Privacy Policy

This Privacy Policy outlines our commitment to protecting the privacy of personal information provided to us, or otherwise collected by us, offline or online, including in person, in writing, via email, over the telephone and through our websites. It describes how we handle personal information in accordance with the Australian Privacy Principles in the Privacy Act 1988. This Privacy Policy may be amended from time to time.

Collecting your Personal Information

What is personal information?

Personal information is information that identifies you as an individual or from which your identity can be reasonably identified.

The types of personal information we may collect include your name, address, email and telephone. We may also collect other information of a personal nature that you disclose during communications with us, whether in person, over the telephone, via email or in writing.

In some instances, we may also collect government identifiers, such as your driver’s licence or passport details.

What is the purpose for collecting personal information?

We only collect personal information that is reasonably necessary for our business functions and activities, including managing our ongoing relationship with you.

How do we collect personal information?

There are several ways that we may collect your personal information. Additionally, Salubris Australia Limited holds your personal information in both physical and electronic forms in accordance with normal business practice.

The ways that we may collect your personal information are set out below:

• Directly from you
  If it is reasonable and practical to do so, we will collect your personal information directly from you. We may do this when we meet you in person, have a conversation with you over the telephone, you send an email or letter to us or you complete an online enquiry.
• Indirectly
  If it is unreasonable or impracticable to collect your personal information directly from you, we may collect it from third parties. This may include collecting your personal information from third parties such as public sources or government agencies. If we receive personal information about you from someone else without having asked for it, we will only continue to hold it if it is personal information that we could have collected from you ourselves, in accordance with this Privacy Policy.
• From our website
  If you are using our website, you will browse anonymously, except as set out in this section.
  For all visitors browsing our website, we may use cookies to collect information such as the server your computer is logged on to, your browser type (for example, Internet Explorer, Chrome or Firefox), the time of visit, pages visited and your IP address. An IP address is a number that is assigned to your computer automatically and required for using the Internet. We may also collect information about your location or activity while you use our website. We also use cookies to manage online advertising.
  Information collected in this way is not capable of personally identifying you.

However, if you have provided us with personal information by completing an enquiry form online, we may be able to link your identity to your previous anonymous browsing history and collect information about your possible future use of our website, irrespective of how you access our site (e.g. from a third party website). We may also use that information to tailor your online experience.

If you would prefer not to be identified in this way when using our website or would prefer us not to collect anonymous cookie information about you at all when using our website, you can delete the cookies and reconfigure the cookie preferences on your internet browser.

How we use and disclose your personal information

Using and disclosing personal information

We only hold, use and disclose personal information about you for the purposes outlined above, or for related purposes which might be reasonably expected, unless we otherwise obtain your consent.

For instance, we may collect, hold, use and disclose your personal information to process applications and payments, verify your identity and other details, manage our services (including monitoring, auditing and maintaining accurate records), manage our relationship with you, protect our lawful interests and deal with your enquiries and concerns.

To do this, we may disclose your personal information to third parties who:

1. provide services which are necessary for us to conduct our business activities, such as providers of share registry services, archival, data storage (including cloud based data storage providers), auditing, banking, insurance, marketing, technology, data processing, professional advisory (legal, accounting, financial and business consulting) and security services;
2. are regulatory bodies, government departments or government agencies, law enforcement bodies, courts and dispute resolution schemes;
3. are your authorised agents, executors, administrators or legal representatives.

We may also hold, use and disclose your personal information in connection with suspected fraud, misconduct and unlawful activity, and as part of a restructure or sale of Salubris Australia Limited.

We may hold personal information in, or disclose your personal information to, third party service providers who are located overseas.

Direct marketing

From time to time, we may use the personal information collected from you for direct marketing purposes, such as providing you with related investment news, targeted advertising and other information which we think you may find interesting.

We may contact you by telephone, electronic messages (e.g. email), online (e.g. website) and other means for these purposes.

If we do contact you in this way, it will only be in relation to matters that would reasonably be expected. And we will ensure that our marketing activities comply with applicable law.

If you no longer wish to receive any direct marketing communication from us, please follow the instructions for unsubscribing in our direct marketing communications. If there are no instructions, please contact us as set out in the ‘Complaints’ section below.

Keeping personal information secure

Before disclosing personal information, we confirm the identity of that person to prevent misuse or unlawful disclosure of the information. We also take measures to ensure the physical security of personal information at Salubris Australia Limited. When records containing personal information are no longer required for our business or by law, we delete the information or permanently de-identify it. If you are considering sending us any personal information electronically, please be aware that the information may be insecure in transit, particularly where no encryption is used (e.g. email, standard http).

Access and correction of personal information

Access

You may access the personal information we hold about you upon request. You can make a request in an email or letter or by telephone. To make such a request, please see our contact details in the ‘Complaints’ section below.

We will provide you access within 30 days if it is reasonable and practicable to do so, but in some circumstances it may take longer.

Your rights to access your personal information are subject to some limitations. We will not provide you with access to the extent it would be illegal to do so or, unless required otherwise by law, if it would have an unreasonable effect on the privacy of others or the request is frivolous or vexatious.

If access is refused, we will give you a notice explaining our decision to the extent practicable and your options to make a complaint.

We do not usually charge you for access to your personal information. However, if the request is complex, we may charge you the marginal cost of providing the access, such as staff costs of locating and collating information or copying costs.

Correction

We take reasonable steps to ensure that all personal information we hold is as accurate as possible. If you feel that the personal information we hold for you is incorrect, you are able to contact us to request that we correct that information.

If you would like to do so please contact us via contact@salubris.au

We will normally try to resolve correction requests within 30 days of you making a request. If we need more time to resolve your request we will notify you in writing as to the delay and seek your agreement to a longer period. There will be no cost to you if we correct your personal information held by us.

Complaints

If you believe that we have not complied with our obligations relating to your personal information, please contact us via contact@salubris.au

Updates

We may review and amend this Privacy Policy from time to time to address changes to laws and to reflect our current operations and practices.