Privacy Policy

This Privacy Policy sets out how GFG Alliance (defined below) and any entity owned or controlled by GFG Alliance (together we, us or our) collect, use, disclose and hold personal information. We recognise the importance of protecting the privacy and the rights of individuals in relation to their personal information. This document is our Privacy Policy and it tells you how we collect and manage your personal information.

This Privacy Policy applies to GFG Alliance and any entity owned or controlled by GFG Alliance, which means:

• Liberty Primary Metals Australia (ACN 631 112 573) and its subsidiaries; and
• Liberty Infrabuild Limited (ACN 631 112 108) and its subsidiaries.

GFG Alliance may update this Privacy Policy from time to time. Any changes will be published on our website (https://www.gfgalliance.com/). Your continued use of our website or services, requesting assistance or the provision of further personal information to us after this Privacy Policy has been revised will constitute your acceptance of the revised Privacy Policy.

Applicable laws

We are bound by the Privacy Act 1988 (Cth) (Privacy Act) in relation to "personal information", which is defined as information or an opinion about an identified individual or an individual who is reasonably identifiable. We respect your right to privacy under the Privacy Act and we comply with all of the requirements in respect of the collection, management and disclosure of your personal information.

GFG Alliance will process personal information belonging to a European resident (EU personal information) in compliance with applicable European data protection laws, including the General Data Protection Regulation 2016/679, the Data Protection Act 2018 (UK) and any implementing laws in relevant European Member States and the United Kingdom (EU Data Protection Law(s)).  GFG Alliance will only process EU personal information in accordance with an EU Data Protection Law when an EU Data Protection Law is applicable.

Collection of personal information

The types of personal information we collect may include your name, date of birth, contact details (such as your residential address, business address, email address and contact telephone/mobile numbers), payment and bank account details, and the content of any communication with us including the details of any enquiry or complaint.

If you are a job applicant, we may also collect your contact details, date of birth, whether you have a right to work in the country in which you have applied for a job, your application for employment, information about your qualifications and employment history and results of any interview and assessments.

We also collect credit and financial related information (your information or that of your business), such as income, expenses, financial assets, liabilities and repayment history. Credit information is exchanged between credit and finance providers and credit reporting bodies.

We may collect sensitive information (including biometric and health information) if it is reasonably necessary for our functions and activities with your consent.

In addition, with the intent of promoting equal employment opportunities as permitted or required by local law, we may also gather additional sensitive information regarding applicants, including their nationality, racial and/or ethnic origin.

Where we have provided you with a vehicle, equipment or device that have the functionality to monitor or record geographical location, we may also collect other personal information such as location data. GFG will only use tracking devices in accordance with the law, and in accordance with our Workplace Surveillance policy.

We also collect information on how you use this website to help us develop and improve it, including details of your domain name and Internet Protocol (IP) address, operating system, browser version, cookie details, how long you stayed on a page, the route you took to navigate through the pages and the website that you visited prior to accessing our site.  Please note that this information is anonymous and only used in the aggregate - it is not personal information associated with you as a specific person.

How we collect personal information

We generally collect personal information directly from you where this is reasonable and practical, but may occasionally collect personal information from third parties including public sources, our related companies, share registry service providers, information service providers, recruiters or your nominated referees if you are a job applicant, and credit reporting bodies.  We may collect this information when:

• you set up an account with us or use any of our products or services;
• you communicate with us through correspondence, email, phone enquiries, our website or our social media channels; or
• you apply for employment with us.

If you do not provide the information requested by us, we may not be able to:

• provide you with our products or services;
• communicate with you;
• improve our product and service offerings; or
• progress your application for employment with us.

If you provide personal information to us about someone else, you must ensure that you are entitled to disclose that information to us and that, without us taking any further steps required by privacy laws, we may collect, use and disclose such information for the purposes described in this Privacy Policy.  For example, you should take reasonable steps to ensure the individual concerned is aware of the various matters detailed in this Privacy Policy.  The individual must also provide the consents set out in this Privacy Policy in respect of how we will deal with their personal information.

How we use personal information

We will use your personal information for the purpose for which it has been collected, reasonably related secondary purposes, any other purpose you have consented to, and any other purpose permitted under the Privacy Act.  This may include using your personal information for the following purposes:

• to provide our products and services;
• to assess and respond to your enquiries, requests and applications, including resource planning and recruitment;
• to provide access to, monitor and develop our website;
• to develop and improve the products and services we offer, including to conduct market research and statistical analysis in relation to our business;
• to monitor, analyse and audit the performance of employees and contractors, and conduct organisational network analysis, including through analysis of internal email traffic and content;
• to monitor and conduct investigations and audits to prevent, detect and respond to any fraud or crime, or suspected fraud or crime;
• to manage our relationship with you;
• to fulfil your orders and otherwise carry out obligations arising from any contracts entered into between you and us; and
• to carry out screening of all applicants who we intend to make an offer of employment and prior to any offer being confirmed, to verify information that an applicant provided during the recruitment process.

