Privacy Policy

Advanced Share Registry Ltd ABN 14 127 175 946 (Company) offers this website, including all information, software, products and services available from this website or offered as part of or in conjunction with this website (Website), to you, the user, conditioned upon your acceptance of all of the terms, conditions, policies and notices stated here (Terms and Conditions). The Company reserves the right to make changes to these Terms and Conditions immediately by posting the changed Terms and Conditions in this location.

Your use and continued use of the Website constitutes your agreement to the Terms and Conditions, and any changes to the Terms and Conditions made by the Company.

The term 'us' or 'we' refers to the Company as the owner of the Website. The term 'you' refers to the user or viewer of the Website.

The use of this website is subject to the following terms of use:

• You use the Website at your own risk. The Website is provided to you "as is," without warranty of any kind either express or implied. Neither the Company nor its employees, agents, third-party information providers, merchants, licensors or the like warrant that the Website or its operation will be accurate, reliable, uninterrupted or error-free. No agent or representative has the authority to create any warranty regarding the Website on behalf of the Company. The Company reserves the right to change or discontinue at any time any aspect or feature of the Website.
• The Website may contain information about our company including business description, names of officers and details of our registry services. While every attempt is made to ensure this information is accurate, the accuracy of this information cannot be guaranteed and you should not rely on such information.

Exclusion of Liability

• The content of the pages of the Website is for your general information and use only. It is subject to change without notice.
• Neither the Company nor any third parties provide any warranty or guarantee as to the accuracy, timeliness, performance, completeness or suitability of the information and materials found or offered on the Website for any particular purpose. You acknowledge that such information and materials may contain inaccuracies or errors and we expressly exclude liability for any such inaccuracies or errors to the fullest extent permitted by law.

Indemnification

• Your use of any information or materials on the Website is entirely at your own risk, for which the Company shall not be liable. It shall be your own responsibility to ensure that any products, services or information available through the Website meet your specific requirements.
• The Website contains material which is owned by or licensed to us. This material includes, but is not limited to, the design, layout, look, appearance and graphics. Reproduction is prohibited other than in accordance with the copyright notice, which forms part of these terms and conditions.
• All trademarks reproduced on the Website which are not the property of, or licensed to, the operator are acknowledged on the Website.
• Unauthorised use of the Website may give rise to a claim for damages and/or be a criminal offence.
• From time to time the Website may also include links to other websites. These links are provided for your convenience to provide further information. They do not signify that we endorse the website(s). We have no responsibility for the content of the linked website(s).

Copyright

• Except for material in the public domain under copyright law, all material contained on the Website (including all software, HTML code, Java applets, and other code) is protected by Australian and foreign copyright laws. Except as otherwise expressly provided in these Terms and Conditions, you may not copy, distribute, transmit, display, perform, reproduce, publish, license, modify, rewrite, create derivative works from, transfer, or sell any material contained on the Website without the prior consent of the Company.
• None of the material contained on the Website may be reverseengineered, disassembled, decompiled, transcribed, stored in a retrieval system, translated into any language or computer language, retransmitted in any form or by any means (electronic, mechanical, photo reproduction, recordation or otherwise), resold or redistributed without the prior written consent of the Company.

Governing Law

• These Terms and Conditions are governed by and enforced in accordance with the laws of Western Australia. Any disputes arising from these Terms and Conditions or in connection with the use of the Website are subject to the exclusive jurisdiction of the courts of Western Australia. The Website may be accessed throughout Australia and overseas. The Company makes no representation that the content on the Website complies with the laws of any country outside Australia. If you access the Website from outside Australia, you are responsible for ensuring that your access to, downloading of, use of or reliance on the content contained on the Website is in compliance with all laws in the place in which you are located.

This following statement sets forth the privacy policy of Advanced Share Registry Ltd ABN 14 127 175 946 (Company or ASW) and its website (Website).

• ASW is bound by the Australian Privacy Principles in the Privacy Act 1988 (Cth) and the Privacy Amendment (Enhancing Privacy Protection) Act 2012, that set out a number of Australian Privacy Principles (APPs). Our aim is to both support and ensure that we comply with these principles. Further information on privacy in Australia may be obtained by visiting the website of the Office of the Australian Information Commissioner at http://www.oaic.gov.au. We believe that this Privacy Policy discloses the purpose, and how the personal and we will protect your personal information in accordance with the Australian Privacy Principles (APP). These principles govern how ASW can collect, use, hold and disclose your personal information, as well as ensuring the quality and security of your personal information.

  ASW also complies with other applicable laws and regulations affecting your personal information, including the Corporations Act 2001 (Cth) and ASX Settlement Operating Rules.

  ASW provides a range of securities registry services to securities issuers (Issuers) including registering securities transfers, handling communications from Issuers to their securityholders, the payment of distributions or dividend payments, handling securityholder inquiries on behalf of Issuers and recording changes to security holdings.

  This privacy policy may be updated from time to time.

• Personal information we collect

  ASW collects personal information about security holders, subscribers and each of their delegates that may include:

  • Names, contact and residential and mailing address details;
  • Phone numbers, mobile numbers and email addresses;
  • Information in identification documents (for example, passport, driver’s licence);
  • Tax file numbers and other government-issued identification numbers;
  • Date of birth and gender;
  • Bank account details, shareholdings and details of investments;
  • Personal information about your spouse and dependants; and
  • IP address (when you use our website).

• How personal information is collected

  We may collect your personal information about you through the following sources:

  • In written form i.e. shareholder forms and/or written letters, emails sent by you or your representatives (for example: your advisers, accountant, broker etc);
  • Electronically i.e. by accessing our website by you or your representatives (for example: your advisers, accountant, broker etc);
  • Verbally;

  The issuer i.e. from the issuer of your security holding; and any securities exchange.

