We are subject to the operation of the Personal Information Protection and Electronic Documents Act (Canada) (“PIPEDA”), the Act respecting the protection of personal information in the private sector (Québec), Privacy Act 1988 (Cth) and the Australian Privacy Principles, as applicable from time to time (together, “Privacy Laws”). This policy explains how we handle personal information relating to individuals so as to ensure we meet our obligations under the Privacy Laws.
Privacy Laws regulate the collection, use and disclosure of “personal information”, which includes information or an opinion about an identified individual or an individual who is identifiable, whatever the medium or format.
We collect personal information by various means including (but not limited to) when you invest in us as a shareholder, when you contact us by any means, when you view, navigate and/or use any of our Websites, such as by subscribing to our newsletter and by contacting us through our general contact forms or our service offer submission forms.This information may include (but is not limited to) your name, e-mail and mailing addresses, contact numbers, company or employer, date of birth, and any content of your communications when you exchange with us by any means.
We may also collect information about how you interact with our Websites, including (but not limited to) your web browser and version, device type, connection type, IP address, performance metrics and usage information, in order to help us to develop and improve our Websites.
We take steps designed to ensure that only those employees who need access to your personal information to fulfil their employment duties will have access to it. We use your personal information for the purpose for which it has been provided, any other purpose you have consented to and any other purpose permitted under the Privacy Laws or any other applicable laws. The primary purpose for which we collect, use and disclose personal information is to manage our operations and promote our business. This may include using your personal information for any of the following purposes:
We may disclose your personal information to third parties for the purposes for which we may use your information as described above. This may include disclosing information to:
These persons or organisations may be located outside of Australia, including to our related bodies and affiliates located in Canada and third party organisations located overseas.
We will only disclose your personal information for other purposes if you consent, where we are required or authorised by law to do so, where the disclosure is authorised under the Privacy Laws, or where we believe you would reasonably expect us to disclose your personal information for a purpose which is related to the primary purpose of collection including to respond to subpoenas, judicial processes or legitimate requests by law enforcement officials or government agencies or departments.
In the event of a change of ownership, sale, merger, liquidation, reorganization or acquisition of any member of our Group, in whole or in part, your personal information may be transferred as part of the transaction.
For Australian citizens and residents only:
At times, we need to disclose personal information to entities located overseas. If we do so, we will take reasonable steps to ensure that the overseas recipient does not breach the Privacy Laws in its handling of the personal information. However, it is not practicable for us to specify in advance every location where your personal information may be sent. It is possible that information will be transferred to a jurisdiction where you will not be able to seek redress under the Privacy Laws and that does not have an equivalent level of data protection as Australia. We will not be accountable for how these overseas recipients handle your personal information. By providing your personal information to us, you consent to our disclosure of your personal information to these parties. If you have any concerns regarding the transfer of your personal information overseas, please contact us using the details provided below.
In addition to this, we also use Google Analytics as part of analytics cookies on our Websites. Google Analytics is Google’s analytical tool that helps us to understand how users engage with our Websites. The information we collect through Google Analytics is page views, time spent through the Network Services, number of visitors, the source where they come from, the pages they have visited, session and Websites usage, the whole in an anonymous form. It uses a set of cookies to collect such information and reports site usage statistics without allowing us to identify individual visitors.
Your personal information is stored by the Champion Group in Montreal, Quebec, Canada. However, it may also be stored and processed in any country where we have facilities or in which we engage service providers. By using our Websites, you consent to the transfer of information to countries outside your country of residence which may have different data protection rules than in your country. (For Australian residents and citizens, please refer to 3 above for information about how your information may be sent outside of Australia.)
We take reasonable steps to secure any personal information which we hold about you and to keep this information accurate and up to date. Personal information is stored electronically or in hard copy and various physical, administrative, technical and technological security measures are in place to protect this information from misuse, interference and loss.
However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Users should be aware that there are inherent risks transmitting information across the Internet.
We will take such steps that are reasonable in the circumstances (if any) to destroy or de-identify personal information when it is no longer required for the purpose(s) for which it was provided. However, we will maintain your personal information for as long as a business need exists, or as required by applicable laws, regulations, or government orders.
We will take such steps as are reasonable to ensure that the personal information which we collect remains accurate, up to date and complete.
We will provide you with access to your personal information held by us unless we are permitted under Privacy Laws (as applicable) to refuse to provide you with such access, such as where the request relates to an existing or anticipated legal proceeding or if your request is vexatious. Please contact us via the details below if you:
Contact Details: firstname.lastname@example.org
There is no charge for requesting access to your personal information, but we may require you to meet our reasonable costs in actually providing you with access.
If you consider that the information which we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, we will take reasonable steps, consistent with our obligations under the Privacy Laws, to correct that information if you so request. We may need to verify the accuracy of new information you provide us before making corrections to your personal information held by us.
We will respond to all requests for access and/or correction within a reasonable time within the timeframe required under applicable Privacy Laws.
If you are located in Canada, you can contact the person who is accountable for compliance with PIPEDA, through the following address: email@example.com.
Being located in Canada, if you are not satisfied with our response, you can also contact the Office of the Privacy Commissioner of Canada’s Information Center:
9:00 am to 4:00 pm EST
Office of the Privacy Commissioner
30 Victoria Street
If you are located anywhere else and would like further information about how we manage your personal information, have any queries or feedback relating to this policy, or wish to lodge a complaint, please contact our Company Secretary through details listed above.
Our Company Secretary is responsible for coordinating the investigation of any complaints and resolving privacy-related issues. The Company Secretary will manage any complaints received in a timely manner and provide you with a response to your complaint.
If you are located in Australia and are not satisfied with our response, you may take your complaint to the Office of the Australian Information Commissioner, contactable by telephone on 1300 363 992, via the OAIC website at www.oaic.gov.au, or by email at firstname.lastname@example.org.