Privacy

AUSTRALIA
NEW ZEALAND

NEO POLYMERS INTERNATIONAL PTY LTD PRIVACY POLICY STATEMENT

This Privacy Policy sets out the policy of NEO Polymers International Pty Ltd ABN 92 069 883 825 (‘we’ or ‘us’ or ‘NEO’ or ‘Polymers’) with respect to the way we obtain, use and disclose information about you, including through our website at www.polymers.com.au , in compliance with the Australian Privacy Principles (‘APPs') contained in Privacy Act 1988 (Cth) (‘the Act’)

We understand and appreciate that you are concerned about privacy, particularly in relation to the use and disclosure of Personal Information. We are committed to providing a high level of privacy in relation to all Personal Information that is collected by us.

This Privacy Policy covers Personal Information collected, used and disclosed by us about you, if you are (or have enquired about becoming) one of the following:

  • a customer;
  • a supplier engaged by us or a partner collaborating with us;
  • an independent contractor or an employment applicant; and
  • an employee, except where the use or disclosure is directly related to the relationship between us as employer and you as the employee and relates to an "employee record" about you as a present or past employee.

What is Personal Information?

“Personal Information” is information or an opinion about you as an identified individual or an individual who is reasonably identifiable, whether or not the information or opinion is true and whether or not it is recorded in a material form.

“Sensitive Information” is information about an individual’s health (including predictive genetic information), racial or ethnic origin, political opinions, membership of a political association, professional or trade association or trade union, religious beliefs or affiliations, philosophical beliefs, sexual orientation or practices, criminal record, biometric information that is to be used for certain purposes and biometric templates.

What Personal Information do we collect from you?

The types of Personal Information collected by us may differ, depending on whether you are, or would like to become, a customer, supplier, employee or independent contractor.

Generally, the Personal Information collected by us includes your name, address, telephone number and email address.

From our customers we also require company details including ABN and/or ACN. Where you seek to purchase goods or services on credit, we may collect credit information from you. How we handle your credit information is regulated by the Privacy Act and the Privacy (Credit Reporting) Code (CR Code) and is the subject of our Credit Reporting Information Policy and Statement of Notifiable Matters. Our Credit Reporting Information Policy and Statement of Notifiable Matters can be obtained at www.polymers.com.au and should be read in conjunction with this Privacy Policy

From our employees and/or prospective employees, in addition to your name, address, phone number, and email address, we collect several types of information, including, but not limited to, photos, employment status, gender, bank account details, emergency contact details, qualifications and certificates, previous employment details, medical and health information, leave summaries, wages and salary information, date of birth, superannuation information, tax file numbers, and where relevant visa and immigration information and information relating to performance and conduct. We will collect information in relation to any education loans, such as HECS or HELP debts and any child support orders. This information is relevant for payroll purposes.

We will also ask for a copy of your driver’s licence, to verify your identity, that you are licenced and your points status. This is relevant where you may drive a company vehicle. We may also ask for a copy of your passport to verify your personal information and citizenship or residency status.

As part of your employment, you may be required to undertake training modules including through our online learning campus and through LinkedIn Learning.

If you provide referees, we may contact them and conduct a background check or reference check. It is important that you obtain your referees’ consent for us to contact them. As a prospective employee, all of your personal information may be viewed by any of our HR recruiters who may be external contractors.

We do not otherwise collect Sensitive Information.

In some circumstances, you may deal with us anonymously or using a pseudonym. However, in most circumstances it is impracticable to do so because if you do not provide us with the Personal Information that we require or if you provide it in a way that does not identify you, we are unlikely to be able to provide the goods and services requested by you.

How do we collect your Personal Information?

