Industry Trading Pty Ltd ATF Industry Trading Unit Trust ABN 84 675 175 616; Industry Trading Pte. Ltd. UEN 201910623Z; and Elite Technology Solutions Ltd NZBN 9429038707384 (collectively, “Industry Trading” or “We” or “Our” or “Us”), respect your right to privacy and your right to control the dissemination of your Personal Information. “Personal Information” has the meaning given to it in the Australian Privacy Act 1988 (“Privacy Act”), namely, information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information or opinion is true or not. We collect your Personal Information for various reasons set out in this privacy policy (“Policy”). This Policy explains how We collect, store, use, disclose and manage your Personal Information (“Handle” or “Handling”).

This Policy applies to:

• the website on which Policy is posted;
• any other website, application or online or digital platform owned or operated by Us; or
• any other third-party website, application or online or digital platform used by Us, such as eBay (but strictly only to the extent that We collect your Personal Information from those third parties, We are not responsible for Personal Information you provide to such third parties);
• your Personal Information contained in written and/or physical form;

(collectively, "Website").

By visiting, using the Website and/or using the products or services contained on or through the Website, you acknowledge you have read and understood the terms of this Policy and that by so doing you provide and consent to Our Handling of your Personal Information.

Personal Information

Personal Information can take many different forms however the types We generally Handle are names, physical and email addresses, phone numbers and other contact information. This information helps Us provide services and service-related information to you.

Using the Website also involves Handling details relating to that use, including but not limited to time, date and duration of use, internet protocol addresses, traffic data, location data, weblogs, browser information, and other communication and diagnostic data. This information helps Us manage, measure and track use of the Website as well as monitor its performance to make the Website both easier and more convenient to use.

We also use cookies which are pieces of information that the Website transfers to your device to store and sometimes track information about your use of the Website. Cookies distinguish you from other users of the Website to help Us better serve you during future visits to the Website. Cookies do not contain any information that personally identifies you, but information that We store about you may be linked, by Us, to the information stored in and obtained from cookies.

You can set your browser to alert you to receipt of cookies, allowing you the opportunity to refuse the use of cookies, however if you so do, certain parts of the Website may not be accessible or function properly. Cookies may be:

• Session cookies: these are temporary and used during the course of your visit to the Website, and expire when you close your browser. These cookies allow Us to enable Website features, and help authenticate users and prevent fraudulent use of the Website; or
• Persistent cookies: these are used to remember your preferences within the Website and remain on your device even after you close your browser or restart your computer. These cookies help Us provide you with a more personal experience while using the Website.

Cookies may also be third party in nature meaning they are cookies used by third parties whose content appears on the Website.

Handling of Personal Information

We may Handle your Personal Information:

• to provide Our services to and do business with you;
• to communicate with you;
• for market research and marketing purposes;
• in the general management, administration, conduct, audit and improvement of Our services, business and Website;
• for security and risk management purposes;
• to comply with obligations imposed by law or with industry standards to which Our management systems are certified; or
• for a joint venture, collaboration, financing, sale, merger, reorganization, change of legal form, dissolution or similar event in relation to Us (“Governance Purpose”).

We will not Handle your Personal Information for any purpose other than that to which it is collected (or a related purpose) unless you have consented to Us so doing (except to extent we are required by law to use your Personal Information in a manner to which you have not previously consented).

Retention of Personal Information

Unless otherwise required by law or where We have a legitimate business need to so do, We retain Personal Information only for so long as is necessary to carry out the purposes set out in this Policy.

Disclosure of Personal Information

We may disclose your Personal Information for the purposes to which it was collected or for related purposes (including but not limited to that described above) to:

• regulatory authorities, police or government agencies or bodies where required by law;
• related parties, entities and trusts of Industry Trading, its directors or shareholders (“Related Parties”).
• other entities, service providers, professional advisors, consultants and third parties who assist Us in the provision of Our services, administration or management of Our business and operations;
• any person where We have a reasonable belief that We are required to so do to protect the rights, property or safety of Industry Trading or third-parties; or
• any person on a temporary or permanent basis, for a Governance Purpose. In the case of a merger or sale, your Personal Information will be permanently transferred to a successor entity.

In the event that your Personal Information is disclosed to a third-party, We request that the third-party does not use it for their own purposes and that they comply with the Privacy Act and this Policy.

Security of Personal Information

We store your Personal Information in Our electronic systems and/or at Our physical locations in electronic or paper form. We value and take reasonable steps to protect, the confidentiality and security of your Personal Information including maintaining safeguards against interference with, unauthorised access to, loss, modification or disclosure of, your Personal Information. By using the Website you agree that no Handling of your Personal Information can be completely secure, that there is always some risk to your Personal Information and that We do not warrant or guarantee the security of your Personal Information.

In the event of a data breach relating to your Personal Information and where We are required to so do by the Privacy Act, We will notify you and/or the Office of the Australian Information Commissioner.

Transfer of Personal Information

We operate and also may use service providers, across a number of countries other than Australia, and as such your Personal Information may be transferred outside of Australia. Where We so do, We take reasonable steps to ensure that service providers are obliged to protect your Personal Information in accordance with this Policy and the Privacy Act.

Some reasons that We may transfer your Personal Information outside of Australia are transfers:

• for storage on cloud or data servers which happen to be hosted outside of Australia;
• to a service provider located outside of Australia to assist Us with functions relating to the purpose of Our collection of your Personal Information, including but not limited to analysing and processing data;
• in order to provide services to, or do business with, you, if it necessarily involves transfer of your Personal Information outside of Australia; or
• to make disclosures to Related Parties located outside of Australia.

In the event that you are located outside of Australia and you use the Website you agree that any data you provide will be Handled in Australia or other countries, and that data protection laws and regulations in those countries may differ from the countries in which you are located.

In addition to the other provisions of this Policy, by your use of the Website you consent to the transfers outlined in this Policy.

Access to your Personal Information

You may contact Us at privacy@industrytrading.com to request access to or correction of, your Personal Information Handled by Us. We will consider your request and if We are unable to comply with it, We will provide you with a written response outlining the reasons why We were unable to so do. You will not be charged a fee to submit such a request, however We may charge you a reasonable fee in the event that complying with your request requires substantial effort on Our part.

Marketing communications

You can opt out of marketing communications from Us by lodging a request at privacy@industrytrading.com. Opting out of marketing communications does not mean We cannot communicate with you where required by law or for other reasonable business purposes.

Third-party websites

In the event the Website contains links to websites or other services owned and operated by third-parties, you agree that when you click on such a link, you are moving off the Website and We are not responsible for the privacy practices of those linked third-parties. We encourage you to read the privacy policies and other terms and conditions that apply to those third-parties which may differ from this Policy. If you have any concerns you should directly contact such third parties.

How to contact Us

If you have any questions, comments, concerns or complaints about this Policy or the Handling of your Personal Information please email Us at privacy@industrytrading.com.

In the event that you make a complaint, We will respond within 30 days and if you are not satisfied with Our response, you should notify Us so that We can investigate further and respond to you. If after that process has concluded you are still not satisfied, you may contact the Office of the Australian Information Commissioner.

Last updated

From time to time We may make updates to this Policy in accordance with changes to laws, technology, Our business and operations. Our current version of this Policy (last updated on 21 September 2021) is posted at https://industrytrading.com/privacy-policy/ and we encourage you to periodically review that webpage to stay updated on any changes to this Policy.