will respond within a reasonable time and in accordance with the Privacy Act.

No fee is generally charged for making an access request, although reasonable administrative costs may apply where extensive copying or retrieval is required.

14. Direct Marketing

From time to time, PACE Program Pty Ltd may provide information about the Program, publications, events or services that may be relevant to you.

You may opt out of receiving marketing communications at any time by:

• selecting the unsubscribe option included in electronic communications; or

• contacting us using the details below.

15. Children's Privacy

The PACE Program is intended for businesses, commercial organisations, government agencies and industry professionals.

Our services are not directed towards children, and we do not knowingly collect personal information from individuals under 18 years of age.

16. Changes to this Privacy Policy

This Privacy Policy may be updated periodically to reflect changes in legislation, technology or the operation of the PACE Program.

The current version will always be published on the PACE website.

17. Contact Us

If you have any questions, concerns or complaints regarding this Privacy Policy or our handling of personal information, please contact:

PACE Program Pty Ltd

Email: info@paceprogram.com.au

If you are not satisfied with our response, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC).

The OAIC can be contacted through its website at www.oaic.gov.au.