Last reviewed: 30th June 2020

Alchemy Telco Solutions Pty Ltd (“Alchemy”) (ACN 632 917 867) is based at Tullamarine, Victoria, 3043, Australia. We are a global services company, specialising in Trade-In and Recycling Services, Consultancy, Product Sourcing, Accessories and Onsite Managed Services.

Alchemy operates conscientiously within the requirements of the Australian Privacy Principles contained in the Privacy Act 1998. We work within the principles of fair data processing, namely:

• Using information in a way that people would reasonably expect.

• Thinking about the impact of our processing.

• Being transparent and ensuring that people know how we will use their information.

This privacy policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

1. What This Privacy Policy Covers

This privacy policy covers how we treat any personal information that we collect and receive either from our website, through our app, or as part of our broader operating processes. This privacy policy describes: what information we collect; the steps we take to protect and secure it; how we use and share information; and finally, how you can contact us with questions or concerns.

2. Information we collect

Personal Information. If you are a customer, we collect your name, email address, phone number, home address, date of birth, and identity documentation (such as a copy of your driver's license, passport, proof of age card, Medicare Card, or other government identifier that shows your full name, photograph, current address and your signature, or other non-photo identification documents) , to provide services to you. We are required to collect identity verification documents to comply with the Second-Hand Dealers and Pawnbrokers (General, Exemption and Record-Keeping) Regulations 2018 (Vic).

If you are a supplier, we collect your name, email address, phone number and title to facilitate your interactions with us.

We may also collect other personal information that you choose to provide to us when you:

• Send us an enquiry or otherwise communicate with us through our website, app or social media networks.

• Call us to speak to customer care or for any other purpose.

• Email us

• Apply for a position with Alchemy.

2.1. Billing Information. If we provide services to you, we will require your billing information in order to process the transaction. Billing information includes your name, address, bank details.

2.2. If you do not provide the personal information that we request, we may not be able to provide the services you have requested to you.

3. Use of your Personal Information

3.1. We only use personal information for the purposes for which we collected it, unless you have otherwise consented or we are permitted or required to do so by applicable law. Under the GDPR, we may use your personal information where there is a legitimate interest and where the use of personal information is required for the fulfilment of your contract with Alchemy.

3.2. We may use personal information collected from you to provide you with information, updates, and our services. We may also make you aware of new and additional products, services, and opportunities available to you. We may use your personal information to improve our products and services and better understand your needs.

3.3. Where you have provided us with personal information as part of an application for a position with us, we may use that information to allow us to make an informed decision about whether to proceed with your application. We may, as part of this recruitment process, collect information about your education, employment history and similar matters from you or third parties.

3.4. If there are additional purposes for which we propose to use your Personal Information which are not specified in this privacy policy, they will be contained in the terms of any consent we may ask you to agree to when we collect your Personal Information. We will give you the option to decline to provide your Personal Information or to decline to allow us to use that Personal Information for the purposes for which we have proposed to use it.

3.5. When you access our website a small text file is saved to your web browser— a cookie. A “cookie” assigns you a unique identifier so that we can recognise you each time you re-enter the website. We use cookies to help us to improve our site and to provide us with information about usage of the website. Certain third parties also place cookies on your device when you browse our website. Cookies help us deliver an enhanced personalised experience to our users. You also have choices with respect to cookies. By modifying your browser preferences, you have the choice to accept all cookies, to be notified when a cookie is set, or to reject all cookies. If you choose to reject all cookies you will be unable to use those services or engage in activities that require the placement of cookies. Certain aspects of the Site may not function properly if you set your browser to reject all cookies. Please check our cookie policy for more information: https://www.alchemyglobalsolutions.com/cookie-policy/

3.6. If you require further information, please see Section 9 ‘Contacting Alchemy’.

4. Disclosure, Sharing and Retention of your Personal Information

4.1. Sharing. Alchemy does not share, sell, rent or trade personal information with any third parties for marketing or promotional purposes.

