Privacy

GreenSquareDC Pty Limited (ACN 656 101 861; ABN 18 656 101 861), its subsidiaries and affiliates in Australia (collectively referred to as GreenSquareDC) is a developer of data centre infrastructure. Please contact us for a full list of the companies which comprise GreenSquareDC and which are subject to this Privacy Policy.

1. Who this Privacy Policy applies to

This Privacy Policy applies to all individuals who interact with GreenSquareDC or whose information is provided to GreenSquareDC. Examples are:

• Clients and prospective clients
• Prospective employees or applicants
• Visitors to our websites
• Other individuals

2. Australian Privacy Principles

GreenSquareDC manages personal information in accordance with the Australian Privacy Principles (APPs) under the Privacy Act 1988 (Cth) (Privacy Act).

3. What kinds of personal information does GreenSquareDC collect and hold?

GreenSquareDC may collect personal information directly from you, or by other means such as from website enquiries, client or employee onboarding, marketing initiatives, recruitment. You can always decline to give GreenSquareDC any personal information we request, but that may mean we cannot provide you with the services you have requested.

The kinds of information we may collect include:

• your name, e-mail, postal address and other contact details
• information about your employer or an organisation who you represent
• your professional details
• any additional personal information you provide to us, or authorise us to collect, as part of your interaction with GreenSquareDC
• your qualifications and work history
• tax file number and superannuation information
• information necessary to conduct background checks
• in an emergency, health information

GreenSquareDC’s websites use “cookies”, which collect information such as:

• your device type
• browser type
• IP address
• pages you have accessed on our websites and on third-party websites

In the case of children:

• GreenSquareDC does not authorise children under 15 years of age to provide personal information to GreenSquareDC and does not knowingly collect personal information about children.
• Where we become aware that we possess personal information about a child, we will delete such information.

4. How and why does GreenSquareDC collect and use your personal information?

Reasons why we collect personal information include:

• to carry out our business and assess and manage our clients’ needs
• administrative functions such as entering into contracts with you
• responding to requests for information and other general inquiries
• researching, developing and expanding our facilities and services
• informing you of our activities, facilities and services
• recruitment processes
• responding to enquiries and complaints
• market research and innovation
• informing you about our services, upcoming promotions and events

Ways we collect personal information include:

• directly from you by phone, email, internet or social media, or in person
• from affiliated and related companies
• third-party suppliers and contractors who assist us to operate our business

5. Can you deal with GreenSquareDC anonymously?

Individuals are entitled to remaining anonymous or use a pseudonym in their dealings with us where it is lawful and practicable (for example, when making a general enquiry). However, if we do not collect personal information about you, you may be unable to utilise our services.

If visiting our websites, you may use the settings in your browser to control how your browser deals with cookies, for the purposes of anonymising yourself.

6. How does GreenSquareDC hold information?

GreenSquareDC holds information:

• secure electronic databases (including on our premises, and with trusted third-party storage providers based in Australia and overseas)
• in documents physically secured, such as through locks and security systems at our premises
• using computer and network security, such as firewalls, user identifiers and passwords

Our websites do not necessarily use encryption or other technologies to ensure the secure transmission of information via the internet. Users of our websites are encouraged to exercise care in sending personal information via the internet. We take steps to destroy or de-identify information that we no longer require. We may store and process personal information using third-party service providers, including customer relationship management (CRM) platforms such as HubSpot. This may involve disclosure of personal information to overseas recipients, including but not limited to the United States and other countries where HubSpot maintains data centres.

We take reasonable steps to ensure that any overseas recipient complies with the Australian Privacy Principles or equivalent privacy protections.

7. How does GreenSquareDC use and disclose personal information?

We may disclose personal information to third parties for:

• providing our services, including contractors and service providers used for data processing
• data analysis
• customer satisfaction surveys
• information technology services and support
• website maintenance or development
• printing, archiving, mail-outs, and market research
• administering billing and payments and debt recovery
• planning, managing, monitoring and evaluating our services
• quality improvement activities
• statistical analysis and reporting
• training staff, contractors and other workers
• risk management and management of legal liabilities and claims (for example, liaising with insurers and legal representatives)
• responding to enquiries and complaints regarding our services
• obtaining advice from consultants and other professional advisers
• responding to subpoenas and other legal orders and obligations

Third parties to whom we have disclosed your personal information may contact you directly to let you know they have collected your personal information and to give you information about their privacy policies.

Personal information may also be shared between related and affiliated companies of GreenSquareDC, located in Australia and overseas.

We may use and disclose your personal information for other purposes explained at the time of collection or otherwise as set out in this Privacy Policy.

8. Does GreenSquareDC disclose your personal information overseas?

GreenSquareDC is a global organisation and works with clients, service providers, sponsors and commercial interests worldwide. Your personal information may be disclosed overseas.

Unless we have your consent, or an exception under the APPs applies, we will only disclose your personal information to overseas recipients where we have taken reasonable steps to ensure that the overseas recipient does not breach the APPs in relation to your personal information.

Where your information is disclosed to overseas recipients, those recipients are likely to be located in countries in the regions in which GreenSquareDC and its related entities and affiliates operate.

9. How can you access or seek correction of your personal information?

You are entitled to access your personal information held by GreenSquareDC on request. To request access to your personal information, please contact our privacy officer (Privacy Officer) using the contact details set out below. You will not be charged for making a request to access your personal information, but you may be charged for the reasonable time and expense incurred in compiling information in response to your request.

You are entitled to request correction of information about you, which you consider is inaccurate, out-of-date, incomplete, irrelevant or misleading. After receiving a request from you, we will take reasonable steps to correct your information.

We may decline your request to access or correct your personal information in certain circumstances in accordance with the APPs. If we do refuse your request, we will provide you with a reason for our decision and, in the case of a request for correction, we will include a statement with your personal information about the requested correction.

10. Making a complaint

You may contact GreenSquareDC at any time if you have any questions or concerns about this Privacy Policy or about the way in which your personal information has been handled.

You are entitled to make a complaint about privacy to the Privacy Officer at the contact details set out below.

The Privacy Officer will first consider your complaint to determine whether there are simple or immediate steps which can be taken to resolve the complaint. We will generally respond to your complaint within a week. If your complaint requires more detailed consideration or investigation, we will acknowledge receipt of your complaint within a week and endeavour to complete our investigation into your complaint promptly. We may ask you to provide further information about your complaint and the outcome you are seeking. We will then typically gather relevant facts, locate and review relevant documents and speak with individuals involved.

If you are not satisfied with our response to your complaint, or you consider that GreenSquareDC may have breached the APPs or the Privacy Act, a complaint may be made to the Office of the Australian Information Commissioner (OAIC). The OAIC can be contacted by telephone on 1300 363 992 or by using the contact details on the OAIC website.

11. How changes are made to this privacy policy?

GreenSquareDC may amend this Privacy Policy from time to time, with or without notice to you. We recommend that you visit our website regularly to keep up to date with any changes.

12. How can you contact GreenSquareDC?

The contact details for GreenSquareDC are:

• GreenSquareDC Privacy Officer
• Address: Level 3, 143 Macquarie Street, Sydney NSW 2000
• Email address: privacy@greensquaredc.com