Privacy Policy

Last updated: 25 September, 2024

Elgin Energy Holdings Limited and its relatedbodies corporate ("we" or "us") understandsthat protecting your personal information is important. This Privacy Policyoutlines our policies regarding the collection, use, and disclosure of personalinformation we receive when interacting with you.

1.    Information Collection and Use

Personal information is information or an opinion, whether true or notand whether recorded in a material form or not, about an individual who isidentified or reasonably identifiable.

The types of personal information we may collectabout you include:

·       Identity data including your name or image;

·       Contact data including your email address;

·       Professional data including your professional history such as your previous positions andprofessional experience; and

·       Technical and Usage Data when you access the website located at elgin.com and any of our socialmedia pages which are operated by Elgin Energy Holdings Limited (together the"Websites") or our other platforms, details about yourinternet protocol (IP) address, login data, browser session and geo-locationdata, statistics on page views and sessions, device and network information,acquisition sources, search queries and/or browsing behaviour, access and useof our Websites (including through the use of Internet cookies or analytics),and communications with our Websites.

We may collect your personal information in thefollowing ways:

·       when you provide it directly to us, including face-to-face, over thephone, over email, or online;

·       through the Websites;

·       when you complete a form on or through the Websites (such as a jobapplication);

·       when you use the Websites (including from any analytics and cookieproviders or marketing providers. See the “Cookies” section below for moredetail on the use of cookies);

·       where we communicate or interact with you in the course of our business;

·       where your personal information is provided to us in connection with theprovision of our services;

·       where you attend an event which we organise or sponsor; or

·       where you are employed or engaged by suppliers of goods or services orparties tendering to provide goods or services.

By submitting personal information, you consent tothe collection, use, and processing of your personal information in accordancewith this Privacy Policy.

We may collect, hold, use and disclose yourpersonal information for the following purposes:

·       recruitment purposes – if you have applied for employment with us, toconsider your employment application (for example, we may use your emailaddress to communicate with you regarding your application and to provideupdates on the recruitment process);

·       to respond to your enquiry and to support any support request you lodgewith us or other enquiries you make with us;

·       to contact and communicate with you in the course of our business,including about any enquiries you make with us via the Websites or forpromotional purposes to support our legitimate interests;

·       to comply with our legal obligations or if otherwise required orauthorised by law;

·       to maintain and operate our Websites;

·       for analytics, market research and business development/marketing purposesto operate and improve our business, associated applications and associatedsocial media platforms; and

·       for internal record keeping, administrative, invoicing and billingpurposes.

If you provide personal information to us, youunderstand we will collect, hold, use and disclose your personal information inaccordance with this Privacy Policy. You do not have to provide personalinformation to us, however, if you do not, we may not be able to consider youremployment application, provide certain products or services in full, orrespond to or manage your enquiry or request.

We will retain personal information only for aslong as necessary for the purposes for which it was collected, as required bylaw or regulatory guidance to which we are subject, and for the exercise ordefence of legal claims that may be brought by or against us.

2.    Cookies

We may use cookies on the Websites. Cookies, bythemselves, do not tell us personally identifiable information. However, theydo recognise you when you return to the Websites and provide enhanced features(such as your language preferences). Please see our CookiePolicy for moreinformation. You can block cookies by activating the setting on your browserthat allows you to refuse the setting of all or some cookies. Most web browsersallow you to control cookies through their settings. You can usually find thesesettings in the "options" or "preferences" menu of yourbrowser. However, disabling certain cookies may affect the functionality of ourWebsites.

3.    Information Sharing and Disclosure

We will only disclose your personal information to thirdparties where it is necessary as part of our business, where we have yourconsent, or where permitted by law. This means that we may disclose personalinformation to:

·       our employees, contractors and/or affiliated companies;

·       third-party service providers who provide services to us, including, forexample assisting us in the recruitment process;

·       IT service providers, data storage, web-hosting and server providers,including third parties to collect and process data, such as analyticsproviders and cookies;

·       courts, tribunals, regulatory authorities and law enforcement officers,as required or authorised by law, in connection with any actual or prospectivelegal proceedings, or in order to establish, exercise or defend our legalrights;

·       third parties as required or permitted by law, such as where we receivea subpoena;

·       a prospective seller or buyer of any of our assets or business; or

·       a third party where it is necessary to protect the vital interests ofthe data subject or another natural person.

