PRIVACY POLICY can be read www.otcbb.com.au/privacy.html

This Policy applies to General Credits Australia Ltd and/or its related organisations in, Melbourne, Rome, London, Hong Kong, Republic of Nauru and the United States ('General Credits Australia Ltd'). It also applies to other companies known as General Credits, Inc, General Credits Capital Corp (USA), Inc., General Credits Custodians Pty Ltd, General Credits Financial Services Pty Ltd, General Credits Capital Pty Ltd, Secur-O-Clear, Corporate Investor Relations Pty Ltd, Australian Unlisted Capital Market Pty Ltd and its related bodies corporate.

This Policy outlines the obligations which General Credits Australia Ltd has in managing the corporate and/or personal information we hold about our clients, potential clients, contractors and others.

General Credits Australia Ltd's privacy policy in respect of its employees is dealt with in separate policy.

General Credits Australia Ltd is bound by the National Privacy Principles ('NPPs') contained in the Privacy Act 1988 (Cth) ('Privacy Act').

In summary, 'personal information' is information or an opinion relating to an individual which can be used to identify that individual.

Why does General Credits Australia Ltd collect personal information?

General Credits Australia Ltd collects personal information in order to conduct its business, to provide and market its services and to meet our legal obligations to the Regulatory and Policing Authorities in various countries.

About whom do we collect personal information?

The type of information we may collect and hold includes (but is not limited to) personal information about clients, business associates and potential clients and their employees suppliers and their employees prospective employees, employees and contractors; and other people who come into contact with:a member of the General Credits Australia Ltd

What kinds of personal information do we collect?

In general, the type of personal information General Credits Australia Ltd collects and holds includes (but is not limited to): names, addresses, contact details, occupations and other information which assist us in conducting our business, providing and marketing our services and meeting our legal obligations.

In most cases, if personal information we request is not provided, we may not be able to supply the relevant product or service.

How do we collect personal information?

Personal Information you provide: General Credits Australia Ltd will generally collect personal information by way of forms filled out by people, face-to-face meetings, interviews, business cards, telephone conversations and from third parties.

Personal Information provided by other people: In some circumstances General Credits Australia Ltd may be provided with personal information about an individual from a third party, for example a report provided by a medical professional or

a reference from another person.

Web site Collection

General Credits Australia Ltd collects personal information from the web site www.otcbb.com au or cirbb.com.au through receiving subscription applications and emails. We also use third parties to analyse traffic at that web site, which may involve the use of cookies. Information collected through such analysis is anonymous.

How might we use and disclose your personal information?

General Credits Australia Ltd may use and disclose your personal information for the primary purpose for which it is collected, for reasonably expected secondary purposes which are related to the primary purpose and in other circumstances authorised by the Privacy Act.

In general, we use and disclose your personal information for the following purposes: to conduct our Business, to provide and market our services; to communicate with you; to purchase from you; to comply with our legal obligations; and to help us manage and enhance our services.

To whom might we disclose your personal information?

We may disclose your personal information to: other members in General Credits and our Associated Office; other companies or individuals who assist us in providing services or who perform functions on our behalf (such as mailing houses, specialist consultants and barristers); courts, tribunals and regulatory authorities; and anyone else to whom you authorise us to disclose it.

We also collect personal information from these organisations and individuals, and deal with that information in accordance with this Policy.

Sending information overseas:

We will not send your personal information to recipients outside of Australia without obtaining your consent (in some cases this consent will be implied);or otherwise complying with the NPPs. General Credits Australia Ltd may disclose your personal information to other members of the General Credits group and our Associated or Contact office, including offices located outside Australia. We take reasonable steps to ensure that such recipients respect the confidentiality of this information by abiding by the NPPs or equivalent privacy laws.

Sensitive information

Some personal information which we collect is ‘sensitive information’. Sensitive information includes information relating to a person's racial or ethnic origin, political opinions, religion, trade union or other professional or trade association membership, sexual preferences and criminal record, that is also personal information; and health information about an individual.

Sensitive information will be used and disclosed only for the purpose for which it was provided or a directly related secondary purpose, unless you agree otherwise, or where certain other limited circumstances apply (eg, where required by law).

Management of personal information

The NPPs require us to take reasonable steps to protect the security of personal information. General Credits Australia Ltd personnel are required to respect the confidentiality of personal information and the privacy of individuals.

General Credits Australia Ltd takes reasonable steps to protect personal information held from misuse and loss and from unauthorised access, modification or disclosure, for example by use of physical security and restricted access to

electronic records.

Where we no longer require your personal information for a permitted purpose under the NPPs, we will take reasonable steps to destroy it.

How do we keep personal information accurate and up-to-date?

General Credits Australia Ltd endeavours to ensure that the personal information it holds is accurate, complete and up-to-date. We encourage you to contact us in order to update any personal information we hold about you. Our contact details are set out below.

You have the ability to gain access to your personal information

Subject to the exceptions set out in the Privacy Act, you may gain access to the personal information which General Credits Australia Ltd holds about you by contacting a General Credits Privacy Officer.

We will require you to verify your identity and to specify what information you require. A fee may be charged for providing access. We will advise you of the likely cost in advance.

Updates to this Policy

This Policy will be reviewed from time to time to take account of new laws and technology, changes to our operations and practices and the changing business environment. The most current version of this Policy is located at http://www.otcbb.com.au/privacy.html.

Enquiries

If you have any questions about privacy-related issues please contact the relevant General Credits Privacy Officer: