1. Scope of this policy

1.1 In this Privacy Policy, ‘us’, ‘we’, or ‘our’ means Spectur Limited (ACN 140 151 579) and our related bodies corporate.
1.2 We are bound by the Australian Privacy Principles (APPs) under the Privacy Act 1988 (Cth) and the New Zealand Privacy Act 1993 and the NZ Information Privacy Principles (NZIPPs). This Privacy Policy has been drafted in order to comply with the APPs and NZIPPs.
1.3 This Privacy Policy sets out how we collect, use, store, and disclose your personal information. We use a number of key terms in this privacy policy including “collect”, “consent”, “personal information” and “sensitive information”. You will find the meanings of these terms in section 20 below.
1.4 By providing personal information to us, you consent to our collection, use, and disclosure of your personal information in accordance with this Privacy Policy and any other arrangements that apply between us.

2. Our business and activities

2.1 At the date of this policy, our business involves developing, manufacturing, and commercialising remote high-definition security systems which operate using solar power and transmit images using the 3G, 4G, and 5G mobile telephone network, and provision of associated services.
2.2 We will only collect and maintain a record of personal information if it is reasonably necessary to pursue at least one of our functions and activities in the course of operating our business.
2.3 Our functions and activities include, but are not limited to:
(a) operating and managing our business as outlined above, including:
(i) the sale or hiring of security cameras and related equipment; and
(ii) the provision of security monitoring and related services;
(b) the referral of customers (or potential customers) to third-party suppliers or service providers;
(c) human resource activities, including training and development and payroll;
(d) occupational health and safety activities;
(e) procurement and supply chain activities;
(f) corporate administration and investor relations, including security holder communications;
(g) marketing and business development; and
(h) public relations activities.

3. What personal information do we collect?

3.1 We may collect any of the following types of personal information:
For Customers
Financial information, including your bank account number for direct debit purposes, if the option is selected.
(a) name;
(b) gender;
(c) mailing or street address;
(d) email address;
(e) telephone number and facsimile number;
(f) your device ID, device type, geo-location information, computer and connection information, statistics on page views, traffic to and from the sites, ad data, IP address, and standard web log information;
(g) details of the goods and/or services we have provided to you or that you have enquired about, including any additional information necessary to deliver those goods and services and respond to your enquiries;
(h) any additional information relating to you that you provide to us through our website, through your use of our website or through other websites or accounts from which you permit us to collect information;
(i) information you provide to us through customer surveys; or
(j) any other personal information that may be required in order to facilitate your dealings with us or which may be reasonably necessary to pursue our functions and activities.

For Employees
Financial information, including your bank account number for salary payment purposes.
(a) age or date of birth;
(b) languages spoken;
(c) occupation;
(d) academic record and level of education;
(e) driver’s license details;
(f) previous employment and training information;
(g) financial details (e.g., credit card, tax details, superannuation information); and
(h) third-party contact information (e.g., carer, employer).

3.2 In the course of carrying out recruitment activities in respect of employees and contractors, we may collect a wide range of information, including information regarding an applicant’s educational qualifications, career history, interests, hobbies, and job interests and such other information as may be routinely included within a curriculum vitae.
3.3 From time to time, we collect sensitive information about individuals in order to provide our services. However, we generally only collect sensitive information if:
(a) the collection is reasonably necessary for one or more of our activities or functions; and
(b) we have the individual’s consent to the collection.
3.4 The APPs & NZIPPs list a number of circumstances that permit the collection of sensitive information about an individual without their consent. We only collect sensitive information without an individual’s consent if one or more of those circumstances applies.

4. How do we collect personal information about you?

4.1 We will only collect personal information by lawful and fair means and not in an unreasonably intrusive way.
4.2 We may collect this personal information either from you or from third parties. We may collect this information when you:
4.3 In order to provide our services, we may collect personal information from third parties, including government agencies and your family and friends.
4.4 We will only collect personal information from third parties if:
(a) we are required or authorised by or under an Australian law, or a court/tribunal order, to collect the information from someone other than the individual concerned;
(b) it is unreasonable or impracticable to collect the information directly from the individual concerned; or
(c) it is provided to us in the course of us providing at least one of our functions and activities.

5. Why do we collect, use and disclose personal information?

5.1 We will only collect and hold personal information if it is reasonably necessary to pursue at least one of our functions or activities or its collection and storage is required or authorised by or under an Australian law or a court/tribunal order.
5.2 When information is sensitive information we will only collect and store information with the consent of the individual concerned and when the information is reasonably necessary for us to carry out at least one of our functions or activities.
5.3 Alternatively, we may collect sensitive information when the APPs & NZIPPs otherwise permit such collection.
5.4 We may collect, hold, use and disclose your personal information for the following purposes (primary purpose):
(a) to enable you to access and use our website, goods, or services;
(b) to operate, protect, improve, and optimise our website, business and website users’ experience, such as to perform analytics, conduct research, and for advertising and marketing;
(c) to investigate and manage enquiries and complaints;
(d) to send you messages, reminders, notices, updates, alerts, and information requested by you;
(e) to send you marketing and promotional messages and other information that may be of interest to you, including information sent by, or on behalf of, our related organisations that we think you may find interesting;
(f) to comply with our legal obligations, resolve any disputes that we may have with any of our website users, and enforce our agreements with third parties; and
(g) to consider your employment application.

5.5 Generally, we will only use or disclose personal information for the purpose for which it was collected (the primary purpose), including the purposes set out above.
5.6 However, we may use or disclose personal information for secondary purposes if we receive your consent to do so, or without your consent, if you would reasonably expect us to use your information for the secondary purpose, or otherwise when the APPs & NZIPPs permit us to do so.
5.7 For example, the APPs & NZIPPs permit us to use and disclose personal information for a secondary purpose without an individual’s consent if the individual would reasonably expect us to use or disclose the information for a certain secondary purpose and the secondary purpose is:
(a) if the information is sensitive – directly related to the primary purpose; or
(b) if the information is not sensitive – related to the primary purpose; or
(c) the use or disclosure of the information is permitted or authorised by or under an Australian & New Zealand law or a court/tribunal order (for example where disclosure of your information will reduce or prevent a serious threat to life, health, or safety or where our disclosure is in response to any unlawful activity).

6. Notification of collection

6.1 At or before the time we collect personal information about an individual (or, if that is not practicable, as soon as practicable after), we will take such steps as are reasonable in the circumstances to notify the individual of the following information (Collection Information):
(a) our identity and contact details;
(b) that we have collected the personal information;
(c) if the collection of the personal information is required or authorised by or under an Australian law or a court/tribunal order – the fact that the collection is so required or authorised;
(d) the purpose for collecting the personal information;
(e) the main consequences (if any) for the individual if we do not collect all or some of the personal information;
(f) the organisations, or types of organisations, to which we usually disclose personal information of that kind;
(g) the fact that our privacy policy contains information about how the individual may access the personal information that we hold about them and how they may seek correction of such information;
(h) the fact that our privacy policy contains information about how individuals may complain about a breach of the APPs & NZIPPs and how we will deal with such a complaint; and
(i) whether we are likely to disclose the personal information to overseas recipients, and if so, the countries in which such recipients

are likely to be located (if practicable to do so).

6.2 Circumstances may arise where it would be reasonable for us not to provide the individual about whom the information relates with notice of all or some of the Collection Information.

7. Do we use your personal information for direct marketing?

7.1 We may, from time to time, use or disclose personal information for the purpose of direct marketing.
7.2 We may send you direct marketing communications and information about our services and products. This may take the form of emails, SMS, mail, or other forms of communication, in accordance with the Australian Spam Act 2003 (Cth) and the Do Not Call Register Act 2006 (Cth) and the New Zealand The Unsolicited Electronic Messages Act 2007.
7.3 We may use or disclose personal information (other than sensitive information) for direct marketing if:
(a) we collected the information from the individual concerned;
(b) the individual has consented to, or would reasonably expect us to, use or disclose the information for that purpose; and
(c) we provide the individual with a simple means by which they may easily request not to receive direct marketing communications from us, and they have not made such a request to us.
7.4 In this regard, you may opt-out of receiving marketing materials from us by contacting us using the details set out below or by using the opt-out facilities provided (e.g. an unsubscribe link).
7.5 If personal information is also sensitive information, we will not use or disclose the information for direct marketing without the consent of the individual concerned.

8. To whom do we disclose your personal information?

8.1 We may disclose personal information for the purposes described in this privacy policy to:
(a) our employees, officers, contractors, and related bodies corporate;
(b) third-party suppliers and service providers (including providers in connection with providing our products and services to you);
(c) professional advisers, dealers, and agents;
(d) payment system operators;
(e) our existing or potential agents, business partners, or partners;
(f) anyone to whom our assets or divisions (or any part of them) are transferred;
(g) a securities exchange or share registry for security holders;
(h) specific third parties authorised by you to receive information held by us; and/or
(i) other persons, including government agencies, regulatory bodies, and law enforcement agencies, or as required, authorised, or permitted by law.

9. Receipt of unsolicited personal information

9.1 If we receive personal information that we did not solicit, we will, within a reasonable period of receiving the information, determine whether we would have been permitted to collect the information pursuant to the APPs & NZIPPs.
9.2 If we determine that we have received personal information that we would not have been permitted to collect pursuant to the APPs & NZIPPs (and the information is not contained in a Commonwealth record), we will as soon as practicable and where it is lawful and reasonable to do so, destroy the information or ensure that it is de-identified.
9.3 If we determine that we would have been permitted to collect the personal information pursuant to the APPs & NZIPPs, we will ensure that the information is dealt with in a manner that complies with the APPs & NZIPPs.

