Cyclone is committed to protecting the privacy of individuals’ personal information by complying with the Australian Privacy Principles set out in the Privacy Act 1988 (Cth).  This Policy describes how Arrium Limited (ABN 63 004 410 833) (Administrators Appointed) and its subsidiaries ("we", "our" or "us") handle personal information.  For details of our subsidiaries, please contact us or see the ‘Controlled Entities’ section of our latest annual report on  Nothing in this Privacy Policy is intended to limit our obligations or permitted handling of personal information under privacy laws.  For example, under the Privacy Act, we may rely on certain exemptions including in relation to employee records.

1. Collection of personal information - We may collect personal information about you in certain circumstances such as where you contact or transact with us.  We collect current and historical personal information including information about your name, contact details, identification, organisational affiliations, positions held, forms submitted, payment details and enquiry/complaint details.  We collect the information that you provide in your communications and transactions with us, including records of any contact we have with you by telephone, email or online.  We may also operate video and audio surveillance devices in our premises for purposes including security, training and dispute resolution.  We collect personal information directly from you as well as from third parties including public sources, our related companies, information service providers and the parties with whom we exchange information as described here.  

2. Use of personal information - The personal information that you provide to us may be used for business purposes relevant to our 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 us improve our product and services offering; marketing our products and services; market research; relationship management; and protecting our lawful interests.  We may not be able to do these things without your personal information.  For example, we may be prevented from delivering our products and services, communicating with you and/or improving our product and service offering.  We may contact you on an ongoing basis by telephone, email, SMS or other means regarding your account or, subject to any legal restrictions, for direct marketing.  If you do not wish to receive direct marketing messages you can "unsubscribe" in accordance with the unsubscribe procedure specified in the relevant message. 

3. Disclosure of personal information - We may exchange your personal information with our related companies, subcontractors, service providers and your representatives in the course of conducting our business.  The types of service providers we engage include those that assist us 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 Australia, USA, Japan, United Kingdom or other countries.  We may also exchange your personal information with third parties when undertaking joint promotions.  Your personal information may be disclosed to third parties transacting with Arrium in relation to our assets or businesses under an undertaking of confidentiality.  When disclosed to parties outside Australia, they will often still be subject to privacy and confidentiality obligations, where you agree to this Privacy Policy you acknowledge that: (a) privacy obligations may not always apply or may differ from Australian privacy laws; (b) we may not be accountable for the third party; (c) you may not be able to seek redress under the Privacy Act; and (d) the third party may be subject to foreign laws which might compel further disclosures of personal information (e.g. to government authorities).

4. Security and Confidentiality - We implement various security measures to protect the security and confidentiality of your personal information, including taking reasonable steps to destroy or de-identify information that we hold about you when it is no longer required.  We hold personal information electronically and in hard copy form, both at our own premises and with the assistance of our service providers. 

5. Online Activity – If you use and our other websites, mobile applications, social media profiles and online facilities (“Online Facilities”), we may record information such as the date and time of your use of our Online Facilities, the pages/sections accessed and any information downloaded.  This information is used for statistical, reporting, administration and maintenance purposes in relation to our Online Facilities.  Our Online Facilities may use ‘cookies’ from time to time.  Cookies are electronic files that allow our system to identify and interact more effectively with your device and software.  The cookie helps us to maintain the continuity of your browsing session and remember your preferences when you return.  In many cases this happens anonymously, however where you have clicked a link in an email we have sent you or you have logged in or provided personal information to our Online Facilities, we may associate the cookie with you.  You can configure your browser software to reject cookies however some parts of our Online Facilities may not have full functionality in that case.  If you are considering sending us any other personal information through our Online Facilities or other electronic means, please be aware that the information may be insecure in transit, particularly where no encryption is used (e.g. email, standard HTTP).  We are subject to laws requiring us to protect the security of personal information once it comes into our possession.  Our Online Facilities may contain links to other websites and online services.  We are not responsible for the privacy practices or policies of those sites and services.

6. Access, Correction and Further Queries - If you wish to find out more about our information handling practices, raise any privacy concerns, and/or you wish to view or request amendment of your personal information, please contact our Privacy Officer by emailing or calling +61 (02) 9239 6666.  We may need to verify your identity.  In the case of access and correction requests, please provide as much detail as you can about the particular information you seek, in order to help us locate it.  We will provide our reasons if we deny any request for access to or correction of personal information.  Where we decide not to make a requested correction to your personal information and you disagree, you may ask us to make a note of your requested correction with the information.  We take your privacy concerns very seriously.  Where you express any concern that we have interfered with your privacy, we will respond to let you know who will be handling your matter and when you can expect a further response.

7. Notification of Changes - This Privacy Policy will be amended and updated from time to time.  You will be notified of any changes to this Policy by an announcement on our website.  The date on the bottom of this page indicates when this Policy was last updated.

Last updated: 17 April 2014
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