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Privacy

PRIVACY STATEMENT

Global Proxy Solicitation Pty Limited ("GPS") provides a range of solicitation and quantitative/qualitative investor research services to Australian and foreign listed companies engaged in takeovers and mergers and for vote-dependent transactions and general meetings, including operating voting services. These services include facilitating communications from clients to securityholders, handling securityholder enquiries and recording information of securityholders for the purposes of establishing and operating proxy solicitation, opinion polling, focus group research and electronic voting and services.

Amendments to the Corporations Act 2001 (Cth) ("Corporations Act") in July 2004 under the Corporate Law Economic Reform Program introduced the ability to authenticate proxy appointments electronically rather than by signature.  The electronic authentication requirements are contained in section 250A and regulation 2G.2.01 of the Corporations Act.  Regulation 2G.2.01 provides that electronic authentication must include:

· a method for identifying the securityholder, which must be done through personal details (such as the securityholder's name, address, telephone number and date of birth); and

· an indication of the securityholder's approval of the information communicated, which must be done through a form of security protection (such as entering or providing a confidential securityholder reference number or holder identification number).

In providing electronic-based voting services, GPS collects records and maintains personal information of securityholders for the purpose of complying with these requirements.

GPS respects your right to privacy.  We are sensitive to the concerns that investors, our clients and online users may have with regards to the confidentiality, security and use of their personal information, and would like to reassure you of our position on this matter.  The purpose of this Privacy Statement is to tell you what type of information we collect, how we may use that information, whether we disclose it to anyone, and the opportunities you have to access and correct the information we hold. 

At all times we will comply with all applicable laws and regulations including the Corporations Act, the National Privacy Principles contained in the Privacy Act 1988 (Cth) and the Do Not Call Register Act 2006 as well as the Telecommunications (Do Not Call Register) (Telemarketing and Research Calls) Industry Standard 2007.

How we collect your information

GPS collects personal information about all types of equities investors including  individuals, companies, private and public superannuation funds, institutions, asset managers and hedge funds, on behalf of its clients.  The information we collect about investors includes name and address details, information on security holdings and contact details (including telephone, facsimile and e-mail).  This information is generally provided to us either directly by securities issuers or through securities exchanges or public sources (or a combination of the above). 

Additional information is collected and stored by us on our online web-portal, the "Deal Room".  This allows our clients to view information online and for GPS to communicate and provide services to clients electronically in a secure environment.

How we use your personal information

We collect personal information to provide our clients with the services they request as well as to provide investors with information about transactions or corporate actions that involve our clients.

Personal information may be used and disclosed within GPS to administer our services, and unless you tell us otherwise, to provide you with related information.  Some of the personal information we collect is essential for use to accurately identify who is using the service.  For example, in communications with securityholders, we may request the securityholder to enter or provide information we already hold such as the securityholder's name, securityholder reference number or holder identification number so we can identify the securityholder to perform the service. 

If you do not consent to certain uses or personal information by GPS, we may not be able to deal with you with the same level of service or ability, or provide you with a particular service.

Disclosure of personal information to third parties

We may disclose your personal information to clients or companies with whom you have invested.

We may engage third party contractors to perform services for us which involves the contractor handling personal information we hold.  For example, we engage third party contractors to provide email and mail handling services, operate call centres, conduct opinion polling and focus group research, telephone number searches and to provide information technology services such as data storage and software and system development and maintenance.

In these situations, we prohibit the third party contractor from using personal information about you except for the specific purpose for which we supply it.

Other than above, we will not disclose your personal information without your consent unless disclosure is authorised or required by law, for the investigation of an offence or for court proceedings.

Cookies

In order to improve the quality of our website and services, we may from time to time send you what is known as a "cookie". A cookie is a piece of text, which a website transfers to your computer's hard drive. A cookie assists in identifying, for example, whether you have visited our website on a previous occasion. Only the site that posted the cookie can read it.  You can generally configure your web browser to accept cookies, reject cookies or notify you when a cookie is sent.

Please note that the websites to which this site may be linked may also make use of their own cookies to collect information from you.

We store your personal information securely

Personal information is mainly held in secure electronic databases. We use a range of security processes to protect the confidentiality and security of personal information that we hold.  Our security procedures also provide that, in addition to any password which you may require to gain access to the service, you may have to provide proof of identification before we will release personal information to you.  You should never divulge your identification numbers, username, or password to anyone else. You should also never write your password down or store it on your computer.

Accessing and updating your information

You can seek access to the personal information we hold about you.  If the information we hold about you is inaccurate, incomplete or outdated, please inform us so that we can correct it.  Communication with you may be impeded if the information we hold is inadequate or inaccurate.

Changes to this Privacy Statement

GPS may make changes to its privacy and information handling practices from time to time for any reason.  Any changes will be made available on our website.

Further information

If you have any questions or would like further information about our privacy and information handling practices, please contact us at:

Privacy Officer
Global Proxy Solicitation Pty Limited
Level 2, 220 George Street
Sydney NSW 2000

Telephone: +61 2 8022 7999

Email: enquiries@gps-proxy.com