10. Disclose to overseas recipients

10.1 From time to time, circumstances may arise where there may be a need for us to disclose personal information to an overseas recipient. This may occur in a range of circumstances. For example, where data is being stored and accessed by way of cloud computing or where we correspond with professional advisors located outside of Australia and New Zealand.
10.2 Before disclosing personal information to an overseas recipient, we will take such steps as are reasonable in the circumstances to ensure that the overseas recipient also complies with the APPs & NZIPPs in relation to that information, unless the APPs & NZIPPs do not require us to do so.
10.3 We will not be required to take the steps described in paragraph 10.2 above if:
(a) we reasonably believe that:
(i) the recipient of the information is subject to a law or a binding scheme that has the effect of protecting the information in a way that, overall, is at least substantially similar to the way in which the APPs & NZIPPs protect the information; and
(ii) there are mechanisms that could be taken to enforce the law or binding scheme; or
(b) both of the following apply:
(i) we expressly inform the individual about whom the information relates that if they consent to the disclosure of the information, we will not be required to take the steps described in paragraph 10.2 above; and
(ii) after being so informed, the individual consents to the disclosure; or
(c) the disclosure of the information is required or authorised pursuant to an Australian and New Zealand law or a court/tribunal order; or
(d) the APPs & NZIPPs otherwise allow us to refrain from taking the steps described in paragraph 10.2 above.

11. Our Website and Cookies

11.1 We may collect personal information about you when you use and access our website.
11.2 While we do not use browsing information to identify you personally, we may record certain information about your use of our website, such as which pages you visit, the time and date of your visit, and the internet protocol address assigned to your computer.
11.3 We may also use ‘cookies’ or other similar tracking technologies on our website that help us track your website usage and remember your preferences. Cookies are small files that store information on your computer, TV, mobile phone, or other devices. They enable the entity that put the cookie on your device to recognise you across different websites, services, devices, and/or browsing sessions. You can disable cookies through your internet browser, but our website may not work as intended for you if you do so.
11.4 We may also use cookies to enable us to collect data that may include personal information. We will handle any personal information collected by cookies in the same way that we handle all other personal information as described in this Privacy Policy.
11.5 Our website may contain links to websites operated by third parties. Those links are provided for convenience and may not remain current or be maintained. Unless expressly stated otherwise, we are not responsible for the privacy practices of, or any content on, those linked websites, and have no control over or rights in those linked websites. The privacy policies that apply to those other websites may differ from this policy, so we encourage you to read them before using those websites.

12. Security

12.1 We may hold your personal information in either electronic or hard copy form. We take reasonable steps to protect your personal information from misuse, interference, and loss, as well as unauthorised access, modification, or disclosure. We use a number of physical, administrative, personnel, and technical measures to protect your personal information. The Company’s security measures include:

• Confidentiality policy and employment contract standards

• Document storage security procedures

• System access security

• Only allowing access to personal information if an individual seeking access has satisfied reasonable identification requirements

• Building access controls

12.2 If we hold personal information about an individual which we no longer require, we will take reasonable steps to destroy the information or ensure that it is de-identified (unless our compliance with the APPs & NZIPPs or a law requires us to avoid taking such steps).

13. Anonymity and Pseudonymity

13.1 When interacting with us, individuals may choose to remain anonymous or to use a pseudonym. However, we may elect not to deal with the individual anonymously or pseudonymously if:
(a) We are required or authorised by or under an Australian and New Zealand law, or a court/tribunal order, to deal with them in accordance with their identity; or
(b) It is impracticable for us to deal with them in this way.

13.2 In some circumstances, it may not be possible for us to properly provide a service without the knowledge of an individual’s identity. This will often be the case when we are providing healthcare services.

14. Quality of Personal Information

14.1 We will endeavour to take reasonable steps to ensure that the personal information we collect is accurate, up-to-date, and complete.
14.2 The reasonable steps described above that we may undertake include:

• Ensuring that updated and new personal information is promptly added to relevant existing records

• Reminding individuals to update their personal information when we engage with them

• With respect to personal information in the form of an opinion, we may take the following steps to verify the accuracy of the opinion:
  (i) Checking that the opinion is from a reliable source
  (ii) Providing the opinion to individuals before we use or disclose it
  (iii) Clearly indicating on our record that the information is an opinion and identifying the individual who formed that opinion

14.3 If you think that the personal information we hold about you might be out of date and needs to be corrected, please contact us using the details located at paragraph 19.