We collect Personal Information in a number of ways, including:

  • from you when you make a telephone or online enquiry, complete a credit application and/or purchase our goods and services;
  • from you when you provide us with information, for example, via our website, feedback forms or when you subscribe to our newsletter or agree to receive electronic direct mail or text messages from us;
  • by visiting or subscribing to any website or social media site established by us, including but not limited to Instagram, YouTube and LinkedIn ("Social Media Sites")
  • from third parties such as credit reporting agencies;
  • from publicly available sources of information
  • through analysis of the Social Media Sites conducted by us or by third parties on our behalf; and
  • our own records.

When you look at our website, we may use tracking technologies such as cookies to make a record of your visit by logging your internet protocol address, device name, operating system version, the date and time of your visit to our site, the pages that you have accessed and the type of browser you were using. We use this information for statistical purposes and for the purposes of marketing and advertising to you. This type of statistical information does not identify you. You have the option to either accept or refuse cookies and to know when a cookie is being sent to your device. If you do not wish to receive any cookies you may set your browser to refuse them. However, this may result in you being unable to use our website.

Primary purpose for which we use and disclose your Personal Information

The primary purpose for which your Personal Information will be used and disclosed is to enable us to provide you with the goods and services requested by you.

This primary purpose generally includes:

  • conducting appropriate credit checks;
  • supplying our products and services to you;
  • providing quality assurance for our products and services;
  • responding to your enquiries and feedback regarding our business, our products and services;
  • monitoring the performance of our business, our contractors and employees and our goods and services including by requesting that you participate in user satisfaction surveys;
  • marketing including email marketing and text messaging, promotional activities relating to our goods and services;
  • enforcing the terms and conditions of our engagement with you;
  • for prospective employees, for recruitment purposes;
  • for employees, for purposes directly related to your employment or the employment relationship;
  • for the management of our database; and
  • ensuring compliance with statutory obligations.

We use and disclose information we hold about you as an employee of or incidental to our role as your employer and in accordance with applicable laws. If you are a prospective employee, we use and disclose your personal information for recruitment purposes, which includes disclosure to parties involved in hiring for that position. It may also be shared with other managers who may be hiring, if you are potentially suitable for other positions.

Direct Marketing

From time to time, we may communicate with you directly to promote our products or services. On each communication, we will advise how you may unsubscribe or opt out of receiving such communications. You may, at any time, request not to receive direct marketing communications from us and we will comply with that request.

Disclosure of your Personal Information via Social Media Sites

By engaging in any Social Media Activity on our Social Media Sites, you agree to and are subject to the terms and conditions of such Social Media Sites. Any Personal Information shared by you on Social Media Sites is generally disclosed in accordance with the terms and conditions and privacy policies of such Social Media Sites.

Generally, photos and other material shared on Social Media Sites will be able to be viewed by the general public. Such material may be shared by others repeatedly and will be visible by anyone visiting the locations to which the material has been shared. You may be able to remove the material that you have shared from the location at which you shared it. However, any material that has been re-shared will be out of our control and neither you nor we will be able to remove it from any subsequently shared location. We are not responsible for any material that has been shared by you.

We reserve the right to remove any photos, comments or other material that is in any way inappropriate or offensive (in our opinion) from our Social Media Sites.

Consent to use and disclosure for secondary purposes

In addition, you consent to our collection, use and disclosure of your Personal Information in the following circumstances:

  • to third party consultants who may from time to time develop, upgrade or manage all or part of our database, computer systems, internet site;
  • to third parties where we outsource any of our functions, including but not limited to development, production and/or printing of advertising and marketing material and campaigns, including where such material contains photos or video of individuals; and
  • of or incidental to a sale of all or part of our business to prospective purchasers and their legal and accounting representatives; and
  • as required by law.

Where your Personal Information is disclosed to a third party by us for these types of purposes, we take reasonable steps to ensure the information is not used for any purpose other than to perform the tasks assigned to them by us.

Cross Border Disclosure

Our related entity is located overseas in New Zealand. Customers’ Personal Information is stored in our database which may be accessed by employees in New Zealand.

