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Privacy Policy

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1. Preface

Athotama Agencies group of companies is committed to keeping the personal information of its historic, current or prospective employees, customers, investors, third-party service providers and other third parties confidential, accurate, secure and private. For the purposes of this Privacy Policy Statement “Athotama Agencies” or the “Company” means Athotama Agencies Limited and its subsidiaries, affiliates, directors, officers or employees (as the context requires).

2. Information we collect

In order for Athotama Agencies to undertake its business and comply with applicable statutory, regulatory, contractual and quality management requirements Athotama Agencies may collect and hold the following personal information of employees, customers, investors and third parties:

  • Professional contact details (e.g. name, email address, postal address, telephone/facsimile number(s));
  • Identification documentation (e.g. photographic ID, date of birth, postal address);
  • Financial details (e.g. bank details).

If third parties contact Athotama Agencies and choose to provide their professional contact details to Athotama Agencies, it will collect and store personal information in a way that allows it to be related to the third party personally (e.g. name, email address, postal address, telephone/facsimile number(s)).

3. How and Why we use information

The use of personal information depends on individual circumstances, including but not limited to:

  • Marketing our business;
  • Performing our services;
  • Reporting to stakeholders;
  • Operating Athotama Agencies’ business.

Athotama Agencies holds data in electronic computer systems and utilises computer and communications equipment to access this personal information. Personal information is stored on Athotama Agencies’ systems and equipment appropriate to the use at the relevant time.

4. Who we share information with

In all circumstances, sharing of personal information is done so where there is a legitimate reason in connection with the uses outlined in Section 3 (How and Why we use information).

Athotama Agencies communicates with multiple parties in the ordinary course of its business, including but not limited to existing and prospective employees, customers, investors and third-party service providers. While doing so Athotama Agencies does not use personal information for any purpose other than that for which it was provided.

Athotama Agencies may share personal information with certain third parties who perform tasks on our behalf however information is only shared to the extent necessary to achieve the purpose for which it was provided. The aforementioned third parties act on Athotama Agencies’ instructions and are processors of the personal information (e.g. service providers, professional advisors, contractual counterparties).

Athotama Agencies may also share personal information with third parties where there is a statutory, regulatory, contractual or quality management obligation to do so.

5. How we protect information

All personal information collected and recorded, on paper or electronically, has appropriate safeguards in place as required by statutory, regulatory, contractual or quality management obligations.Athotama Agencies’ policies and procedures are intended to minimise the risk of loss or damage.

Athotama Agencies has ensured key personnel within the Company have been provided familiarisation and training in relation to protecting personal information and are subject to a duty of confidentiality in respect of personal information we obtain and process.

Athotama Agencies is able to restore personal information stored electronically in situations where data has become corrupted or lost.

Where appropriate, the Company uses encryption, access restrictions and/or security measures to protect personal information.

The Company’s control of personal information is regularly reviewed to ensure adherence with best practice and to ensure suitability of the controls over confidentiality, accuracy, security and privacy of personal information.

No means of protecting personal information is guaranteed by Athotama Agencies.

6. Where information is processed

Due to the nature of the Company’s business personal information is processed worldwide.

7. How Long we keep information

In accordance with the Company’s policies and procedures, personal information may be maintained for up to 7 years. From time to time the Company has a legitimate interest to maintain historic records of personal information for internal purposes indefinitely.

8. Your rights

Employees, investors, customers and third parties have legal rights in relation to how Athotama Agencies processes personal information, including but not limited to:

  • Right to be informed;
  • Right of access;
  • Right to request rectification;
  • Right to request erasure;
  • Right to restrict processing;
  • Right to data portability;
  • Right to object or withdraw consent.

9. Contract information and complaints

Any enquiries or complaints in relation to this Privacy Policy or the personal information Athotama Agencies has or may obtain / process in respect of historic, current or prospective employees, investors, customers or third parties should be directed to:

Athotama Agencies Limited, 200 Cantonment Road #13-05, Southpoint,

10. Changes to the policy

This policy was last updated 25 May 2018. Athotama Agencies reserves the right to make changes to this policy as required.

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