Privacy Policy


This Privacy Statement explains in general terms how Subnet protects the privacy of your personal information under the Australian Privacy Principles and the Information Privacy Act 2014 (ACT)

It will apply to any personal information you provide to us in the course of your dealings with us.


The types of personal information that we collect from you will depend on the circumstances of collection and its relevance to our business. For example, we may collect details such as your name, address, credit/debit card number and expiry date, charging codes, billing address, telephone numbers and issues relevant to our services or other operations. Subnet does not require that you supply any sensitive information to the company unless it is essential for the purpose of the conduct of business. As we are required by law to obtain your consent for the collection of “sensitive information” we will assume that you have consented to the collection of all information, which is provided to us for use in accordance with this Statement, unless you tell us otherwise.

We generally collect personal information:

  • from you directly when you provide your details to us
  • when you purchase our solutions, products and services
  • from you indirectly through emails, forms, face-to-face meetings, interviews, registration and attendance at seminars, business cards and telephone conversations and through use of the services and facilities available through, including receiving subscriptions, events, workshops, seminars, blogs and other social media
  • from outlets to which you contribute
  • when we purchase your products and services
  • when we respond to your inquiries and requests
  • when we obtain feedback from you about our solutions and services
  • when we conduct our administrative and business functions
  • when we market our products, solutions and services to you and
  • through your access and use of our websites.
  • from people booking a service for you on your behalf
  • from a company providing a service to you, which has sub-contracted (part of) provision of that service to us
  • from other service providers who collect information on our behalf, and
  • from market research companies contracted by us to obtain information so that we may improve and market our products and services.

We may also collect personal information from third parties including credit reporting agencies, law enforcement agencies and other government entities. Subnet only collects information by lawful and fair means.

Subnet will only collect personal information from the individual unless otherwise required under Australian Law.

We may automatically collect non-personal information about you such as the type of internet browsers you use or the website from which you linked to our site. You cannot be identified from this information and it is only used to assist us in providing an effective service on our website.


A cookie is a piece of text, which asks permission to be placed on your computer’s hard drive. Once you agree (or your browser agrees automatically if you have set it up in that way), your browser adds that text in a small file.

We may use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to user needs. We only use this information for statistical analysis purposes and then the data is de-identified or removed from the system. Denial of a traffic log cookie may prevent you from using our website.


All customer Personal Information collected by Subnet is solely used for our business functions and activities. It may be used for the following purposes:

  • for billing purposes and order fulfilment
  • to contact you in relation to our provision of services to you
  • to maintain your account details
  • to provide technical support – for example, account creation, password reset
  • to provide you with information in relation to our products, services or other information that you may have requested
  • to streamline and personalise your experience while dealing with Subnet
  • to undertake customer satisfaction surveys and to tailor Subnet information, services or products in order to improve and enhance those services and products provided to the customer.

Subnet may also collect from its customers Personal Information relating to its employees and customers, for example, payroll information. This Personal Information is solely used so that we can facilitate provision of the services our customers have requested.

Occasionally, Subnet uses de-identified Personal Information derived from our customers and our customers’ employees and customers use of our products and services in order to provide Subnet with anonymous demographic and customer usage information. Subnet will then use this anonymous, aggregated information to develop new and/or more appropriate services and products to offer to our customers.


We will only disclose your personal information to a third party where we have your consent, or where the disclosure is permitted or required by law. For example, we may disclose your personal information to:

  • Subnet’s related companies
  • clients where required for specific business purposes
  • external service providers, such as contractors, consultants and agents
  • suppliers whom we engage in the provision of our services, but only for specific business purposes relating to their engagement
  • tax, financial, audit and legal advisers, and
  • government regulatory and law enforcement agencies.

We may disclose your personal information to the following overseas recipients:

  • other companies or individuals who assist us in providing solutions and services or who perform functions on our behalf (such as third party service providers), including those located in the USA, United Kingdom and other countries where we are engaged in business or related activities with you or your company or organisation;
  • regulatory authorities
  • anyone else to whom you authorise us to disclose it and
  • anyone else where authorised by law.

We will take steps to contractually ensure that overseas recipients of your personal information provide a level of protection for your personal information, which is equivalent to the APPs.


You may request access to personal information we hold about you by making a written request. We will respond to your request within a reasonable period. We may charge you a reasonable fee for processing your request (but not for making a request for access).

We may decline a request for access to personal information in circumstances prescribed by the Privacy Act, and if we do, we will provide you with a written notice that sets out the reasons for the refusal (unless it would be unreasonable to provide those reasons).

If, upon receiving access to your personal information, or at any other time, you believe the personal information we hold about you is inaccurate, incomplete or out of date, please notify us immediately. We take reasonable steps to correct the information so that it is accurate, complete and up to date. If we refuse to correct your personal information, we will provide you with a written notice that sets out the reasons for our refusal (unless it would be unreasonable to provide those reasons) and provide you with a statement regarding the mechanisms available to you to make a complaint


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

If the personal information we hold about you is inaccurate, incomplete or out-of-date please contact us and we will take reasonable steps to either correct this information, or if necessary, discuss alternative action with you.


Due to the nature of the services that Subnet provides, in most situations it will be impracticable for an individual to deal with us on an anonymous basis. However, Subnet will consider requests on a case-by-case basis. An example of a situation where Subnet might permit an individual to deal with us anonymously or through the use of a pseudonym is when an individual is making an enquiry about our services or employment opportunities.


We may transfer to people in foreign countries any of your personal information to fulfil the purposes set out in this Privacy Statement, for example, to our offices overseas, or to data processors. All such transfers are on the basis that the information will be kept confidential, and not used except for the purposes set out in this Privacy Statement.

In most cases the transfer will be necessary to provide a service to you or for the implementation of pre-contractual 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. Please let us know if you have any objections to these transfers.


If you wish to gain access to your personal information, have a complaint about a breach of your privacy or you have any query on how your personal information is collected or used please forward your request, complaint or query to the address below. We will respond to your query or complaint as soon as possible. Privacy complaints about our acts or practices may be investigated by the Federal Privacy Commissioner who has the power to make a determination including a declaration that the claimant is entitled to compensation.


Attention: The Privacy Officer
76 – 78 Leader Street
Forestville, SA 5035
T: (08) 7127 9400


We may amend this Privacy Statement as our business requirements or the law changes. Any changes to this Privacy Statement will be updated on this website, so please visit periodically to ensure that you have our most current privacy statement.

In this Privacy Statement, “we”, “us” and “Subnet” means Wigtown Bear Pty Ltd ABN 77 083 911 246 and/or any of its subsidiaries, as applicable.


The information on this website is intended to be useful and informative for clients, the media and others who are interested in Subnet. Subnet will use reasonable care to ensure that information is accurate at the time it is added on the site. Please note, however, that Subnet cannot guarantee the information is accurate and it will not be liable for any losses or damage that anyone may suffer as a result of relying on this information. The information may be changed by Subnet at any time. Please also note that the contents of this website do not constitute an invitation to invest in shares of Subnet or any other company. The copyright in this website belongs to Subnet. All other intellectual property rights are reserved.