Privacy Policy

Our commitment

This document sets out the policy of Gelion Technologies Pty Ltd ACN 604 926 098 and its related entities (Gelion, we, us, or our), relating to the protection of the privacy of ‘personal information’ as that term is defined in the Privacy Act 1988 (Cth) (Privacy Act). In respect of the protection of personal data of individuals under either the United Kingdom or European Union General Data Protection Regulation (GDPR), Gelion has a separate Privacy Policy available.

Gelion is committed to complying with the requirements under the Privacy Act and GDPR in respect of the collection, use, storage and disclosure of personal information.

‘Personal Information’ as defined by the Privacy Act, means any information by which an individual could be identified. We only collect personal information that is relevant and necessary for our business operations which might include, but is not limited to service providers, customers and shareholders.

Under the GDPR, individuals over 16 years can consent to the processing of personal data, but anyone younger needs the consent of a parent or guardian.

As part of our ongoing commitment, we acknowledge the rights of individuals under the GDPR to: be ‘forgotten’; access their data; request that their data be erased; request for the processing of their data to be restricted; and data portability.

Collection of Information

Most of the personal information we hold is provided directly by our providers, customers and stakeholders at the commencement of our commercial relationship. When the information has been provided directly to us by such parties, we rely upon the accuracy of the information provided by those parties, where reasonable to do so.

Generally, we may collect your personal information in the course of operating our business, providing you with goods or services, where you contact us or as may otherwise be set out in this privacy policy.

What personal data we collect and why we collect it.

The types of personal information we may collect about an individual will depend upon the nature of our interaction with them. Set out below are some example of the types of individuals we may collect personal information from, as well as the kinds of personal information we may collect from such individuals.

Comments

When visitors leave comments on the site we collect the data shown in the comments form (for example, the visitor’s name, email address and any other details provided in the relevant form), and also the visitor’s IP address and browser user agent string to help spam detection.

An anonymized string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here: https://automattic.com/privacy/. After approval of your comment, your profile picture is visible to the public in the context of your comment.

Investors

We also collect information about our investors/shareholders and potential investors/shareholders, as necessary to provide information about our company, manage and respond to their requests including their applications for shares, and to carry out appropriate administration activities in the course of our business, as further detailed below in this privacy policy. This information may include but is not limited to names, age and/or date of birth, contact details including telephone numbers (landline and/or mobile) and other details we require in order to perform the foregoing activities.

Our suppliers and contractors

We may also collect business contact information about the staff of our suppliers and potential suppliers and their representatives in connection with them providing goods and services to us. This information may include but is not limited to names, employment title, contact details including telephone numbers (landline and/or mobile), email address and other business related details necessary to conduct our relationship with such individuals and their principals (for example, Australian Business Number (ABN)).

Media

If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.

Contact forms

We receive and store any information you enter on our website. Such information may include but is not limited to your name, age and/or date of birth, contact details including telephone numbers (landline and/or mobile), email address and other details you enter on our website.

Cookies

If you leave a comment on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year before automatic deletion.

If you have an account and you log in to this site, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.

When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for one year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.

If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after one day.

You can configure your browser to accept all cookies, reject all cookies, or notify you when a cookie is sent. Each browser is different, so check the “Help” menu of your browser to learn how to change your cookie preferences.

If you disable the use of cookies on your web browser or remove or reject specific cookies from our website or linked sites then you may not be able to gain access to all of the content and facilities in those websites.

Use of Information

We will use personal information to provide a particular product or service and to contact shareholders about matters pertaining to Gelion. We may use personal information for purposes related or ancillary to the main reason we collect it, such as accounting, administration, reporting and compliance.