15. Accessing Your Personal Information

15.1 You can access the personal information we hold about you by contacting us. Requests for access to personal information should be made in writing and addressed to the Human Resources Department, whose contact details are located in paragraph 19 below.
15.2 Upon request, we will, within a reasonable period of the request being made, give access to the information in the manner requested (if it is reasonable and practicable to do so), subject to exceptions set out in the APPs & NZIPPs.
15.3 The APPs & NZIPPs provide a list of situations in which we may deny individuals access to their personal information. These situations include where:

• Granting access would have an unreasonable impact on the privacy of others

• The information relates to existing or anticipated legal proceedings between the individual and ourselves, and would not be accessible by the process of discovery in those proceedings

• Access would reveal our intentions in relation to negotiations with the individual in such a way as to prejudice those negotiations

• Granting access would be unlawful

• Denying access would be likely to prejudice the taking of appropriate action in relation to the matter

15.4 If we refuse to give access to the personal information in accordance with the APPs & NZIPPs, or if we refuse to give access in the manner requested, we will take such steps (if any) that are reasonable in the circumstances to give access in a way that meets our needs and the needs of the individual.
15.5 If we refuse to give access to personal information in accordance with the APPs, we will provide a written notice setting out:

• The reasons for denying access to personal information (except where it would be unreasonable to provide the reasons)

• The mechanisms available to complain about the refusal

• Any other matters prescribed by the regulations

15.6 Generally, we will not charge fees for giving access to personal information. However, we reserve the right to charge reasonable fees where requests for personal information are complicated or resource-intensive.

16. Correction of Personal Information

16.1 Requests for correction of personal information should be made in writing and addressed to the contact person listed under paragraph 19.
16.2 If, with regard to the purpose for which it is held, we are satisfied that personal information we hold is inaccurate, out-of-date, incomplete, irrelevant, or misleading, or if the individual about whom the information relates makes a request, we will take reasonable steps to correct the information. However, as a matter of practice, when we receive personal information, we will hold the information for a period of time before we consider whether it is inaccurate, out-of-date, incomplete, irrelevant, or misleading (unless we are informed otherwise).
16.3 If we correct personal information, we will take reasonable steps to notify any third party to whom we had previously disclosed the information, if the individual about whom the information relates requests it and it is not unlawful or impracticable for us to do so.
16.4 If we refuse to correct personal information in accordance with the APPs & NZIPPs, we will provide a written notice setting out:

• The reasons for the refusal (except where it would be unreasonable to provide the reasons)

• The mechanisms available to complain about the refusal

• Any other matter prescribed by the regulations

16.5 If we refuse to correct personal information in accordance with the APPs & NZIPPs, the individual may request that we associate the information with a statement that the information is inaccurate, out-of-date, incomplete, irrelevant, or misleading. Where such a request is made, we will take reasonable steps to associate the statement so that it is apparent to the users of the personal information.
16.6 We will aim to respond to any request regarding the correction of personal information within 30 days of the request being made.
16.7 We will not charge fees for requests for the correction of personal information or for associating the statement with the personal information.

17. Making a Complaint

17.1 If you are concerned by the way Spectur Limited and Spectur NZ has used your private information or any aspects of this Privacy Policy, please contact us, and we will endeavour to resolve your enquiry by following our internal complaint resolution process. You can contact us using the details set out in paragraph 19 below.
17.2 Please include your name, email address, and/or telephone number and clearly describe your complaint. We will acknowledge your complaint and respond to you regarding your complaint within a reasonable period of time.
17.3 If you think that we have failed to resolve the complaint satisfactorily, a complaint may be made to the Office of the Australian Information Commissioner or the New Zealand Office of the Privacy Commissioner.

18. Changes to This Policy

We may change our Privacy Policy from time to time by publishing changes to it on our website. We encourage you to check our website periodically to ensure that you are aware of our current Privacy Policy.

19. Contact Us

For further information about our Privacy Policy or practices, or to access or correct your personal information, or make a complaint, please contact us using the details set out below:

Contact Person
Privacy Officer, Spectur Limited

Address in Person
12 Fargo Way, Western Australia, Australia 6164

Address by Post
PO Box 76, Welshpool DC, WA, 6986

Email
[email protected]

Telephone
1300 802 960

20. Definitions of Key Terms

• “Collect”: Personal information, including sensitive information, is considered ‘collected’ if it is included in a record or a generally available publication.

• “Consent”: Consent can be given either:

  • Expressly: Explicit consent either in writing or orally

  • Impliedly: Implied consent inferred from conduct (yours and ours)

• “Personal Information”: Defined in the Privacy Act, it includes any information or opinion about an identifiable person, whether true or false, and recorded in any form. Examples include name, address, and date of birth.

• “Sensitive Information”: A type of personal information that includes sensitive details such as:

  • Racial or ethnic origin

  • Political opinions

  • Religious beliefs

  • Health information

  • Criminal record

  • Sexual orientation or practices

21. Authorisation

Authorised by: The Board
Date: 01/09/2021