Introduction

We are bound by the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles (APPs). This policy explains how and why we collect, use, hold and disclose your personal information.

“We”, “us” and “our” means Vulcan Energy Resources Limited (ACN 624 223 132) of Level 11, Brookfield Place 125 St Georges Terrace, Perth WA 6000.

You consent to us collecting, holding, using, and disclosing your personal information in accordance with this policy.

What is Personal Information

Personal information is any information or an opinion about an identified individual or an individual who can be reasonably identified from the information or opinion. Information or an opinion may be personal information regardless of whether it is true.

What is Sensitive Information

Sensitive personal information includes information or an opinion about matters like your health, criminal history or racial or ethnic origin. In limited circumstances, we need to collect this information from you to assist you. We will not collect sensitive information about you unless you consent to the collection and the information is directly related to our activities.

What Personal Information do we Collect and Hold

We collect information about you and your interactions with us, for example, when you sign up to our newsletter, call us or otherwise visit our website. The information we collect from you may include your identity and contact details, your history of purchases and details of enquiries or complaints you make.

We may collect information about how you access, use, and interact with the website. (We do this by using a range of tools such as Google Analytics). This information may include:

• the location from which you have come to the site and the pages you have visited; and
• technical data, which may include IP address, the types of devices you are using to access the website, device attributes, browser type, language, and operating system.

We use cookies on the website. A cookie is a small text file that the website may place on your device to store information. We may use persistent cookies (which remain on your computer even after you close your browser) to store information that may speed up your use of our website for any of your future visits to the website. We may also use session cookies (which no longer remain after you end your browsing session) to help manage the display and presentation of information on the website. You may refuse to use cookies by selecting the appropriate settings on your browser. However, please note that if you do this, you may not be able to use the full functionality of the website.

Links on our website may take you outside our network.  These links are provided in good faith.  However, we are not responsible for third party sites and accept no responsibility for the content, accuracy, security or function of third-party sites.

Why we Collect, Hold and Use your Personal Information

We collect, hold, and use your personal information so that we can:

• provide you with information and manage our relationship with you;
• contact you, for example, to respond to your queries or complaints, or if we need to tell you something important;
• comply with our legal obligations and assist government and law enforcement agencies or regulators; or
• identify and tell you about other products or services that we think may be of interest to you.

If you do not provide us with your personal information, we may not be able to provide you with our services, communicate with you or respond to your enquiries.

How we Collect your Personal Information

We will collect your personal information directly from you whenever you interact with us, which may include data that is freely provided by you, collected automatically when using this website or from publicly available sources including social media.

We may collect information from third parties including but not limited to data collection and analysis platforms, credit reporting bodies, other credit providers, existing or previous supplier of goods or services, your bank and certain other businesses for the purposes of providing our services.

Users are responsible for any third-party personal data obtained, published or shared through this Website and confirm that they have the third party’s consent to provide the data to the owner.

How we Store and Hold Personal Information

We store most information about you in computer systems and databases operated by either us or our external service providers. Some information about you may be recorded in paper files that we store securely.

We implement and maintain processes and security measures to protect personal information which we hold from misuse, interference, or loss, and from unauthorised access, modification, or disclosure.

These processes and systems include:

• the use of identity and access management technologies to control access to systems on which information is processed and stored;
• requiring all employees to keep information secure; and
• monitoring and regularly reviewing our practise against our own policies and against industry best practice.

We will also take reasonable steps to destroy or de-identify personal information once we no longer require it for the purposes for which it was collected or for any secondary purpose permitted under the APPs.

Who do we Disclose your Personal Information to and why?

We may transfer or disclose your personal information to our related companies.

We may disclose personal information to external service providers so that they may perform services for us or on our behalf.

We may also disclose your personal information to others (outside our group of companies) where:

• we are required or authorised by law to do so;
• you may have expressly consented to the disclosure, or the consent may be reasonably inferred from the circumstances; or
• we are otherwise permitted to disclose the information under the Privacy Act.

For example, we may share your data with service providers, including third party social networking and media websites such as Facebook or Twitter, to enable them to provide quality services on our behalf; company affiliates, in order to work with them; or business partners, for example to offer products or services where you purchase or specifically express interest in a jointly-offered product or service from us.

We do not control our business partners’ use of the data about you we collect, and their use of the information will be in accordance with their own privacy policies

If the ownership or control of all or part of our business changes, we may transfer your personal information to the new owner.

Do we Disclose Personal Information to Overseas Recipients?

We may disclose your personal information to recipients which are located outside Australia.

Those recipients are likely to be located in Germany, United Kingdom and/or United States. However to facilitate any global operations of the Company, it may transfer and access such information from around the world, including from other countries in which the Company operates. This Privacy Policy will apply even if the Company transfers data about you to recipients in other countries.

Do we use Your Personal Information for Marketing?

Where you receive electronic marketing communications from us, you may opt out of receiving further marketing communications by following the opt-out instructions provided in the communication.

Access to and Correction of your Personal Information

You may access or request correction of the personal information that we hold about you by contacting us. Our contact details are set out below. There are some circumstances in which we are not required to give you access to your personal information.

There is no charge for requesting access to your personal information, but we may require you to meet our reasonable costs in providing you with access (such as photocopying costs or costs for time spent on collating large amounts of material).

We will respond to your requests to access or correct personal information in a reasonable time and will take all reasonable steps to ensure that the personal information we hold about you remains accurate and up to date.

Your Rights Under the EU GDPR

Under the European Union (EU) General Data Protection Regulation (GDPR), as a data subject you have the right to:

• access your data;
• have your data deleted or corrected where it is inaccurate;
• object to your data being processed and to restrict processing;
• withdraw consent to having your data processed;
• have your data provided in a standard format so that it can be transferred elsewhere; and
• not be subject to a decision based solely on automated processing,
  (Data Subject Rights).

We have processes in place to deal with Data Subject Rights requests. Our actions and responsibilities will depend on whether we are the controller or processer of the personal data at issue. Depending on our role as either a controller or processor, the process for enabling Data Subject Rights may differ, and are always subject to applicable law. Please refer to the Contact Details section of this policy if you would like to make a Data Subject Rights request OR have a specific need for assistance with a Data Subject Rights request.

Complaints

If you have a complaint about the way in which we have handled any privacy issue, including your request for access or correction of your personal information, you should contact us. Our contact details are set out below.

We will consider your complaint and determine whether it requires further investigation. We will notify you of the outcome of this investigation and any subsequent internal investigation.

If you remain unsatisfied with the way in which we have handled a privacy issue, you may approach an independent advisor or contact the Office of the Australian Information Commissioner (OAIC) (www.oaic.gov.au) for guidance on alternative courses of action which may be available.

Contact Details

If you have any questions, comments, requests, or concerns, please contact us at:

Vulcan Energy Resources Limited
Level 2,
267 St Georges Terrace
Perth WA 6000

Australia

+61 8 6189 8767

info@v-er.eu

Changes to this policy

From time to time, we may change our policy on how we handle personal information or the types of personal information which we hold. Any changes to our policy will be published on our website.

You may obtain a copy of our current policy from our website or by contacting us at the contact details above.