For example, we may collect, hold and use personal information in order to:

(a) identify and communicate with you

(b) enable us to provide you with requested information, products or services

(d) help us to manage and enhance goods and services we procure from our suppliers and subcontractors

(e) help us manage and respond to a general or specific shareholder enquiry

(f) process share applications and service shareholders’ needs

(g) provide facilities and services a shareholder may request

(h) carry out appropriate administration in relation to our shareholders and our share registry, including to submit listing applications to, or respond to enquiries from, corporate regulators

(i) personalise and customise your experiences on our website

(j) provide you with information that we believe may be of interest to you or that you may be interested in receiving regarding our business

(k) analyse our shareholder base and for product development and planning

(l) protect you and us from fraud

(m) provide for the safety and security of workers and onsite visitors

(n) help us manage our business operations

(o) manage business support purposes including maintenance, backup and audit

(p) process any job application submitted by you

(q) respond to any queries or complaints you may have

(r) investigate, review, mitigate risks associated with, and inform you of, a data or other security breach involving your personal information, or

(s) comply with our statutory and legal obligations.

We do not provide personal information to third parties for their own marketing purposes, but we may provide personal information to third parties as necessary for their provision of services to us (for example, for the dissemination of our company newsletters and shareholder

updates which are sent on our behalf from a third party under a confidentiality agreement). We take all reasonable steps to ensure that personal information is only collected and used for the purposes for which it is obtained.

We use a third party service provider to track and report on website analytics to collect and store data about traffic on our website to gain information on, for example, the most visited web pages or the most common searches conducted. This information is then used to determine what information, services and benefits are likely to be of most interest. This information is not considered personal information because there are no unique identifiers collected, stored or used in the process.

We take reasonable steps to ensure that all personal information is accurate, complete and up to date and we regularly request our shareholders to assist us in updating our records in relation to their personal information whenever possible.

When we disclose your personal information to third parties

Gelion may disclose, or provide access to, your personal information to third parties in connection with the purposes described in this privacy policy. Depending on the circumstances and the nature of your engagement with us, we may disclose your personal information to our related entities, to third parties that provide products and services to us or through us, or to other third parties (such as your referee(s) in connection with a job application you have submitted). In general these disclosures will be for the same purposes as our collection of the personal information, unless otherwise allowed or required by law.

These third parties may include the following, depending on your engagement with us:

(a) any of Gelion’s internal divisions, business units or departments

(b) your nominated representatives

(d) professional service providers and advisors who perform functions on our behalf, such as lawyers

(e) representatives, agents or contractors who are appointed by us in the ordinary operation of our business to assist us in providing goods or services or administering our business (such as for data storage or processing, printing, mailing, marketing, planning and product or service development)

(f) banks, lenders, valuers, insurers, brokers, auditors, business consultants and IT service providers, and

(g) Government, regulatory authorities, stock exchanges (such as the LSE) and other organisations as required or authorised by law.

As we continue to develop our business, we may buy, merge or partner with other companies or organisations, and in so doing, acquire customer personal information. In such transactions, personal information may be among the transferred assets. Similarly, in the event that some or all of our business or assets are sold or transferred to a third party, we may also disclose certain information including your personal information to a purchaser or potential purchaser in connection with the sale or potential sale of us, our business or any of our assets, including in insolvency.

Marketing

If you make an enquiry about becoming an investor or if you provide your personal information by signing up to our newsletter via our website, you consent to us using your personal information for sending you information, including promotional material, about us or our business, as well as information about our related entities and their businesses, now and in the future. You also consent to us sending you such information by means of direct mail, email, SMS and MMS messages.

If you do not, or no longer, want to receive marketing information from us, you can unsubscribe by either:

(a) clicking on the ‘unsubscribe’ or subscription preferences link in a direct marketing email that you have received from us, or

(b) contacting us using the contact details specified below in this privacy policy.

Overseas disclosures

Some of your personal information may be disclosed, transferred, stored, processed or used overseas by us, or by third party service providers. This may happen if:

(a) our offices or related entities are overseas

(b) we outsource certain activities overseas

(d) our computer systems including IT servers are located overseas.

By providing your personal information to us, you consent to the collection, use, storage, and processing of your personal information outside of Australia as set out in this privacy policy.

