MillROC Privacy Policy

MillROC is committed to protecting the privacy of individuals' personal information by complying with relevant privacy laws. This Policy describes how MillROC handles personal information.

Nothing in this Policy is intended to limit MillROC's obligations or permitted handling of personal information under privacy laws in the countries where it operates. For example, under privacy laws in some jurisdictions, MillROC may rely on certain exemptions including in relation to employee records. If there is any conflict or inconsistency between the terms of this Policy and the privacy laws in the country where it operates, those privacy laws will prevail.

1.0 COLLECTION OF PERSONAL INFORMATION

Personal information is information or an opinion, including information or an opinion forming part of a database, whether true or not, and whether recorded in a material form or not, about an individual whose identity is apparent, or can reasonably be ascertained, from the information or opinion.

MillROC may collect personal information about you in certain circumstances such as where you contact or transact with MillROC. MillROC may collect current and historical personal information including information about your name, contact details, identification that you provide (e.g. driver's licence or passport), organisational affiliations, positions held, forms submitted, payment details, enquiry/complaint details, details of any injury or safety incident on any MillROC sites, results of drug and alcohol testing at MillROC sites, GPS tracking at MillROC sites and between sites, and details of any gifts or entertainment provided to you.

MillROC collects the information that you provide in your communications and transactions with MillROC, including records of any contact MillROC representatives may have with you by telephone, email or online.

MillROC may also operate video and audio surveillance devices in its premises for purposes including security, training, and dispute resolution. MillROC collects personal information directly from you as well as from third parties including public sources, its related companies, information service providers, and the parties with whom MillROC exchanges information as described here.

2.0 USE OF PERSONAL INFORMATION

The personal information that you provide to MillROC may be used for business purposes relevant to its relationship with you. This may include but is not limited to: assessing and responding to your enquiries, requests and applications; fulfilling your orders; identifying other products and services that you might purchase; helping MillROC improve its product and services offering; direct or other marketing of its products and services; market research; relationship management; injury and safety management, and protecting its lawful interests. MillROC may not be able to do these things without your personal information.

For example, MillROC may be prevented from delivering its products and services, communicating with you, and/or improving its product and service offering. MillROC may contact you on an ongoing basis by telephone, email, SMS, or other means regarding your account.

3.0 DISCLOSURE OF PERSONAL INFORMATION

MillROC may exchange your personal information with its related companies (parent companies, holding, subsidiaries, or affiliates under common control of MillROC), subcontractors, service providers, your guarantors (where applicable), and your representatives in the course of conducting its business.

The types of service providers MillROC engages include those that assist it with archiving, auditing, accounting, customer contact, legal, business consulting, banking, payment, debt collection, delivery, data processing, data analysis, information broking, research, investigation, insurance, website or technology services.

These services may be provided by third parties located in various countries. Your personal information may be disclosed to third parties transacting with MillROC in relation to its assets or businesses under an undertaking of confidentiality. If MillROC intends to transfer information to a domestic or foreign third party, the third party will assume the same obligations as MillROC.

Where you agree to this Policy, you consent to the disclosure of your personal information as outlined in this Policy and acknowledge and agree that: (a) privacy obligations in different countries may not always apply or may differ from country to country; (b) in some countries, MillROC may not be accountable for a recipient's storage, use, or disclosure of the information; and (c) a recipient of the information may be subject to relevant country laws which might compel further disclosures of personal information (e.g. to government authorities).

4.0 SECURITY AND CONFIDENTIALITY

MillROC implements various security measures to protect the security and confidentiality of your personal information, including taking reasonable steps to destroy or de-identify information that it holds about you when it is no longer required.

MillROC holds personal information electronically and in hard copy form, both at its own premises and online or with the assistance of its service providers.

5.0 RECRUITMENT

If you apply for a position with MillROC, MillROC may also collect information about your experience, character, qualifications, and screening checks (including background, health, reference, directorship, financial probity, identity, eligibility to work, vocational suitability, and criminal record checks).

MillROC may collect, use, and disclose your personal information to assess your application, conduct screening checks, and consider and contact you about positions available. MillROC may exchange your personal information with academic institutions, recruiters, screening check providers, health service providers, professional and trade associations, law enforcement agencies, referees, and your current and previous employers for the purpose of considering your application.

6.0 PERSONNEL

This section applies to MillROC's current and former employees and contractors, in addition to the recruitment section above. MillROC may collect information relating to your current or former employment or engagement, including information about your training, disciplining, resignation, termination, terms and conditions, emergency contact details, performance, conduct, use of MillROC IT resources, payroll matters, union or professional/trade association membership, recreation, drug/alcohol tests, leave, and taxation, banking, or superannuation affairs.

MillROC is required or authorised to collect your personal information under various laws in different countries. MillROC may collect, use, and disclose your personal information for purposes relating to your employment or engagement with it including engagement, training, disciplining, payroll, superannuation, health and safety, administration, insurance (including workers' compensation insurance), and staff management purposes.

MillROC may exchange your personal information with your representatives (including unions) and MillROC's service providers including providers of payroll, superannuation, banking, staff benefits, medical services, surveillance (where permitted by law), and training services. Without your personal information, MillROC may not be able to effectively manage your employment or engagement. If a current or former employee makes a claim under the workers' compensation law in any state, province, or territory, proper processing, assessing, and management of the claim will necessitate that information be collected and provided to and from statutory authorities and other entities under the legal obligations imposed by the applicable state, province, or territory.

7.0 CREDIT-RELATED INFORMATION

This section applies in addition to (and without limiting) the other parts of this Policy in connection with all trading and customer accounts with MillROC.

If you are an individual credit applicant or customer of MillROC, or if you are a guarantor for another credit customer (e.g. a company you represent), MillROC may collect consumer credit-related personal information about you.

The types of credit-related personal information we collect may include your name, gender, date of birth, and three most recent addresses; driver's license number; employer; amount and type of credit you have applied for; credit limits; terms relating to credit arrangements; confirmation of previous information requests to credit reporting bodies ("CRBs") made by other credit providers, mortgage insurers, and trade insurers; details of your current and previous credit providers; start and end dates of credit arrangements; permitted payment default information including information about related payment arrangements and subsequent repayment; any credit provider's opinion that you have committed a serious credit infringement (acted fraudulently or shown an intention not to comply with your credit obligations); information about court judgments against you; publicly available information about your creditworthiness; insolvency information; and any credit score or credit risk assessment indicating a CRB's or credit provider's analysis of your eligibility for consumer credit.

a. Credit information from third parties – The credit information that MillROC collects may include information about your arrangements and applications with other credit providers as well as with MillROC.

MillROC may collect credit-related personal information directly or indirectly from third parties including CRBs, published court records, and other credit providers (including through means such as credit references).

MillROC may also collect credit-related personal information directly or indirectly from you or an authorized representative assigned by your organization, including when you or the authorized representative within your organization applies for a commercial credit facility with MillROC; when you as a director of a company, owner of the business, or in your own capacity as an individual, provide personal guarantees as collateral for such a credit facility; when you or your organization request an increase in an existing credit facility and MillROC requires you to complete an application to facilitate such a request; or when you request access to, or correction of, your credit-related personal information.

b. Use and disclosure of credit-related personal information – MillROC uses credit-related personal information to (among other things) determine a credit applicant's (company or individual's) eligibility to qualify for, or request an increase to, a commercial credit facility with it; determine the strength of an individual's offer to act as a guarantor in support of a commercial credit facility being provided or an application for credit that has been submitted; manage the credit facility, guarantee, account, and our relationship with you effectively, including dealing with overdue debts, verifying your identity, maintaining and updating records.