Global Privacy Policy

This Policy applies to Mincom Limited and to all Mincom related organizations world-wide ("Mincom").

This Policy outlines the obligations which Mincom has in managing the personal information we hold about our clients, potential clients, contractors and others.

Mincom is bound by the National Privacy Principles ('NPPs') contained in the Privacy Act 1988 (Cth) ('Privacy Act') of Australia. Mincom also seeks to adhere to local privacy principles in the countries where Mincom operates.

In summary, 'personal information' is information or an opinion relating to an individual which can be used to identify that individual.

Why does Mincom collect personal information?

Mincom collects personal information in order to conduct our business, to provide and market our products and services and to meet our legal obligations.

About whom does Mincom collect personal information?

The type of information we may collect and hold includes (but is not limited to) personal information about:

clients, business associates and potential clients and their employees
suppliers and their employees
prospective employees, employees and contractors; and
other people who come into contact with a member of the Mincom Group.

In this Policy the Mincom Group includes Mincom Limited ACN 010 087 608, and the group of companies controlled by Mincom Limited irrespective of whether the control is direct or indirect (including through subsidiaries of Mincom Limited) and whether it is because of control of shares, votes at general meetings of shareholders, votes at meetings of directors or the appointment or removal of directors or otherwise.

What kinds of personal information do we collect?

In general, the type of personal information Mincom collects and holds includes (but is not limited to): names, addresses, contact details, occupations and other information which assist us in conducting our business, providing and marketing our products and services and meeting our legal obligations.

In most cases, if personal information we request is not provided, we may not be able to supply the relevant product or service.

How is personal information collected by Mincom?

Mincom collects personal information by a number of means, including:

Personal Information you provide: Mincom will generally collect personal information by way of forms filled out by people, face-to-face meetings, interviews, business cards, telephone conversations and from third parties.
Personal Information provided by other people: In some circumstances Mincom may be provided with personal information about an individual from a third party, for example a report provided by a medical professional or a reference from another person.
Web site Collection: Mincom collects personal information through its web site www.mincom.com. We also analyze traffic at that web site, which may involve the use of cookies. Mincom has a specific Privacy Statement that governs the collection and use of information via that web site. You can read that statement (which compliments this policy) at http://www.mincom.com/legal/privacy.aspx.

How do we use and disclose your personal information?

Mincom may use and disclose your personal information for the primary purpose for which it is collected, for reasonably expected secondary purposes which are related to the primary purpose and in other circumstances authorized by the Privacy Act.

In general, we use and disclose your personal information for the following purposes:

to communicate with you;
to purchase from you;
to conduct our business;
to provide and market our products and services;
to comply with our legal obligations; and
to help us manage and enhance our products and services.

To whom might we disclose your personal information?

We may disclose your personal information to:

other members of the Mincom Group and our distributors and agents;
other companies or individuals who assist us in providing products and services or who perform functions on our behalf (for example, specialist consultants);
regulatory authorities; and
anyone else to whom you authorize us to disclose it.

We also collect personal information from these organizations and individuals, and deal with that information in accordance with this Policy.

Sending information overseas:

We will not send your personal information to recipients outside of your country of residence without:

obtaining your consent (in some cases this consent will be implied); or
otherwise complying with the NPPs.

Mincom may disclose your personal information to other members of the Mincom Group our distributors and agents. We take reasonable steps to ensure that the recipients respect the confidentiality of this information by abiding by the NPPs or equivalent privacy laws.

Sensitive information

We may collect personal information that is 'sensitive information'. Sensitive information includes: information relating to a person's racial or ethnic origin, political opinions, religion, trade union or other professional or trade association membership, sexual preferences and criminal record, that is also personal information; and health information about an individual.

While Mincom does not foresee a need to use or disclose Sensitive Information, it may be collected during Mincom's business activities. Sensitive information will only be used and disclosed for the purpose for which it was provided or a directly related secondary purpose, unless you agree otherwise, or where certain other limited circumstances apply (eg, where required by law).

Management of personal information

The NPPs require us to take reasonable steps to protect the security of personal information. Mincom personnel are required to respect the confidentiality of personal information and the privacy of individuals.

Mincom takes reasonable steps to protect any personal information held by Mincom from misuse and loss, from unauthorized access, modification or disclosure. This is managed by use of physical security and restricted access to electronic records.

Where Mincom no longer requires your personal information for a permitted purpose under the NPPs, we will take reasonable steps to destroy it.

Keeping personal information accurate and up-to-date

Mincom endeavors to ensure that the personal information it holds is accurate, complete and up-to-date. Mincom encourages you to contact Mincom's Privacy Officer in order to update any personal information we hold about you. The contact details are set out below.

You have the ability to gain access to your personal information

Subject to the exceptions set out in the Privacy Act, you may gain access to the personal information held by Mincom about you by contacting Mincom's Privacy Officer.

We will require you to verify your identity and to specify what information you require. A fee may be charged for providing access. We will advise you of the likely cost in advance.

Updates to this Policy

This Privacy Policy will be reviewed from time to time to take account of new laws and technology, changes to our operations and practices and the changing business environment. The most current version of this Policy is located at http://www.mincom.com and can be obtained by contacting Mincom's Privacy Officer.

Enquiries

If you have any questions about privacy-related issues please contact the Mincom Privacy Officer by email at info@mincom.com.