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Armstrong Registry Services Limited (Armstrong Registry Services) understands that privacy is important to you.

Armstrong Registry Services is subject to the requirements of the Privacy Act 1988 (Cth) (‘Privacy Act’) including the national privacy principles which govern, among other things, how we handle your personal information.

Armstrong Registry Services honours without reservation our obligation to respect and protect the privacy of the personal information of individuals with whom we deal.

Our privacy policy is designed to answer the following questions:

What personal information does Armstrong Registry Services collect?

How is personal information collected and stored?

How is personal information used?

Will personal information be given to anyone else?

How can you access and correct your personal information?

What personal information does Armstrong Registry Services collect?

Personal information means information or an opinion from which an individual’s identity may be ascertained. Armstrong Registry Services, a provider of registry and registry related services to listed and unlisted entities (‘Issuers’) and the holders of their securities (‘you’) may obtain personal information in order to administer your securityholding or to provide you with other services. If part or all of the information is not provided, then Armstrong Registry Services may not be able to supply its services to the Issuers and you.

In accordance with the Corporations Act 2001 (Cth) (Corporations Act 2001), Armstrong Registry Services collects personal information about you including your name, address and details of any securities held on behalf of the Issuer. This information is included in the public register of the Issuer in which you hold your securities. You may also be asked to provide contact information including telephone and facsimile numbers and email addresses. Other examples of information Armstrong Registry Services may require from you are your tax file number and financial institution account details. Under the Corporations Act, your personal information must continue to be included in the public register of the Issuer for seven years after you cease to be a securityholder.

How is personal information collected and stored?

The way in which personal information is collected and stored depends on how you interact with Armstrong Registry Services and the services you require.

We may collect personal information about you from an application form or a registration form or verbally if you call us or speak directly with our staff.

In addition, if you access our website, we may collect personal information relating to you during your business visit to our website. The personal information is maintained on our servers and a reference to this information is sent to the application you are using to access the internet, in the form of a cookie. A cookie is a packet of information placed on a user’s computer by a website for record keeping purposes. Cookies are generally used on the Armstrong Registry Services website to monitor website traffic. Cookies may also be used for other purposes, but in each case none of the information collected can be used to personally identify you.

You can configure your browser to accept all cookies, reject all cookies, or notify you when a cookie is sent. Each browser is different, so check the Help menu of your browser to learn how to change your cookie preferences. If you disable the use of cookies on your web browser or remove or reject specific cookies from Armstrong Registry Services website or linked sites, then you may not be able to gain access to all of the content and facilities in this website.

If you visit our website to browse, read or download information, Armstrong Registry Services system will log these movements. These website logs are not personally identifiable and Armstrong Registry Services makes no attempt to link them with individuals who browse the site.

Armstrong Registry Services takes reasonable steps to ensure the security of personal information held by it from such risks as loss or unauthorised access, destruction, use, modification or disclosure.

How is personal information used?

Armstrong Registry Services’ policy is to use personal information for the purpose for which it was collected and to offer and provide related services that are connected to that initial purpose.

For example, the personal information collected by Armstrong Registry Services from you may be used to:

  • Notify you about other Issuer or registry services relating to the purpose for which your personal information was collected; and/or
  • Provide the relevant Issuers and you with registry and registry related services, or with other information you have requested.

If at any time you no longer wish to be notified about other Issuer or registry services, please let us know. Please note that the personal information collected about you may be disclosed to related companies of the Issuer or Armstrong Registry Services, but only if this relates to the purposes for which your personal information was collected.

Under the Corporations Act Chapter 2C, certain information about you as a securityholder, including your name, address and details of the securities you hold must be included in the public register of the entity in which you hold securities and therefore this information will be disclosed and in the public domain. Armstrong Registry Services will not use or disclose your personal information for any other purpose without first obtaining your express or implied consent.

Will personal information be given to anyone else?

Armstrong Registry Services policy is designed to maintain the confidentiality of all personal information. We will take all reasonable steps to protect your personal information from misuse and loss and from unauthorised access, modification and disclosure. Armstrong Registry Services does not sell, rent or trade personal information to or with third parties.

In some circumstances, however, personal information may be disclosed outside Armstrong Registry Services. For example:

  • Personal information collected by Armstrong Registry Services may be disclosed to third parties to which Armstrong Registry Services contracts out specialist functions including mail houses and printing companies. If so, we take reasonable steps to ensure that those contractors comply with the Privacy Act and are authorised only to use the personal information in order to perform the functions required by Armstrong Registry Services.
  • Disclosures may be required or authorised by or under law, for example, in accordance with the Corporations Act where a person requests a copy of an Issuer’s register of securityholders.
  • Personal information may be disclosed to third parties in accordance with the Issuer’s direction where this is related to the Issuer’s administration of securityholdings.

How can you access and correct your personal information?

Under the Privacy Act, you have a right to seek access to information that we hold about you, although there are some exceptions to this (please see Principle 6 of the National Privacy Principles extracted from the Privacy Amendment (Private Sector) Act 2000. You will also have the right to ask us to correct information about you which is inaccurate, incomplete or out of date. Armstrong Registry Services’ policy is to consider any requests for access or correction in a timely way and to take reasonable steps to correct the information so that it is accurate, complete and up to date.

To provide you with access to your personal information, Armstrong Registry Services would ordinarily provide you with a print out of the relevant personal information from our current data bases, or with photocopies of records which are only held on current paper files.

To access and/or correct such information, you may write or call Armstrong Registry Services on the following:

Telephone: +61 7 3231 0050

Facsimile: +61 7 3231 0099

In writing: GPO Box 897, Brisbane, Queensland 4001

If you wish to correct current information about you which is inaccurate, incomplete or out of date, then for security purposes, you will need to prove your identity by confirming/providing the following information to us:

  • Quote your holder identifier number/securityholder reference number that appears on the last documentation sent to you in relation to your securityholding; or
  • Quote/proof of your registered name (note supporting documentation eg birth certificate (marriage certificate may also be required) and quote/proof of your registered address, that match the details appearing on the register.

A form signed by you will also need to comply with the signing requirements below:

Individual holder must be signed by the securityholder and/or his attorney.

Joint holders must be signed by all joint securityholders or their attorneys.

Companies must be signed by either two directors or a director and company secretary with their titles stated, or a sole director and sole company secretary with his/her title stated; or the company’s attorney; or on letterhead if it claims to be signed by a duly authorised officer with their title.

If the form is signed by an attorney, a certified copy of the Power of Attorney must accompany the form.

Please note that if your securityholding is sponsored by a broker, you will need to contact your broker direct who will then arrange for the information to be corrected.

For legal and administrative reasons, Armstrong Registry Services may also store records containing personal information in our archives. You may seek access to the records held by Armstrong Registry Services which are not current records, but if you do so, we may charge you for the cost of providing access.

If you have any questions or comments about this privacy policy, or if you wish to complain about how we have handled personal information about you, please contact Armstrong Registry Services Privacy Officer:

Telephone: +61 7 3231 0050

Facsimile: +61 7 3231 0099

Email: privacy@armstrongregistryservices.com.au

In writing: The Privacy Officer

Armstrong Registry Services Limited, GPO Box 897, Brisbane, Queensland 4001

This privacy policy may change from time to time.

Armstrong Registry Services      Ph: +617 3231 0050      Email: registry@armstrongregistries.com.au
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