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Privacy Policy

Link Market Services Limited (‘Link’) [ABN 54 083 214 537] understands that privacy is important to you.

Link is subject to the requirements of the Privacy Act 1988 (Cth) ('Privacy Act') including the National Privacy Principles, which govern, among other things, how we handle your personal information.
Our Privacy Policy is designed to answer the following questions:

1. What personal information does Link collect?

Personal information means information or an opinion from which an individual's identity may be ascertained.
Link, a provider of registry and registry related services to listed and unlisted organisations (‘Issuers’) and the holders of their securities (‘you’), may obtain personal information in order to administer your security holding or to provide you with other services. If part or all of the information is not provided, then Link may not be able to supply its services to the Issuers and you.

Corporations Act 2001
In accordance with the Corporations Act 2001 (Cth) (‘Corporations Act’), Link collects personal information about you (including name, address and details of security held) on behalf of the Issuer. This information is included in the public register of the Issuer in which you hold securities.

You may also be asked to provide contact information (including telephone and facsimile numbers and email address). Other examples of details we may require from you are your tax file number and financial institution account details.
Under the Corporations Act, your personal information must continue to be included in the public register of the Issuer for 7 years after you cease to be a security holder.

Anti Money Laundering and Counter Terrorism Financing Act 2006
In accordance with the Money Laundering and Counter Terrorism Financing Act 2006 (AML/CTF Act), Link may collect personal information about you including but not limited to, your legal name and other names you may be known by, your residential street address and your date of birth. Link may also ask you for identity documents in order to verify your identity.

This information is collected on behalf of the Issuer, and, in regards to our ‘Share Sale Centre’, on behalf of Link/Pacific Custodians Pty Ltd. The AML/CTF Act requires a designated reporting entity to collect this information where a ‘customer’ (the investor) is requesting one of the designated services covered by the AML/CTF Act.

This information is generally not included in the public register. Access to information collected under the AML/CTF Act is restricted to authorised Link employees, the Issuer for which we collected the information, the AML/CTF Regulator – AUSTRAC and law enforcement agencies. Your personal information must be retained for a period of 7 years after the provision of a designated service.

2. How is personal information collected and stored?

This will depend on how you interact with us or the services you require.

We may collect personal information about you from an application form or a registration form or verbally if you call our call centre or speak directly with our staff.

In addition, if you access your information on-line through our Internet site [] (‘our website’) we may collect personal information relating to your holding during your visit to the website. The personal information is maintained on our servers, and a reference to this information is sent to the application you are using to access the Internet, in the form of a non-persistent "cookie". A "cookie" is a method employed to maintain a link between the application you are using and the website you are visiting. It is also used for security purposes. Non-persistent cookies exist only in the application's memory and are destroyed when the application is shut down. This behaviour is different to persistent cookies, which are stored on your computer and which may remain there for an extended period of time. Link specifically and exclusively uses a non-persistent (or session) cookie, which means once you exit your application the cookie and the reference to the data it contains is destroyed.

For on-line access to information about your security holding, you will need to authenticate your identity through a ‘knowledge’ process. This means that you must identify all of the following three fields adequately to gain and protect your access on-line:

  • Holder Identifier (e.g. your Security Reference Number or Holding Identification Number)
  • Surname/Company Name
  • Postcode/Country Name

Link takes reasonable steps to ensure the security of personal information held by it from such risks as loss or unauthorised access, destruction, use, modification or disclosure.

3. How is personal information used?

Link’s policy is to use personal information for the purpose for which it was collected and to offer and provide related services that are connected to that initial purpose.
For example, the personal information collected from you by Link may be used to:

  • Provide the relevant Issuers and you with registry and registry related services, or with other information you have requested; and/or
  • Notify you about other Issuer or Link services relating to the purpose for which your personal information was collected. If at any time you no longer wish to be notified about other Issuer or Link services, please let us know.

Please note that the personal information collected about you may be disclosed to related companies of the Issuer or Link, but only if this relates to the purpose for which your personal information was collected.

Please note that under the Corporations Act Chapter 2C certain information about you as a securityholder (including your name, address and details of the securities you hold) must be included in the public register of the entity in which you hold securities and, therefore, this information will be disclosed and is in the public domain.