Alchemy reserves the right to share data with relevant authorities if compelled to do so to comply with legal obligations. We will use third party payment processors for card transactions to pay for goods and services but these third parties are authorized to use the data only as necessary to provide these services to us and are prohibited from using your personal information for promotional purposes. We may share Personal Information amongst other Alchemy businesses. Where information is shared, that other Alchemy business is bound by the original Primary Purpose for which the information was collected.

4.2. Disclosure. Alchemy may disclose your personal information under the following circumstances:

• In certain situations, we may disclose personal data in response to lawful requests by public authorities, including but not limited to national security or law enforcement requests. We may also disclose your personal information as required or permitted by law, such as to respond to court orders, or similar legal processes, to establish or exercise our legal rights or, defend against legal claims, or if in our judgment in such circumstances disclosure is required or appropriate.

• If we believe it is necessary to investigate, prevent, or take action regarding illegal activities in relation to our business, suspected fraud, situations involving potential threats to the physical or other safety of any person (including health), violations of our various terms of use, or as otherwise required or permitted by law.

5. International Transfer of your personal data

Information that we collect may, from time to time, be stored, processed in or transferred between parties located in countries outside of Australia. We have hosting facilities in Australia, UK and the European Economic Area (EEA). We adhere to the provisions in the Privacy Act 1998 during the transfer of your personal data by ensuring appropriate safeguards are deployed and ensure that when required, these are part of our service contracts. Alchemy operations across EEA adhere to the EU General Data Protection Regulations 2018 to ensure data security. Your personal data may also be processed by staff operating outside the European Economic Area who work for us or for one of our suppliers. These countries include but are not limited to the United States of America (USA) and India. Transfers to the USA will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission, a copy of which can be obtained from https://www.privacyshield.gov/. This arrangement imposes strong data protection obligations on companies receiving personal data from the EU, safeguards on US government data, effective protection and redress for individuals, and is subject to annual joint review by EU and US. The data processing conducted in India adheres to Alchemy’s data security and management standards.

6. Confidentiality and Security of your Personal Information

We use physical, electronic, and procedural safeguards to protect personal information. Our IT arrangements aspire to “Data Protection by Design” and should be able to detect a significant data breach. Where such a breach could result in discrimination, damage to reputation, financial loss, loss of confidentiality or any other significant economic or social disadvantage we will notify the relevant authority. Where a breach is likely to result in a high risk to the rights and freedoms of individual data subjects, we will also notify those concerned directly and at the earliest practical opportunity. We shall then fully investigate any data breach and implement corrective actions to prevent recurrence.

By using our services or providing personal information to us, you are consenting to Alchemy communicating with you electronically regarding security, privacy, and administrative issues related to your use of our services. We may post a notice on our website if a significant security breach occurs. In these circumstances, we may also send an email to you at the email address you have provided.

Data transmissions over the Internet are not 100% secure. Consequently, we cannot guarantee or warrant the security of any information you transmit to us and you do so at your own risk. Once we receive your transmission, we use reasonable efforts to ensure security on our systems.

7. Access to your personal Information

You may request details of personal information that we hold about you in accordance with the provisions of the Privacy Act 1988. If you would like a copy of the information which we hold about you or believe that any information we hold on you is inaccurate, out of date, incomplete, irrelevant or misleading, please email privacy@alchemyglobalsolutions.com

A fee may be charged for providing access however we will advise you of the likely cost in advance and will aim to supply the information within 14 days.

We reserve the right to refuse to provide you with information that we hold about you, in certain circumstances set out in the Privacy Act.

8. Changes to the Privacy Policy

Alchemy reserves the right to revise, modify, or update this privacy policy at any time. We will notify you via email about material changes in the way we treat personal data or by placing a prominent notice on our website.

9. Contacting Alchemy for Complaints or Privacy concerns

If you have a privacy concerns regarding Alchemy , or this privacy policy, you may contact us via privacy@alchemyglobalsolutions.com. We take complaints very seriously and will respond shortly after receiving written notice of your complaint.