  We will take steps to ensure that personal information we hold is accurate, complete and up-to-date. If you think that we hold information about you that is incorrect in any way, please update that information via our website https://www.advancedshare.com.au/ or contact us.

• Why ASW collects information

  We collect personal information about you so that ASW can facilitate the efficient provision of the registry services. For example:

  • Pay your dividends directly into a bank account provided by you;
  • Send holding confirmations directly to you by the email provided by you;
  • Provide important information about your security holding to your email or send important information to your mailing/registered address maintained by ASW;
  • To inform you of the products and services offered by the issuers of your securities and services offered by ASW;
  • To perform other registry functions such as system development, staff training, surveys and research;
  • To prevent or investigate any fraud or crime (or suspected fraud or crime); and
  • As required by law (for example, ATO reporting).

• Disclosure of your information

  Personal information is only disclosed in the course of providing our services. For example, personal information may be accessed by, or disclosed to, the party on whose behalf we are acting as registry, mail houses, legal advisers, insurers, regulators and courts. In some situations the law may require the provision of information to an individual’s spouse or former spouse.

  ASW and our outsourced partners may use other providers to help maximise the quality and efficiency of our services and our business operations. This means that individuals and organisations outside of ASW and our outsource partners, such as mail houses, will sometimes have access to personal information held by us and may use it on our behalf. These providers are required to adhere to strict privacy guidelines and not to keep this information or use it for any unauthorised purposes. ASW accepts no responsibility for any breach of privacy by third parties.

  We will only disclose your personal information to a third party to provide you with a service that you requested or the services offered by the issuer of securities.

  Under the Corporations Act 2001 (Cth) certain information about you as security holder must be included in the public register of the entity in which you hold securities and therefore this information will be disclosed and is in the public domain.

• Access & correction to information collected

  Individuals will have access to their personal information collected via our website or directly from us and are able to notify us of any corrections which need to be made. However, there are exemptions as specified in the APPs where access may be denied. If your security holding is broker sponsored, you need to contact that broker to update your registered name or address.

  We will only grant access by an individual to personal information where the individual has given appropriate identification verification, which may be required in writing and subject to the terms and conditions of the use of the services of ASW. We reserve the right to impose charges for providing such access to information.

• Marketing and privacy

  ASW may from time to time use or disclose your personal information to send you marketing material about particular products and services offered by us or our related bodies corporate. In addition, the Issuer of your security holding may choose to either send or authorise us on their behalf to send you marketing material or include such material in a corporate communication.

  Marketing materials may be sent to you in various forms, including mail, SMS, facsimile and email. If you indicate a preference for a method of communication, we will endeavour to use that method whenever practical to do so.

  If you would like to opt-out of receiving marketing material about ASW, any of our related bodies corporate or for any of your security holdings registered with ASW, please contact us on +618 9389 8033

• Security and storage of information

  Where we store your information as a part of our services or to enable us to provide the services, we have developed security measures and implemented global standard operating procedures that cover the handling and storage of your information. These procedures are in turn localised to effectively ensure Australian standards are adhered to. Internally we have developed a set of standards to ensure our policies and procedures meet or exceed industry and government legislative requirements.

  In some cases you may be using services that involve digital storage of your information, whether it is in the form of cloud storage, or as a result of us carrying out scanning services. In these cases we use the following measures:

  • Firewalls and access logging tools that protect against unauthorised access to your data and our network.
  • Secure work environments and workflow systems that prevent unauthorised access and copying of your personal information.
  • Secure server and closed network environments.
  • Encryption of data.
  • Virus scanning tools.
  • Ongoing security reviews.

  Personal information collected by ASW may be accessed by our officers, employees, agents and delegates. Personal information is stored in secure electronic databases and where applicable, on paper documents. Any information on paper documents is stored for a period of time determined by law or as agreed with the issuer of your security holding.

  We take all reasonable measures to protect personal information that we hold from unauthorised access, modification or disclosure. We will, where practicable, destroy or permanently de-identify personal information that is no longer needed.

  The digital landscape is constantly changing, so while these measures have been successful to date, the nature of the medium means that they cannot be relied upon to always be effective. We will keep striving to maintain the security of your digital personal information.

• Visiting our website

  When visiting this website, a record of your visit is logged and information is automatically recorded for statistical purposes to enable us to improve this site and our services. This information may identify you personally and ASW may track information about individuals and their visits.

• Links to other websites

  Sometimes our website may contain a link to third party websites. ASW is not responsible for the content or material contained in, or obtained through, any third party website or for the privacy practices of the third party website. We suggest that you review the privacy policy of each website that you visit.

• How you can help protect your privacy

  You can help protect your privacy by:

  • Contacting us immediately when you change/update your contact details, such as your mailing/postal or registered address. If your security holding is broker sponsored, you need to contact that broker to update your registered name or address;
  • Keeping your Security holder Reference Number (SRN) and/or Holder Identification Number confidential; and
  • Keeping your login credentials such as username and password confidential.

• How to contact us about privacy

  If you have any questions or complaints about this privacy policy, please contact us or write directly to:

  The Privacy Officer
  Advanced Share Registry Ltd
  110 Stirling Highway
  Nedlands WA 6009

• Complaint Resolution

  If you wish to make a complaint to ASW about our handling of your personal information, please contact our Privacy Officer in writing as set out above.

  Your access to and use of this site is conditional upon your acceptance and compliance with the terms, conditions, notices and disclaimers contained on this page and elsewhere on the ASW Site ("General Conditions"). Your Access to the Site constitutes your agreement to be bound by the General Conditions. ASW reserves the right to amend the General Conditions at any time and you should periodically refer to them on this page and elsewhere on the Site.