Who we are and our commitment:

Uncomplicated Times Pty Ltd (ACN 700 835 945) (we, us, our) provides luxury watch sourcing and sale services. Depending on the transaction, we may locate a Watch for you and introduce you to the retailer, boutique or dealer who sells it to you directly, or we may acquire and sell a Watch to you ourselves. We will make clear which entity is selling the Watch before you enter into the transaction. We hold a second-hand dealer licence in Queensland, which requires us to keep records of the watches we buy and the people we buy them from.

We are committed to handling personal information in accordance with the Australian Privacy Principles (APPs) in the Privacy Act 1988 (Cth) and other applicable privacy laws. This Privacy Policy explains what personal information we collect, why, how we use and share it, and your rights. A shorter Collection Notice is provided at the point we collect your information; this Policy is the fuller statement.

This Privacy Policy applies to all personal information collected by us via our website located at [www.uncomplicatedtimes.com.au] ("Website").

What personal information we collect:

Clients and prospective clients

When you enquire with us or engage us, we typically collect:

• Your name, email address, phone number and postal address;

• Your watch brief and preferences brands, models, budget range, condition and timing — and your purchase history with us;

• Identity verification information required by anti-money laundering and counter-terrorism financing (AML/CTF) laws, which may include your date of birth, residential address, and copies or details of photo identification documents (such as a passport or driver licence), and information about the source of funds where the law requires it;

• Payment and transaction information, including information required to invoice and receive our sourcing fee and, where we sell a Watch to you directly, information required to process and administer payment of the purchase price. Payment card or banking information may be processed by our payment service providers rather than stored directly by us;

• Delivery information, transaction records and information concerning returns, warranties, authentication, servicing or other after-sales matters where we sell a Watch directly to you; and

• Records of our communications with you, including by email, phone, SMS and social media.

People who sell watches to us

If you sell a watch to us, or offer one for sale, trade-in or consignment, we collect your name, residential address, date of birth and contact details; evidence of your identity, such as a driver licence or passport; evidence that you own the watch and how you acquired it; the details of the watch, including brand, model and serial number; and the bank details we need to pay you. We are required to collect and record most of this information by the Second-hand Dealers and Pawnbrokers Act 2003 (Qld). If you do not provide it, we cannot buy your watch.

Dealer and business contacts

We collect the names and business contact details of people at the retailers, boutiques and dealers we work with.

Website visitors

When you use our website we collect technical data such as IP address, device and browser type, pages visited and referral source, using cookies and similar analytics technologies. You can disable cookies in your browser, though parts of the site may not function fully. You can browse our website, and make general enquiries, without identifying yourself or using a pseudonym; however, we cannot provide sourcing services or buy a watch from you anonymously because second-hand dealing laws require us to record who we acquired it from, and we cannot complete some transactions anonymously where identity verification is required by law.

Sensitive information

We do not ask for sensitive information (such as health, religious or biometric information) and ask that you do not send it to us. If you volunteer it, we will only keep it with your consent and where it is reasonably necessary.

How we collect it

We collect personal information directly from you through our website enquiry form, email, phone, SMS, social media, and in person. We may also collect it from:

• Dealers, to the extent needed to progress your purchase (for example, confirmation that your transaction has completed, which we are entitled to receive under our dealer agreements);

• Identity verification and AML/CTF screening providers, where the law requires us to verify who you are; and

• People authorised to deal with us on your behalf (for example, where a family member or adviser engages us for you).

Why we collect, use and hold it

We collect, hold and use personal information to:

Provide our sourcing services taking your brief, searching the market, making introductions to dealers, and coordinating your purchase through to completion;

• Verify your identity and otherwise comply with AML/CTF laws, including enrolment and reporting obligations to AUSTRAC where applicable;

• Invoice and administer our sourcing fee and where applicable process and administer direct sales, payments, delivery, returns, warranty matters and transaction records;;

• Communicate with you about your brief, watches we identify, and market opportunities relevant to your stated preferences;

• Send you marketing about our services if you have agreed to receive it, you can opt out at any time using the unsubscribe link or by contacting us, and we will action opt-outs promptly in accordance with the Spam Act 2003 (Cth);

• Operate, secure and improve our website and business; and

• Comply with our other legal obligations and establish or defend our legal rights.

• Buy, authenticate, hold and sell watches on our own account, including checking ownership and searching registers of lost or stolen watches; and

• Keep the transactions register and make the reports required of us as a licensed second-hand dealer

Who we disclose it to

In a Sourcing Transaction, we may disclose your name and appropriate contact details to the dealer, boutique or brand involved in sourcing or supplying the Watch. Where we sell a Watch directly to you, we may disclose information to an upstream supplier, authenticator, insurer, courier or other service provider only to the extent reasonably necessary to complete, verify, deliver or support the transaction.