4.    Data Security

We take appropriate security measures to protectagainst unauthorised access, alteration, disclosure, or destruction of personalinformation collected. However, please note that no method of transmission overthe internet or method of electronic storage is 100% secure. Therefore, whilewe strive to use commercially acceptable means to protect your personalinformation, we cannot guarantee its absolute security.

5.    Changes to this Privacy Policy

We may update this Privacy Policy from time totime. We will notify you of any changes by posting the new Privacy Policy onthis page. You are advised to review this Privacy Policy periodically for anychanges.

6.    Your rights and controlling your personal information

a)    Australian Compliance

This section and all provisions in relation to Australianprivacy and data protection compliance in this Privacy Policy only apply to theextent that Australian law applies to the relevant individual.

You have a right to:

• Access     your personal information: You may request access to the personal     information that we hold about you. Please note, we may be legally     permitted to withhold access to your personal information in some     circumstances. If access cannot be provided, we will notify you as soon as     reasonably possible and provide you with the reasons for our refusal and     any processes available to complain about the refusal. If we can provide     access to your information in another form that still meets your needs,     then we will take reasonable steps to do so.
• Correct     your personal information: You     may request us to correct the personal information we hold about you if     you believe it is inaccurate, out of date, incomplete, irrelevant or     misleading. We will take reasonable steps to promptly correct any     information found to be inaccurate, out of date, incomplete, irrelevant or     misleading. Please note, we may be legally permitted to not correct your     personal information in some circumstances. If we cannot correct your     information, we will advise you as soon as reasonably possible and provide     you with the reasons for our refusal and any process available to complain     about the refusal.

To exercise these rights, you may contact us usingthe contact information provided in this Privacy Policy below.

Complaints

If you wish to make a complaint in connection withthe collection and handling of your personal information, please contact ususing the details below and provide us with full details of the complaint. Wewill promptly investigate your complaint and respond to you, in writing,setting out the outcome of our investigation and the steps we will take inresponse to your complaint. If you are not satisfied with our response, you maycontact an external regulatory complaint body, such as the Office of theAustralian Information Commissioner (OAIC) for Australian complaints.

Overseas disclosures

We may disclose your personal information tooverseas recipients, including the UK and to countries in the European Union.This is strictly for the purposes set out in the section titled “InformationCollection and Use” and we will only disclose your personal informationoverseas in accordance with the section titled “Information Sharing andDisclosure”.

b)    GDPR Compliance

Elgin Energy is committed to compliance with theGeneral Data Protection Regulation (“GDPR”) regarding the collection,use, and retention of personal data from individuals in the European Union. Thissection and all provisions in relation to GDPR compliance in this Privacy Policyonly apply to the extent that the GDPR applies to the relevant individual.

Legal Basis for Processing

Under the GDPR, we process personal data based onone or more lawful bases, including:

• the consent of the data     subject;
• processing necessary     for the performance of a contract with the data subject or to take steps     at the request of the data subject prior to entering into a contract;
• compliance with a legal     obligation;
• protection of vital     interests;
• performance of a task     carried out in the public interest or in the exercise of official     authority vested in the controller; and
• legitimate interests     pursued by the controller or a third party.

European Economic Area (EEA) Data Transfers

We may transfer personal data collected tocountries outside the European Economic Area (EEA) for the purposes describedin this Privacy Policy. When we transfer personal data outside the EEA, weensure adequate safeguards are in place to protect the privacy and security ofpersonal data in accordance with applicable data protection laws, including theGDPR.

Data Subject Rights

Under the GDPR, individuals in the European Unionhave certain rights regarding their personal data, including the right to:

·       access their personal data;

·       rectify inaccurate personal data;

·       erase personal data ("right to be forgotten");

·       restrict the processing of personal data;

·       object to the processing of personal data; and

·       data portability.

To exercise these rights or for any inquiriesregarding the processing of personal data, individuals may contact us using thecontact information provided in this Privacy Policy.

You have the right to lodge a complaint with theData Protection Authority, in particular in the Member State of your residence,place of work or place of an alleged infringement, if you consider that theprocessing of your personal data infringes the GDPR.

7.    Contact Us

If you have any questions about this Privacy Policyor our practices regarding the collection, use, or disclosure of personalinformation, you can contact us by visiting the Contact Us page on the Website, by email, or over thephone.

• By email: office@elgin-energy.com

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