If you do not provide us with the personal information described above, some or all of the following may happen:

• we may not be able to provide our products and services to you, either to the same standard or at all;
• we may not be able to provide you with information about products and services that you may want, including information about special promotions;
• if you are applying for a role with us, we may not be able consider your application for the role (for example, for employment or engagement as a contractor) or provide you with any benefits or otherwise administer our employment or contracting relationship with you; or
• we may be unable to tailor the content of our websites to your preferences and your experience of our websites may not be as enjoyable or useful.

How we disclose personal information

We will disclose your personal information for the purpose for which it has been collected, reasonably related secondary purposes, any other purpose you have consented to, and any other purpose permitted under the Privacy Act.  This may include disclosing your personal information to:

• our service providers and subcontractors including marketing agencies, logistics companies, printing and postal services, call centres, mail houses, website developers, cloud storage providers, data analytics providers that assist us with archiving, auditing, accounting, customer contact, legal, consulting, banking, debt collection, data processing and data analytics, market research, insurance, website or technology services;
• credit reference agencies, debt collection agencies, fraud prevention agencies, security agencies, financial institutions, emergency services, crime prevention agencies and telecommunications companies, for the purposes of fraud prevention, debt collection, credit management and emergency services and crime prevention;
• anyone acting on your behalf;
• our professional advisors and consultants, accountants, lawyers and auditors;
• any of our employees, related companies and business partners;
• anyone who is considering acquiring an interest in our assets or businesses (or any part of them);
• if you are applying to work with us, your referees; organisations that conduct background, competence and psychometric tests; and any relevant government agencies or departments; and
• respond to subpoenas, judicial processes or legitimate requests by law enforcement officials or government agencies or departments.

We may from time to time transfer personal information outside Australia to countries whose privacy laws do not provide the same level of protection as Australia's privacy laws, including to New Zealand, USA, Japan, United Kingdom, USA or other countries.

By providing us with your personal information, you agree to us disclosing your information to entities located outside Australia and we will take such steps as reasonable to ensure that any overseas recipient complies with Australian privacy laws in relation to your information.  You agree that we will not remain accountable for the information once it is disclosed overseas, and you will not be able to seek redress against us under the Australian privacy law in the event of any breach, unless we have breached the Privacy Act.

Protection of personal information

We take reasonable steps to protect the personal information we hold from misuse, interference, loss and unauthorised access, modification or disclosure. Some of the ways we do this include:

• confidentiality obligations imposed on our employees;
• document storage security policies;
• security measures for access to our systems;
• only providing access to personal information to a person who is verified to be able to receive that information;
• controlled access to our buildings; and
• and electronic security systems, such as firewalls and data encryption.

We hold personal information electronically and in hard copy form, both at our own premises and with the assistance of our service providers.

Please be aware that, although we take steps to create a secure environment for your personal information, we cannot guarantee the security of any personal information you transmit online.  We will make reasonable attempts to notify you if there is a data breach involving your personal information which may result in serious harm, such as identity theft.

Please note that you are responsible for keeping your password secure and you should not disclose it to anyone (unless you want to authorise them to access your account and incur charges on your account).

Access to and correction of personal information

To find out what personal information we have collected about you, please email us at privacy.officer@gfgalliance.com.au.  There may be situations where we are not required to provide you with access to your personal information, such as where the request relates to an existing or anticipated legal proceeding, or if your request is vexatious.

If you become aware of any inaccuracies in the personal information you have provided to us, you must notify us as soon as possible and we will take reasonable steps to ensure it is corrected.  We will generally rely on you to assist us in informing us if the information we hold about you is inaccurate or incomplete.

Credit related information

This section applies in addition to (and without limiting) the other parts of this Privacy Policy in connection with all trading and customer accounts with us.  If you are an individual credit applicant or customer of ours or if you are a guarantor for another credit customer (eg, a company you represent), we may collect consumer credit-related personal information about you.  The types of credit-related personal information we collect includes your name, sex, date of birth and three most recent addresses; driver’s license number; employer; amount and type of credit you have applied for; credit limits; terms relating to credit arrangements; confirmation of previous information requests to credit reporting bodies (CRBs) made by other credit providers, mortgage insurers and trade insurers; details of your current and previous credit providers; start and end dates of credit arrangements; permitted payment default information including information about related payment arrangements and subsequent repayment; any credit provider’s opinion that you have committed a serious credit infringement (acted fraudulently or shown an intention not to comply with your credit obligations); information about court judgments against you; publicly available information about your credit worthiness; insolvency information from the National Personal Insolvency Index; and any credit score or credit risk assessment indicating a CRB’s or credit provider’s analysis of your eligibility for consumer credit.