In particular, your personal information may be disclosed to our related entities in the United Kingdom, and to third parties in such other countries in which those parties or their, or our, computer systems may be located from time to time, where it may be used for the purposes described in this privacy policy. Where such parties are located overseas, you may have rights to enforce such parties’ compliance with applicable data protection laws, but you might not have recourse against those parties under the Australian Privacy Act in relation to how those parties treat your personal information.

Storage of Information

Gelion takes all reasonable steps to protect personal information from misuse and loss which includes the use of firewalls, encryption, anti-virus software and login and password protection. In addition, access is restricted to authorised personnel who have a need to access the information to perform their role. We will keep personal information for as long as it is reasonably necessary and will take steps to destroy or permanently de-identify personal information when no longer needed.

Embedded content from other websites

Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.

These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracing your interaction with the embedded content if you have an account and are logged in to that website.

Access and correction of your personal information

You are generally entitled to access personal information that we hold about you. If you request access to your personal information, in ordinary circumstances we will give you full access to your personal information. Depending on the nature of the request, we may charge for providing access to this information, however such charge will not be excessive. However, there may be some legal or administrative reasons to deny access. If we refuse your request to access your personal information, we will provide you with reasons for the refusal where we are required by law to give those reasons.

A request for access can be made by contacting our Privacy Officer in any of the ways specified below in this privacy policy.

We take all reasonable steps to ensure that any personal information we collect and use is accurate, complete and up-to-date. To assist us in this, you need to provide true, accurate, current and complete information about yourself as requested, and properly update the information provided to us to keep it true, accurate, current and complete.

Please contact us in any of the ways specified below in this privacy policy if you believe that the personal information is inaccurate, incomplete or out of date, and we will use all reasonable efforts to correct the information.

It would assist us to ensure we properly understand your request, and allow us to respond more promptly, if requests are made in writing and include as much detail as possible.

Complaints

If there is a complaint about the way Gelion has collected, stored or used personal information, a complaint should be made to the Privacy Officer who will endeavour to deal with the complaint and take any steps to resolve the complaint within two weeks of receiving the complaint. If the complaint cannot be resolved within that period we will write to the complainant setting out the status of the complaint, any further steps needed to be taken and an estimated length of time required to resolve the complaint. We will inform the complainant whether it is considered that any breach of the Privacy Act has occurred and, if so, the steps being taken to rectify the situation.

If, after giving Gelion a reasonable opportunity to resolve the complaint, there is no resolution, the matter can be progressed to the Office of the Australian Information Commissioner.

Complaints should be forwarded to:

The Privacy Officer

Gelion Technologies Pty Ltd

c/o Bedford CA, Level 16, 101 Miller Street

North Sydney NSW 2060 Australia

A written complaint must include a return address, and identify the conduct that is the basis for the complaint. There are no fees for lodging a complaint.

Updates to this Privacy Policy

We may, from time to time, review and update this privacy policy, including to take into account new laws, regulations, practices and technology. All personal information held by us will be governed by our most recent privacy policy posted on our website. Any changes to this privacy policy may be advised to you by updating this page on our website. We will aim to provide reasonable advance notice of such changes though this may not always be possible depending on the circumstances. We encourage you to check this page from time to time for any changes.

Contacting us

If you:

(a) have a query or concern about this privacy policy or our personal information handling processes

(b) wish to make a complaint in relation to a breach of your privacy

(d) would like to update or correct your personal information held by us, or

(e) would like to opt out of direct marketing,

please contact our Privacy Officer:

The Privacy Officer

Gelion Technologies Pty Ltd

c/o Bedford CA, Level 16, 101 Miller Street

North Sydney NSW 2060 Australia

Email: Privacy@gelion.com

For individuals based in the EU, the Data Protection Officer (DPO) can be contacted at:

The Data Protection Officer

Gelion Technologies Pty Ltd

c/o Bedford CA, Level 16, 101 Miller Street

North Sydney NSW 2026 Australia