We use programs, software, online tools, or Social Media Sites that may be based in and/or housed overseas. Our use of such products may involve disclosure of your Personal Information to such organisations overseas. In using such products, we will take all reasonable steps to ensure all privacy settings are set to the highest possible level of confidentiality and privacy. However, use and disclosure of your Personal Information by such overseas organisations is generally in accordance with the terms and conditions and privacy policies of such organisations. See the table below showing the online tools used by us which may involve an overseas disclosure.

Product/website Country of disclosure Link to Privacy Policy
Microsoft Sharepoint USA and others https://privacy.microsoft.com/en-ca/privacystatement
Microsoft Office 365 USA and others https://privacy.microsoft.com/en-ca/privacystatement
SAP Business One Germany and others https://www.sap.com/australia/about/legal/privacy.html
Google Drive USA and others https://policies.google.com/privacy

If you consent to disclosure of your Personal Information as described above, we are not required to take reasonable steps to ensure that such organisations do not breach the APPs in relation to the disclosed information, we will not be liable under the Privacy Act and you will not be able to seek redress under the Privacy Act. The overseas organisation may not be subject to any privacy obligations in their own country that are similar to the APPs, you may not be able to seek redress in the overseas jurisdiction and the overseas recipient could be subject to foreign laws that compel disclosure to third parties, such as overseas authorities. Having been informed of the possibility that such disclosure may occur, you consent to that disclosure by undertaking the type of activities specified above which indicate your consent.

Security

We are committed to ensuring the security of your Personal Information and we will take all reasonable steps to protect it from misuse, interference, loss, unauthorised access, modification or disclosure, including:

  • Company files are stored with Microsoft where data is encrypted in transit and at rest
  • User access to Microsoft is secured by multifactor authentication and conditional access policies
  • User access to Microsoft data is tracked and monitored
  • Microsoft solutions are utilised for email and file protection against malware, phishing attacks, and spam
  • All Microsoft data is backed up to a third party cloud, with data encrypted in transit and at rest
  • All PCs and servers are protected against malware.
  • On-premises network is protected by firewall.
  • Staff undergo cyber awareness training and phishing testing

Our security measures are continuously enhanced in keeping with new technological developments.

We will take all reasonable steps to ensure your Personal Information is accurate and kept up-to-date and complete and is relevant for the purposes for which it may be used pursuant to this Privacy Policy.

Please note that our website does not provide systems for secure transmission of Personal Information across the internet, except where otherwise indicated. When emailing or providing Personal Information to us via our website, please be aware that there are risks involved in transmitting Personal Information via the internet.

Our website may contain links to other internet sites. We have no control over the privacy practices employed at other websites and we accept no responsibility for the collection, use and disclosure of your Personal Information by other internet sites. We strongly advise you to review the privacy policies of such websites. We have no control over and assume no responsibility for the content, polices or practices or any third-party sites or services.

We cannot provide a guarantee with respect to the security of your Personal Information and we will not be liable for any breach of security or unintended loss or disclosure of information due to the website being linked to the internet.

You must ensure your username and password applicable to any online services provided by us is kept secret. We cannot be held liable where you have not kept your username and password strictly confidential.

How to check or change your details

If you wish to view the Personal Information we hold about you, please send your request to our Privacy Officer by email or mail using the contact details at the end of this Privacy Policy. A fee may apply for such access. If we deny your request for access, we will let you know why.

If you wish to amend the Personal Information because it is inaccurate, out of date, incomplete, irrelevant or misleading, or if you wish your Personal Information to be deleted, please contact our Privacy Officer. If we refuse to comply with your request, we will let you know why.

Changes to our Privacy Policy

From time to time, we may amend or update this Privacy Policy, especially with future changes to the privacy laws in Australia, If and or when this occurs, we will post the new version of the Privacy Policy on our website. We encourage you to periodically review this Privacy Policy so that you remain informed as to how we are protecting your Personal Information.

