PRIVACY POLICY

Globe International Limited (“Globe”) trading as Impala™ is committed to ensuring the privacy and security of all information collected from our customers, potential customers and any other persons we deal with, in accordance with the Privacy Act 1988 and its thirteen Australian Privacy Principles (APPs) in so far as they apply to our business operations. This Privacy Policy outlines the information collection practices utilized by Globe, how that information is used and the choices you can make about the way the information you provide to us is collected and used.

The information we collect

When you lodge an enquiry with or submit an order to Globe either by telephone, via our websites, or by any other method we collect information about you in order to enable us to complete our sales transaction or to provide information about our products or our company or to service your request. This information includes, but is not limited to, your personal information such as your name, your contact details, your purchase or enquiries and relevant business and financial information. We may not be able to serve you fully if you do not supply the information.

We will take all reasonable steps to ensure that the personal information we collect from you is accurate, up to date and complete and that when we use or disclose that information it remains accurate, up to date and complete. If you request that we correct or change information that we have previously provided to third parties, then we will do so provided it is reasonable and practicable to do so.

Globe does not receive unsolicited personal information about you from any third parties. Further we do not collect any sensitive information about you such as information about your political opinions, religious beliefs, sexual preferences or about your health. Lastly we do not adopt any government related identifiers in order to identify you. For example your personal income tax number.

When you are not purchasing products from Globe you have the option of not identifying yourself or alternatively you can use a pseudonym for instance, when you ask for a catalogue of our products or product information. However the use of a pseudonym might not always be practicable as it may make it difficult for us to forward such information without your name, being made available to us.

If we were to collect your personal information from someone other than you, we will notify you that such information has been collected and the circumstances of that collection.

Globe web site

Like most web sites, there is certain information we automatically track when you use a Globe website, including the URL that you came from, the browser you are using and your IP address. This data is utilized to improve how GLOBE responds to your queries and purchase requirements and does not include any personally identifying information. We will not retain any such information unless you submit that information for our response or other transactional purposes.

This policy does not apply to other third party websites which you access by using a link from our website. The content and privacy policies of other websites are the responsibilities of their owners.

How we use the information

The information you provide will be collected and saved by us and used to assess your requirements and to enable Globe to provide its products and product information to you or to service any other request you may have. It may also be used for other purposes which you would reasonably expect, for example, for research, staff training, planning or for supply to third party service providers such as mailing houses that we use to send you surface post material, third party clearance houses, share registries or mercantile agents for account settlement.

We do not sell, rent or trade your personal information to third parties for their marketing purposes. If at any point in time you would like your personal information to be deleted from our system, please contact our privacy officer or online team and we will arrange to have your records deleted from our database.

As a customer or potential customer of Globe’s products, you may occasionally receive email or other updates from us about new information or products being offered by Globe. You may always unsubscribe and opt out from receiving these messages.

Unless otherwise prohibited by law, we may disclose personal information if required to do so by law, court order, or as requested by a governmental or law enforcement authority. Such situations may include to protect the rights or properties of Globe or when we have reason to believe that disclosing the information is necessary to identify, contact, or bring legal action against someone who may be causing, or who may be threatening to cause, interference with or damage to our rights or properties, whether intentionally or otherwise; or when anyone else could be harmed by such activities.

We do not disclose your personal information to any overseas recipients.

Opting out of promotional information from GLOBE

Globe works hard to provide our customers and future customers with the best possible products and information at all times. From time to time, we will send you newsletters, updates and other useful information. We hope that you will find these items informative and useful. However, should you choose to not receive them in the future, you will have the ability to unsubscribe from the mail database by following the Unsubscribe instructions at the bottom of each email.

Our commitment to data security

All information captured by Globe is stored securely at all times and will not be provided to any unauthorised third parties.

We use Secure Socket Layer (SSL) encryption to scramble your personal information including credit card information. From time to time we review whether we still need to retain your personal information. If it is no longer required for its purpose for which we originally collected it then we will delete your information from our database or ensure the information is de identified.

Access to your information

If you wish to know what information we have gathered about you, you can request this information by contacting our privacy officer, Samantha Cook, Company Secretary, Globe International Limited 1 Fennell Street, Port Melbourne 3207 Victoria, Australia or by email at: privacyofficer@globebrand.com. If any of the personal information provided by you changes, is inaccurate, incomplete, irrelevant or misleading please let our privacy officer know what information needs to be deleted, changed or corrected. We will endeavour to respond to your request within seven days. However we are not required by the Privacy Act to give you access to your information in certain circumstances such as where your request for access if frivolous, vexatious or information relates to legal proceedings between us and yourself and would not be accessible by the process of court discovery in these proceedings. If you would like a free copy of this policy in paper form or in some other form please make that request of our privacy officer. In some circumstances we may ask you to pay reasonable out of pocket expenses, such as photocopy costs, associated with satisfying your request.

 

If we refuse to give you access to your information or to give access in its manner requested by you then we will give you a written notice that sets out:

• Our reason for refusal except to the extent that, having regard to the grounds for the refusal, it would be unreasonable to do so and
• The mechanisms available to complain about the refusal
• Any other matter prescribed by the regulations of the Privacy Act.

If we were to refuse to correct your personal information when you request that we do, we will provide a written notice which will set out both our reason for our refusal unless it is unreasonable to do so and the mechanism available to complain about our refusal and any other matter prescribed by regulations to the Privacy Act. You also have the right to request that we associate a statement with your information stating that you say that the information is inaccurate, out of date, incomplete, irrelevant or misleading.

Making a complaint

A person may make a complaint if they feel their personal information has been handled inappropriately by Globe in breach of Globe’s privacy obligations under the Privacy Act.

In the first instance, complaints must be directed to Globe’s Privacy Officer in writing. Globe will investigate the complaint and prepare a response to you in writing within a reasonable period of time.

If you are not satisfied with Globe’s response or the manner in which Globe has dealt with the complaint, you may make a formal complaint to the Office of the Australian Information Commissioner (“OAIC”).

Revisions to policy

This policy is reviewed regularly and may be revised from time to time, as we alter the way we use your information, or new features are added to the site or the legislation changes. Please check the policy periodically for updates and additions.

International application of privacy laws

As an Australian listed company, this policy outlines our policies in so far as they comply with Australian regulations. In addition to this, where we have operations outside of Australia, there are policies in place to ensure compliance with privacy laws and regulations in the relevant jurisdictions.

How to contact us

If you have any concerns or queries about Globe’s Privacy Policy or would like more information, please contact our privacy officer Samantha Cook, Company Secretary, Globe International Limited, 1 Fennell Street, Port Melbourne 3207 Victoria, Australia or by email at: privacyofficer@globebrand.com