PROTECTING YOUR PRIVACY
Protecting your privacy and your personal information is important to Georgeson Shareholder Communications Australia Pty Ltd (ABN 19 092 812 470) (Georgeson). We are bound by the Australian Privacy Principles in the Privacy Act 1988 (Cth).
Georgeson, a Computershare company, is a leading provider of strategic shareholder services to corporations and shareholder groups (Clients). We offer unsurpassed advice and representation for annual meetings, mergers and acquisitions, proxy contests and other extraordinary transactions. Our core proxy expertise is enhanced with and complemented by our strategic consulting services, including solicitation strategy, shareholder identification, corporate governance analysis, vote projections and insight into investor ownership and voting profiles (collectively, our Services).
HOW WE COLLECT YOUR PERSONAL INFORMATION
In the course of providing Services to Clients, and in meeting the service needs of their investors, we receive personal information about shareholders. The types of personal information we may collect includes names, address details, phone numbers, email addresses, bank account details and credit card details.
This information can come from you directly when you send us a form, request customer support or otherwise communicate with us. We also collect personal information about you from Clients, for example, the issuer of your shareholding or third parties who are authorised or directed by Clients to provide information to us, including other share registry and financial services providers.
We may also collect information about you from publicly available resources, for example, the information about you that appears in a telephone directory. If you are a shareholder, we may also collect information about you that is included in the public share register in which you hold shares.
HOW WE USE YOUR PERSONAL INFORMATION
We only collect personal information about you that is necessary to perform our functions and activities. We collect information only by fair and lawful means.
Georgeson may collect your personal information:
- to provide Services to relevant Clients and you, or with other information you have requested;
- to inform you of other products or services offered by Georgeson and its related bodies corporate;
- to perform other administrative and operational functions (including systems development and testing, staff training and market or customer satisfaction research); and
- for other lawful purposes related to the Services we provide and to better serve your and our Clients' needs.
DISCLOSURE OF YOUR PERSONAL INFORMATION TO THIRD PARTIES
Georgeson may disclose your personal information:
- to our related bodies corporate that provide data processing or other support services including printing and mailing (primarily our parent company, Computershare, or its affiliates since we are members of the Computershare group of companies and these entities are generally located in Australia, Canada, New Zealand, the United Kingdom and the United States of America);
- to other companies or individuals who assist us in supplying our services or who perform functions on our behalf, including providers of contact centre services and products such as automated dialling systems;
- to Clients in the course of providing Services to them;
- to third parties in accordance with a Client's direction in the course of providing Services to them;
- to your authorised agents, administrator or legal representative;
- to regulatory authorities or as otherwise required to fulfil legal and regulatory requirements; or
- where required or authorised by law to do so.
Under no circumstances do we sell investor lists or other personal information to third parties. Georgeson will only disclose your personal information to a third party for the purpose for which the information was collected or for related purposes. In this respect, Georgeson may disclose your personal information to overseas recipients, if necessary, to perform our functions and activities where authorised or directed to do so by our Clients.
ACCESS AND CORRECTION
Georgeson takes various measures to ensure the accuracy of your personal information. We also rely on you to inform us of relevant changes to your information. For example, there may be problems mailing you important communications if you have moved and you have not advised us or our client company of your new address.
If you would like to access, correct and update the personal information that we hold about you, please contact the relevant number set out on the documentation that we send to you. You can also contact our Privacy Officer (contact details provided below) if you would like to access or correct the personal information that we hold about you. We will respond to your request within a period of reasonable time.
To ensure the integrity and safety of your personal information, we will only disclose personal information to you or an authorised person acting on your behalf if our internal procedures are satisfied.
We may impose a small fee to respond to your request for access but, if we do, we will first give you notice of the amount and obtain your direction to proceed.
In some cases we might not provide access to personal information within our possession or control. This could occur when providing access would reveal confidential commercial information or the information has been collected during the investigation of a legal matter or cannot be disclosed for other legal reasons. If we deny your request for access to your personal information, we will tell you why in writing unless, having regard to the grounds for the refusal, it would be unreasonable to do so.
STORAGE AND SECURITY OF PERSONAL INFORMATION
Georgeson maintains physical, organisation and technological safeguards to protect your personal information from loss, misuse, interference, unauthorised access, modification or disclosure. Your personal information may be stored in paper-based form or electronically in our systems.
Our computer systems, including portions of Computershare's and Georgeson's websites, are kept secure through the use of firewalls and other security measures such as identification codes and passwords to control access to computer system. If you send us an email message that includes personal information, we may use that information to respond to your inquiry, but please note that email and other Internet communications are not necessarily secure against interception. If your communication is very sensitive, you should not send it electronically unless your browser indicates that the access to our website is secure.
HOW TO CONTACT US ABOUT PRIVACY
If you have any questions about our privacy practices or wish to make a complaint about the way Georgeson has handled your personal information, please contact our Privacy Officer by email at firstname.lastname@example.org or write to:
Georgeson Shareholder Communications Australia
Level 3, 60 Carrington Street
Sydney NSW 2000
We will respond to your complaint within a reasonable period of time.
Georgeson will generally provide you with a written response based on the findings of our investigation within 30 days of receipt of your original complaint. If this is not possible, our Privacy Officer will arrange for a Georgeson representative to contact and advise you about the progress we have made and the estimated completion date for the investigation process.