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Privacy Policy - Easton Investments Limited (Easton)

 

Easton believe that privacy is an important individual right and are committed to ensuring the privacy of personal information. We are bound to comply with the Australian Privacy Principles (APPs) subject to the Privacy Act 1988 (Cth) (the Act).

 

The Easton Privacy Policy sets out how Easton collects information about you, what we do with it, and our information handling practices to ensure the privacy of individuals interacting with the Company and using our website - www.eastoninvestments.com.au.

 

The principles set out in the Privacy Policy will apply to personal information you provide to Easton, via our website, under any arrangement or agreement, or by any other means.

 

Throughout the Privacy Policy, we refer to "personal information" which means information that identifies you as an individual or from which your identity can be reasonably ascertained. Your home address and telephone number are examples of personal information.

 

The Privacy Policy does not apply to acts and practices of an Easton entity which relates directly to the employee records of the entity's current and former employees.

 

When will we collect your personal data?

 

Easton only collects personal information if it is necessary or incidental to our business purposes.  We note that Easton has out-sourced the share registry function and, as such, Easton does not collect or maintain share registry information, although it does have access to that information in the normal course of business.

 

The types of personal data that we collect from you

 

The information we collect may be limited to contact details where we interact with the public over the telephone or in person, or when you send us correspondence (whether by letter, fax, website facility or e-mail). In general, the type of personal information we collect and hold includes, but is not limited to: names, addresses, contact details, occupations and other information which assist us in conducting our business.

 

Easton receives personal information from our website www.eastoninvestments.com.au through it being accessed and through use of the ‘make an enquiry' facility. Your use of our website will determine the extent and type of information collected. In general, you can visit our website without revealing any personal information about yourself. Your name, contact number and email address will only be recorded if you send us a message, and will only be used for the purpose for which you have provided it. It will not be added to a mailing list or used for any other purpose without your consent, after which it may subsequently be removed at your request.

 

Use of Personal Information

 

We use personal information for the primary purpose for which it is collected or received. That may include responding to an individual's request. We may also use and disclose personal information for purposes related or ancillary to the main reasons we collect it. We will not use your personal information for any purpose which is not related to the functions or activities of Easton, or for any purpose for which you would not reasonably expect us to use the information. Reasonable steps are taken to ensure that personal information is accurate, complete and up-to-date whenever Easton receives or uses it.

 

Disclosure of your personal data

 

Easton only shares personal information where we are required to do so in order to comply with our legal and statutory obligations.  As noted above, Easton has access to share registry information, but does not share such information unless required to do so in compliance with its regulatory disclosure obligations.

 

Storage and Security of Information

 

Easton takes all reasonable measures to ensure the security of data supplied, and to protect it from misuse, unauthorised access, modification or disclosure.

 

In relation to security on the Easton website at www.eastoninvestments.com.au, mechanisms are in place to protect the security and integrity of your personal information. However, no data transmission over the internet can be guaranteed as completely secure so any information that you provide to us over the internet is at your own risk.

 

Access to and Correction of Personal Information

 

We will provide access to personal information upon request by an individual, unless a request is unreasonable and the APPs would permit us to decline that access. We will require you to verify your identity and to specify what information you require.

 

Persons who wish to gain access to their personal information should contact Easton by writing to:

 

The Privacy Officer

Easton Investments Limited

Level 2, 115 Pitt Street, Sydney NSW 2000

Attention: Company Secretary

 

In some cases, we may request an administrative fee to cover the cost of access. If we refuse to provide you with access to the information, we will provide you with reasons for the refusal and inform you of any exemptions relied upon under the Act.

 

You should notify Easton of a change to personal information or if you believe that the information held is incorrect or incomplete.

 

Your Computer and the Easton website including links to other websites

 

"Cookies" are pieces of information that may be transferred to your computer's memory when you visit a website for record keeping purposes. Any website server (including Easton’s) may:

 

  • store one or more cookies in your browser; or

  • request your browser to transmit the data to the Web server.

 

Our website may store cookies on your computer in order to better serve you upon your subsequent visits to the Easton website. We may track usage patterns on our website on an anonymous aggregate basis, however your identity cannot be reasonably ascertained from this information.

 

The data that may be recorded may likely include your:

 

  • Internet Service Provider

  • The type of browser you are using

  • Date and time of your visit

  • Pages accessed and documents downloaded

  • Referring URL's

 

Please note that most web browsers can also be configured to notify the user when a cookie is received, allowing you to either accept or reject it. If you are not sure whether your browser has this capability, you should check with the software manufacturer or your Internet Service Provider.

 

Our website includes links to other websites, including those of our related companies’ websites and our share registry provider, whose privacy practices may be different from that of Easton. If you submit Personal Information to any of those sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any website you visit.

 

By using our website, you are consenting to the collection of information by us in accordance with the Privacy Policy.

 

Anonymity

 

You have the option of using a pseudonym when dealing with us so as not to identify yourself fully to us. Please bear in mind, however, that we will be unable to provide certain services to you unless you disclose your correct identity.

 

Direct marketing and opting out

 

We want to communicate with you only if you want to hear from us. If you prefer not to receive customer focused marketing event information from us, please let us know by clicking on the "unsubscribe link"/"update preferences" at the bottom of any of our communications, or by sending us an email.

 

Review of Privacy Policy

 

The Privacy Policy may be reviewed and revised from time to time to take account of new laws and changes to our operations and practices. Easton reserves the right to modify or amend the Privacy Policy at any time. We may notify you about changes to the Privacy Policy by publishing an updated version on our website.

 

Enquiries and making a privacy complaint

 

If you have any questions or complaints about privacy-related issues please contact our office:

 

Easton Investments Limited

Level 2, 115 Pitt Street, Sydney NSW 2000

Ph: +61 2 9221 6666

Email: info@eastoninvestments.com.au

 

Date of publication – November 2014