Credit information from third parties

The credit information we collect may include information about your arrangements and applications with other credit providers as well as with us.  We may collect credit-related personal information directly or indirectly from third parties including the CRBs listed below; records published by Australian Courts; and other credit providers (including through means such as credit references).  We may also collect credit-related personal information directly or indirectly from you or an authorised representative assigned by your organisation, including when you or the authorised representative within your organisation applies for a commercial credit facility with us; when you as a director of a company, owner of the business or in your own capacity as an individual, provide personal guarantees as collateral for such a credit facility; when you or your organisation request an increase in an existing credit facility and we require you to complete an application to facilitate such a request; or when you request access to, or correction of, your credit-related personal information.

Our CRBs include: (1) Veda Advantage, PO Box 964 North Sydney 2059, www.mycreditfile.com.au, 1300 762 207; (2) Dun & Bradstreet, Level 7, 479 St. Kilda Road Melbourne 3004, www.dnb.com.au, pacaustral@dnb.com.au, 1300 734 806;(3) Experian, GPO Box 1969, North Sydney NSW 2060, www.experian.com.au, 1300 784 134; (4) Tasmanian Collection Service, 29 Argyle Street, Hobart, www.tascol.com.au, enquiries@tascol.com.au, (03) 6213 5555.

You can contact these credit reporting bodies or visit their websites to see their policies on credit-related personal information, including details of how to access or correct your credit-related personal information they hold. You can also request credit reporting bodies not to use your credit information to determine your eligibility to receive direct marketing from credit providers or not to use or disclose your credit information if you have been or are likely to be a victim of fraud.

Use and disclosure of credit-related personal information

We use credit-related personal information to (among other things) determine a credit applicant’s (company or individual’s) eligibility to qualify for, or request an increase to, a commercial credit facility with us; determine the strength of an individual’s offer to act as a guarantor in support of a commercial credit facility being provided or an application for credit that has been submitted; manage the credit facility, guarantee, account and our relationship with you effectively, including dealing with overdue debts, verifying your identity, maintaining and updating records and producing our own assessments and ratings of your credit worthiness; assist a CRB to maintain records in relation to your credit worthiness; and enable debt collection agents and/or solicitors to positively identify and recover any unpaid debts referred to them by us. We may not be able to do these things without your personal information.  We may disclose your credit-related personal information (including defaults and serious credit infringements) to CRBs for this purpose. CRBs may disclose those records to third parties as permitted by law, including to other credit providers conducting their own credit assessment processes.

Queries and complaints in relation to credit-related personal information

If you request access to, or correction of, credit-related personal information that is held by a CRB or another credit provider, we will endeavour to consult these businesses for a response.  You can also contact us using the contact details provided below if you wish to view or request amendment of your credit-related personal information. If you submit a complaint in relation to our collection, use or disclosure of credit-related personal information, we will endeavour to acknowledge receipt of your complaint, investigate and consult with any relevant associated entities (eg, a CRB) within applicable legally proscribed time limits.  If we believe that we will not be able to resolve your complaint or access or correction request within the proscribed time limits, we will notify you of the delay and the expected timeframe to resolve the matter.

Marketing

We may contact you from time to time by telephone, email, SMS or other means regarding your account or for marketing purposes if we have obtained your consent to contact you for marketing purposes.

If you no longer wish to receive marketing or promotional information from us and our affiliates and partners, you can unsubscribe at any time by following the unsubscribe procedure specified in our relevant message.

Browser Cookies

Browser cookies are small pieces of text stored by your Internet browser on the hard drive of the computer you are using to access this website.  This website uses cookies to connect you and the information you have provided in order to provide you with personalized content and a better experience when you return.  Most Internet browsers automatically accept cookies, although you can choose not to.  If you disable browser cookies from your browser, you will not be able to create a shopping basket or place an order.  For further information about managing and disabling browser cookies, you should refer to your Internet browser's help section or user guide.  There are also many resources on the Internet regarding browser cookies.

Links to other websites

This website may provide access to third-party websites by linking to them.  This website is not responsible for the privacy practices (including data protection and cookies), content or security of linked websites.

Retention and destruction of personal information  

We will retain personal information in accordance with our Document Retention Standard.

Within a reasonable period of time after we no longer reasonably require your personal information under an Australian law, order of a court or tribunal or business purposes, we will either:

• destroy the records containing your personal information; or
• render your personal information non-identifying so that it can no longer be used to identify you.

Contact details and complaints

If you have any complaints regarding our privacy practices, please contact us at:

privacy.officer@gfgalliance.com.au

We will use reasonable endeavours to respond to you within 30 days.

If you are dissatisfied with the outcome of your complaint, or the way the complaint was handled, then you may contact the Office of the Australian Information Commissioner.

Website: www.oaic.gov.au

Phone: 1300 363 992

Last updated - September 2024