Complaints

If you believe that we have not complied with our obligations under the Act, or have a complaint about the use or disclosure of your Personal Information by us, please contact our Privacy Officer. We will discuss your concerns with you and take action as necessary to address such concerns which may include contacting us to take the matter further.

We will endeavour to resolve your complaint as soon as possible. However, the length of time will depend on the nature and complexity of the issues you have raised.

You will receive an acknowledgement of receipt of the complaint from us within ten business days. We will give you an estimate of how long it may take us to deal with the matter but we will endeavour to finalise the matter within 30 days.

If we decide that your complaint is justified, we will then decide what action we should take in response. We will always try to match our response to the nature of your complaint and your desired outcome, but this may not always be possible.

Some of the things that we may decide to do include:

  • take steps to rectify the problem or issue you have raised;
  • provide you with additional information or advice so that you can understand what happened and how we have dealt with it;
  • take steps to change our policies or procedures if your complaint identifies a problem in the way we are doing things.

It will not always be possible to resolve a complaint to everyone's satisfaction. In that case, you might want to escalate the matter to the Privacy Commissioner via an online privacy complaint form which can be found at: https://www.oaic.gov.au/privacy/privacy-complaints/lodge-a-privacy-complaint-with-us/. We welcome your questions and comments regarding this Privacy Policy.

Contact Details

Privacy Officer

NEO Polymers International Pty Ltd
Phone: +61 (3) 9587 7155
Email: finance@polymers.com.au

In order to process the Credit Application, Neo Polymers Limited (NEO) collects personal information about certain individuals (being a guarantor, trade references and key persons) (Personal Information). The Personal Information includes details such as names, addresses, phone numbers, driver’s licence numbers and birth dates, as well as credit card and bank account details, e-mail addresses, credit reporting information and credit information. There may be occasions when we need to source Personal Information about individuals from a third party. For example, from a credit reporting body, our business alliance partners, and government agencies.

The credit Applicant, each Guarantor and each of the persons named in the Credit Application (Key Persons) authorises NEO to:

  1. obtain credit reporting information from a credit reporting body that contains Personal Information about the Applicant, each Guarantor and each Key Person;
  2. obtain a report from a credit reporting body and other information pertaining to the Applicant’s,

each Guarantor’s and each Key Person’s commercial credit activities; and

  1. give to and obtain from any credit provider named in the Credit Application, or in any report issued by a credit reporting body, information about the Applicant’s, each Guarantor’s and each Key Person’s credit arrangements, including any information about their credit worthiness, credit standing, credit history or credit

USE OF PERSONAL INFORMATION

All Personal Information is treated confidentially and is only used for the purposes of assessing any credit application, establishing and maintaining an account for purpose of providing services and goods to the Applicant, and if required, in the collection of any debts, assisting the Applicant to avoid defaulting on its credit obligations, notifying other credit providers of a default by the Applicant (if permitted by law), and assessing the Applicant’s or Guarantor’s credit worthiness. If this information is not provided, then NEO may not be able to establish or maintain a trading relationship with the Applicant. The Applicant, the Guarantor and each Key Person acknowledges that NEO will not use Personal Information other than for the purposes of:

  • assessing any credit application made to NEO by the Applicant and the Guarantor;
  • assisting the Applicant to avoid defaulting on its credit obligations;
  • for NEO internal management directly related to the provision or management of commercial credit, including establishing and maintaining an account for the Applicant and managing that account and our relationship with the Applicant;
  • managing the delivery of products or services;
  • sending the Applicant communications with information about new goods or services, or information about projects being undertaken;
  • providing information to debt collection agencies for the purpose of recovering debts;
  • assessing credit defaults reported by any credit reporting body or a debt collection agency;
  • reporting to any credit reporting body or a debt collection agency of any credit defaults;
  • preventing or investigating any fraud or crime (or a suspected fraud or crime);
  • as required by law to do so; and
  • doing something that one would reasonably expect us to do using the

We will not sell or disclose Personal Information to any individual or entity outside NEO, unless described above, required by law to do so, or where the Applicant, Guarantor or Key Person (as relevant) has consented for the information to be disclosed.

