PRIVACY POLICY

Sumitomo Australia Pty Ltd (SAPL) is a wholly owned subsidiary of Sumitomo Corporation Asia & Oceania Pte. Ltd. The ultimate holding company is Sumitomo Corporation.

SAPL, like all other companies operating in Australia, is bound by the National Privacy Principles as set out in the Privacy Act 1988 (Cth), see:

http://www.oaic.gov.au/privacy/making-a-privacy-complaint

In November 2012, the Australian Senate passed the Privacy Amendment (Enhancing Privacy Protection) Act 2012 changes to Australian privacy law in a number of areas. These changes will take effect in March 2014.

To review the amendments, see: http://www.oaic.gov.au/privacy/making-a-privacy-complaint

SAPL’s policy on the collection, use and disclosure of personal information based on the Privacy Act 1988 and the 2012 Amendments to the Act is set out below:

1. What Personal Information does SAPL collect and why?

SAPL collects personal information:

(a) for the purposes of recruitment and employment (“Employment Information”); and
(b) in order to provide goods and services to customers (“Customer Information”).

The type of personal information we collect is usually a person’s name, address, email address, and telephone numbers.

Personal Information may also include the following:

(a) in relation to Employment Information - date of birth, CVs and resumes, education, qualification, language skills, medical information and emergency contact details; and
(b) in relation to Customer Information - information on the use of our products and services.

2. How SAPL may use your Personal Information

Employment Information may be used for recruitment, employment and human resource management purposes.

Customer Information may be used for a number of purposes connected with our business operations, which include:

(a) processing your orders, billing and administering your account;
(b) carrying out credit checks and scoring;
(c) carrying out market and product analysis and marketing our products and services generally; and
(d) contacting you about and providing you with our products and services

3. Disclosure of Personal Information

SAPL may disclose or receive personal information or documents about you:

(a) to/from its related body corporates, who will protect and use the information only in accordance with this policy;
(b) as required by law or law enforcement agencies;
(c) in relation to Employment Information – to/from human resource and payroll services providers who have agreed to keep the information confidential;
(d) in relation to Customer Information - to/from service providers or other contractors, in relation to the goods or services provided to you, and who have agreed to keep the information confidential.

Your personal information may be transferred overseas for the purposes listed above. Countries to which your personal information may be transferred may include the Netherlands (Summit Global Management B.V. II), Japan (Sumitomo Corporation) and Singapore (Sumitomo Corporation Asia & Oceania Pte. Ltd.).

We will not use your information other than described above unless we have your consent.

4. Security of and access to your Personal Information

We will take reasonable steps to ensure that the personal information we collect, use or disclose is:

(a) accurate;
(b) complete;
(c) up-to-date; and
(d) stored in a secure environment protected from unauthorised access, modification or disclosure.

Upon your request, SAPL will provide you access to your personal information held by us, except in certain prescribed circumstances, including emergency situations, specified business imperatives and law enforcement or other public interests. Information contained on the database may be amended by contacting SAPL.

5. Cookies

We do not use "cookies" and other Web technologies at this time, however in the event our website should have cookies in the future, we will revise and update this policy accordingly. A cookie is a small file sent by a Web site and stored on a user’s computer which enables the Web site to remember information about you and your preferences.

6. Links to Non-SAPL and Third Party websites

This website may contain links to other websites for convenience and information. We do not control those sites or their privacy practices, and we do not endorse or make any representations about third party websites. Any personal data provided to unrelated third parties is not covered by this policy.

7. Cloud Computing Services

We do not use any cloud computing services at this time, however, in the event we move to use such services, we will revise and update this policy accordingly.

8. How to Complain About a Privacy Breach

If you believe SAPL has breached your right to privacy of personal information, you may complain to SAPL’s Company Secretary as a first instance, and, if we fail to respond, or you are dissatisfied with our response, to the Office of the Australian Information Commissioner (OAIC) who investigates privacy complaints from individuals about Australian, ACT and Norfolk Island government agencies, and private sector organizations covered by the Privacy Act.
Before you can lodge a complaint with the OAIC, you will generally need to complain directly to the agency or organization you are complaining about and allow 30 days for it to respond. If you do not receive a response (after 30 days), or you are dissatisfied with the response, you may then complain to the OAIC. Here is a link for more information on how to lodge a complaint with the OAIC: http://www.oaic.gov.au/privacy/making-a-privacy-complaint.

9. How SAPL will deal with a complaint

SAPL is committed to keeping your personal information private, and in all cases we will treat your personal information with no less protection than that provided for by the National Privacy Principles and the privacy laws that are in force in Australia. However, if you believe we have breached your right to privacy of personal information, we will carefully review your complaint and aim to reply within 30 days of receipt of the complaint.

To make a complaint please do so by contacting the Company Secretary on 02 9335 3700.

10. Changes or updates to this policy

From time to time and in line with legislative changes, our privacy policy and procedures will be reviewed and, if appropriate, updated.

11. How to contact us

If you have any queries or concerns, please contact the Company Secretary on 02 9335 3700.