Dealers, boutiques and brands

This is central to how our service works, so we want it to be clear: to make an introduction, we provide your name and, where appropriate, your contact details to the dealer, boutique or brand that holds (or can obtain) the watch you want. Some brands require us to notify them of a client's identity in advance of an appointment. Our agreements with dealers restrict them from using your details for their own marketing without your consent.

Service providers

We share personal information with providers who support our business, IT, website hosting and cloud services, CRM and communications platforms, identity verification and AML/CTF screening providers, payment processors  and financial institutions for sourcing fees and, where applicable, the purchase price of Watches sold by us.

Professional advisers, regulators and law enforcement

We may disclose personal information to our lawyers, accountants and insurers; to AUSTRAC and other regulators where the law requires or permits it (in some cases, the law prohibits us from telling you a disclosure has been made); and to courts or law enforcement under compulsory process. We may also disclose information as part of a genuine sale or restructure of our business, on confidential terms.

We do not sell personal information.

We store data on secure servers located in [Australia/other jurisdictions – via GoDaddy].

We take reasonable steps to:

• Protect data from misuse, interference, loss, unauthorised access, or disclosure. These include encryption, access controls, and secure transmission protocols.;

• Restrict access to authorised staff or contractors only;

• Ensure secure deletion or anonymisation of data when no longer required for business or legal purposes.

Information transmitted online is done so at your own risk; we cannot guarantee complete security of data transmitted over the internet.

Personal information is generally retained for the purposes outlined in this policy and as long as your account remains active. If you delete your account, identifying information will be removed or de-identified, although anonymised reviews may remain for analytical or historical purposes.

Overseas disclosures

The watch market is international. Depending on your brief, we may disclose your name and contact details to dealers, boutiques or brands located overseas most commonly in Switzerland, the United Kingdom, the European Union, the United States, the United Arab Emirates, Hong Kong, Singapore and Japan. Some of our service providers (such as cloud, CRM and analytics platforms) also store data overseas, including in the United States and the European Union.

Where we disclose personal information overseas, we take steps reasonable in the circumstances to ensure the recipient handles it consistently with the APPs, such as contractual protections, unless an exception under APP 8 applies (for example, where the disclosure is required to provide the service you have asked for and you have been informed and consented). Overseas recipients are subject to the laws of their own countries, which may differ from Australian law.

Where we buy or sell a watch ourselves, we may also disclose the details of that watch, including its serial number, and in some cases limited personal information, to authentication specialists, brand service centres and international databases of lost and stolen watches, which are most commonly located in Switzerland, the United Kingdom and the United States

How we hold and protect it, and for how long

We hold personal information in secure cloud-based systems and, where in hard copy, in secure storage. We use safeguards appropriate to a business handling high-value transactions access controls, multi-factor authentication, encryption in transit and appropriate vendor due diligence and we limit access to those who need it.

We keep personal information only as long as needed for the purposes above and to meet legal obligations. Records we are required to keep as a licensed second-hand dealer are retained for the period required by that legislation. .We retain personal information for as long as reasonably necessary for the purposes for which it was collected and to comply with applicable legal obligations. Where AML/CTF record-keeping obligations apply, we retain the records required by those laws for the applicable period. We do not retain copies of complete identity documents merely because they were used for verification where they are no longer reasonably required, and take reasonable steps to destroy or de-identify information when it is no longer required.

If a data breach occurs that is likely to result in serious harm, we will notify affected individuals and the Office of the Australian Information Commissioner (OAIC) in accordance with the Notifiable Data Breaches scheme.

Access, correction and complaints

You may request access to, or correction of, the personal information we hold about you by contacting us at the details below. We will respond within a reasonable period (usually within 30 days). We do not charge for making a request, and will only charge reasonable costs (if any) of giving access. If we refuse access or correction, we will tell you why in writing and how to complain.

If you believe we have mishandled your personal information, please contact us first — we will acknowledge your complaint promptly and aim to resolve it within 30 days. If you are not satisfied, you may complain to the OAIC at www.oaic.gov.au or 1300 363 992.

Changes and contact

We may update this Privacy Policy from time to time; the current version will always be published on our website with its date. Material changes to how we handle personal information will be notified on the website or directly where appropriate.

Privacy contact: Privacy Officer / Clare Smith, Uncomplicated Times Pty Ltd, [enquiries@uncomplicatedtimes.com.au, 0432 981 275.