SECURITY OF PERSONAL INFORMATION

NEO will take reasonable steps in an effort to protect the security of Personal Information. This includes taking steps to ensure the information can only be accessed by authorised persons and protecting the information from misuse, interference and unauthorised modification.

UPDATING PERSONAL INFORMATION

NEO will take reasonable steps to ensure that Personal Information is accurate, complete and up-to- date at the time of collecting, using or disclosing the information. The Applicant, Guarantor or Key Persons should contact NEO if it believes that the Personal Information we hold is inaccurate, incomplete or not up- to-date, and we will promptly update the information. If we disagree with such request, the Applicant, Guarantor or Key Person may request that a statement be attached to their Personal Information.

ACCESS TO YOUR PERSONAL INFORMATION

Please contact us. We will try to comply with such request promptly. In some limited circumstances, we may not be able to disclose what Personal Information we hold about the individual who submitted the request. This may include where it may threaten the privacy of other individuals, where the information relates to anticipated legal proceedings, where disclosure would reveal our commercially sensitive decision making process or we are prevented by law from disclosing the information. We will destroy Personal Information if it is no longer needed for the purposes it was collected, or to meet any legal requirement.

COMPLAINTS

If the Applicant, Guarantor or Key Person believes that we have contravened our obligations under the Privacy Act 1993 or the Credit Reporting Privacy Code 1994, please contact us. We will endeavour to resolve any complaint within 30 business days. If the complainant is not satisfied with the outcome, it may lodge a complaint with the Office of the Privacy Commissioner, whose website is: https://www.privacy.org.nz

NOTICE

To the extent permitted by the Privacy Act 1993 NEO may disclose Personal Information to credit reporting bodies for purposes such as those described above, including notifying them of an inquiry being made by NEO for the purpose of assessing whether or not to give commercial credit, a failure to meet payment obligations and if the Applicant or the undersigned commits a serious credit infringement. The credit reporting bodies with whom the NEO may deal are:

Veda Advantage Dun and Bradstreet Centrix
Public Consumer Enquiries Attn: Public Access Centre Attn: Credit Report
PO Box 912012, Victoria St West Auckland 1142 Level 3, 1 Queen Street Auckland 1010 PO Box 62-512 Greenlane Auckland
0800 692 733 (0800 MYCREDITINFO) 0800 362 222 0800 236 874
publicaccess.nz@veda.co.nz pacnz@dnb.co.nz admin@centrix.co.nz
www.mycreditfile.co.nz www.dnb.co.nz www.centrix.co.nz

If an individual fails to meet their payment obligations in relation to consumer credit or commits a serious credit infringement, NEO may be entitled to disclose this to the credit reporting body. An individual has a right to:

  1. access any credit-related Personal Information about the individual held by NEO;
  2. request NEO to correct credit information or credit eligibility information and to make a complaint to NEO;
  3. request credit reporting bodies not to use credit reporting information for the purposes of pre- screening of direct marketing by a credit provider; and
  4. request the credit reporting body not to use or disclose credit reporting information about the individual, if the individual believes on reasonable grounds that the individual has been, or is likely to be, a victim of

To obtain a copy of a credit reporting body’s policy about their management of credit information and credit

reporting information, or otherwise exercise available rights, please contact them directly.

HOW TO CONTACT US:

If the Applicant, Guarantor or a Key Person has any questions or concerns, or wishes to obtain a copy of the NEO privacy policy or credit reporting policy, please contact our Privacy Officer on:

FINANCE MANAGER

17-19 Endeavour Way

Braeside VIC 3195 Australia

+61 (3) 9580 8733

finance@neopolymers.com.au

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