Link will not use or disclose your personal information for any other purpose without first obtaining your express or implied consent

4. Will personal information be given to anyone else?

Our policy is designed to maintain the confidentiality of all personal information. We will take all reasonable steps to protect your personal information from misuse and loss, and from unauthorised access, modification or disclosure.

Link does not sell, rent or trade personal information to or with third parties.

In some circumstances however, personal information may be disclosed outside Link.

For example:

  • Disclosures may be required or authorised by or under law (for example, in accordance with the Corporations Act, where a person requests a copy of an Issuer's register of security holders).
  • Disclosures may be required or authorised in accordance with the AML/CTF Act, where the AML/CTF Regulator – AUSTRAC or a law enforcement agency requests a copy of the information.
  • Personal information collected by Link may be disclosed to third parties to which Link contracts out specialised functions (including mailing houses and printing companies). If so, we take reasonable steps to ensure that those contractors comply with the Privacy Act, and are authorised only to use personal information in order to perform the functions required by Link.
  • Personal information may be disclosed to third parties in accordance with the Issuer’s direction where this is related to the Issuer’s administration of security holdings.

5. How can you access and correct your personal information?

Under the Privacy Act, you have a right to seek access to information that we hold about you, although there are some exceptions to this (please see Principle 6 of the National Privacy Principles (Extracted from the Privacy Amendment (Private Sector) Act 2000). You also have the right to ask us to correct information about you which is inaccurate, incomplete or out of date. Link’s policy is to consider any requests for access or correction in a timely way and to take reasonable steps to correct the information so that it is accurate, complete and up-to-date.

To provide you with access to your personal information, Link would ordinarily provide you with a print-out of the relevant personal information from our current databases, or with photocopies of records which are held only on current paper files.

To provide you with access to personal information we collected under the AML/CTF Act, the Issuer and Link/Pacific Custodians will only provide you with a copy of, or confirmation of, the relevant personal information that we actually collected from you. The AML/CTF Act prevents the issuer and Link/Pacific Custodians from revealing certain information.

To access and/or correct such information, you may write to or call Link on the following:

Telephone: Sydney (02) 8280 7111 Melbourne (03) 9615 9800
In writing: Level 12, 680 George Street,
Level 1, 333 Collins Street,

If you wish to correct current information about you which is inaccurate, incomplete or out-of-date then, for security purposes, you will need to prove your identity by confirming/providing the following information to us:

  • Quote your Holder Identifier Number/Security Reference Number that appears on the latest documentation sent to you in relation to your security holding; OR
  • Provide proof of your registered name (Note: supporting documentation e.g. birth certificate, marriage certificate may also be required), and
  • Provide proof of your registered address that matches the details appearing on the register.

A form signed by you will also be needed in order to comply with the signing requirements below:

Individual holder: Must be signed by the securityholder or his/her attorney or a parent/guardian (if under 18) or a trustee such as a bankruptcy trustee or an Executor of a deceased estate.
Joint holders: Must be signed by all joint securityholders or their attorney(s) as stated above.
Companies: Must be signed by either; two directors or a director and company secretary with their titles stated, or a sole director and sole company secretary with his/her title stated; or the company’s attorney(s); or on letterhead if it claims to be signed by a duly authorised officer with their title.

Please note that if your security holding is sponsored by a broker, you will need to contact your broker directly who will then arrange for information such as your name and address to be corrected.
For legal and administrative reasons, Link may also store records containing personal information in its archives. You may seek access to the records held by Link which are not current records, but if you do so, we may charge you the reasonable cost of providing access.

If you have any questions or comments about this privacy policy, or if you wish to complain about how we have handled personal information about you, please contact Link’s Privacy Officer:

Telephone: (02) 8280 7824
In writing: The Privacy Officer, Link Market Services Limited, Locked Bag A14, SYDNEY SOUTH NSW 1235

If you have a privacy complaint, Link’s Privacy Officer will try to resolve the issue. Where the matter cannot be resolved to your satisfaction, you may refer it to The Privacy Commissioner who may be contacted on 1300 363 992 (for the cost of a local call anywhere in Australia) or by post to GPO Box 5218 Sydney NSW 2001.

This privacy policy may change from time to time and is current as at Date: 13 April 2011.

General Investor Enquiries

Link Market Services and Link Investor Services


0861 LINKSA (546572)


Postal Address:
PO Box 4844
Johannesburg 2000

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