1. Policy Introduction

Bellavista Resources Limited (Bellavista, us, our) is committed to protecting the privacy of individuals’ personal information. This Privacy Policy sets out the principles that Bellavista will follow in collecting, using, holding, disclosing and otherwise managing personal information.

“Personal information” is information or an opinion about an identified individual or an individual who is reasonably identifiable, whether true or not and whether the information or opinion is recorded in a material form or not.

Bellavista is bound by the Privacy Act 1998 (Cth) (Act) and the Australian Privacy Principles that are contained in that Act.

2. Collection of Personal Information

Bellavista may collect personal information about an individual in a variety of ways, including when an individual interacts with Bellavista in person or electronically, for example when an individual accesses our website.

Bellavista will only collect personal information about an individual where the information is reasonably necessary for one or more of our functions or activities. The kinds of personal information collected and held, how that information is collected and held and the purposes for which that information will be collected, held, used and disclosed will depend on the circumstances.

Examples of instances where personal information may be collected by Bellavista include collecting personal information:

• from shareholders for the purposes of enabling proper records to be kept and for reporting purposes;
• from individuals who enter into (or represent an organisation which enters into) service agreements, joint venture agreements or other transactions with Bellavista for the purpose of administering those agreements or transactions or for reporting purposes;
• about visitors to Bellavista’s premises for health and safety or security purposes;
• from and about individuals applying for employment with Bellavista for the purposes of assessing their application and undertaking hiring processes;
• about landowners with whom Bellavista may need to interact for business purposes; and
• from individual representatives of industry associations relevant to Bellavista’s business.

Examples of the kinds of personal information Bellavista may collect and hold include:

• name;
• address;
• phone number;
• fax number;
• email address;
• information about goods or services ordered, acquired or supplied;
• information from enquiries made;
• communications between Bellavista and an individual;
• for visitors and job applicants, health and biometric information where necessary for Bellavista’s health and safety or security procedures;
• for job applicants, qualifications, work and/or criminal history and membership of trade unions or professional associations; and
• credit card information.

Bellavista will take reasonable steps to ensure that the personal information that is collected, used or disclosed by it is complete and up to date. Bellavista will only collect personal information about an individual from that individual unless it is unreasonable or impractical to do so.

An individual may choose to interact with Bellavista anonymously or using a pseudonym, however, in certain contexts this may prevent Bellavista from continuing to interact with any such individual.

3. Use and Disclosure of Personal Information

At or before, or if that is not practicable, as soon as practicable after, the time that the personal information is collected, Bellavista will take reasonable steps to ensure that the individual is aware of the matters required by the Australian Privacy Principles, including:

• why the personal information is being collected;
• who else the personal information might be given to;
• the fact that this Privacy Policy contains information about how the individual is able to gain access to and correction of the information collected; and
• how to contact Bellavista, including to make a complaint.

If Bellavista collects personal information about an individual from someone else, Bellavista will take reasonable steps to ensure that the individual is aware that Bellavista has collected the information and of the above matters.

Bellavista will only use or disclose this personal information for:

• the purpose for which it was collected;
• any related (or in the case of sensitive information (as that term is defined in the Act), directly related) purpose for which it would reasonably be expected to be used or disclosed;
• a purpose required or permitted by law; or
• a purpose for which the individual has provided consent.

Examples of instances where Bellavista may disclose personal information about individuals to third parties include disclosure to:

• providers of services to Bellavista;
• government agencies and regulatory authorities;
• related bodies corporate of Bellavista or potential acquirers of Bellavista’s business or assets; and
• professional advisers of Bellavista.

Bellavista requires its service providers to keep the personal information confidential and not use it for any purpose other than performing those services.

Bellavista is unlikely to disclose personal information to overseas recipients.

4. Security of Personal Information

Bellavista will take reasonable steps to ensure that the personal information that it holds is protected from misuse, interference and loss and from unauthorised access, modification and disclosure.

Bellavista will also take reasonable steps to ensure that personal information it holds that is no longer necessary for the disclosed purpose is destroyed or permanently de-identified, subject to any legal obligation to keep the personal information for any required period of time.

5. Access to, Updating and Correcting Personal Information

At the request of an individual, Bellavista will, in most circumstances, provide access to an individual to any personal information that is being held by Bellavista about that individual.

There are certain circumstances where Bellavista will not provide an individual access to such personal information in accordance with the Act. These circumstances include where providing access would have an unreasonable impact on the privacy of others, where providing access would reveal commercially sensitive information about the organisation or where providing access would be unlawful.

An individual can seek access to, and update or correct, any personal information that is being held by Bellavista about that individual by contacting us here.  If Bellavista does not provide access as requested, or disagrees with a request to update or correct personal information, the individual making the request may make a complaint, which will be handled in accordance with the procedure set out below.

6. Amendment of Policy

Bellavista may amend this Policy from time to time, and the Policy (as amended) will be available on the Bellavista intranet and website and on request.

7. Cookies and Third Party Links

Bellavista’s website uses cookies and other tools to record and analyse traffic.  When individuals visit our website, these tools may record information about the visit including the individual’s IP address, pages viewed and information downloaded.  This information is used for analytics and improving our website and services.  Many internet browsers offer settings through which individuals can control the use of such tools, however blocking such tools may reduce the features of the website.

Bellavista’s website may contain links to third party websites.  Bellavista is not responsible for the content or policies, including privacy policies and practices, of such third party websites.  Individuals should refer to the privacy policies of such websites.

8. Direct marketing

If an individual consents, Bellavista may send (or allow third party partners to send) the individual marketing communications by SMS, email, post or social media.  An individual may opt out of such marketing communications at any time by contacting the Privacy Officer or using any mechanisms for unsubscribing provided in the communication.

9. Concerns, Queries and Complaints

If a person has any concern, query or complaint about:

• any personal information that may have been collected, used or disclosed or otherwise handled by Bellavista;
• this Privacy Policy; or
• a breach of the Australian Privacy Principles,

they are to be referred to the Privacy Officer.

The Privacy Officer can be reached at:

Bellavista Resources
Attn: Privacy Officer
GPO Box 2884, WEST PERTH WA 6872
[email protected]
T: +61 8 6383 7556

Bellavista takes complaints very seriously and the Privacy Officer will respond as soon as practicable after receiving written notice of the complaint.  The Privacy Officer will use reasonable endeavours to resolve the complaint within 30 days after receipt.  If an individual is not satisfied with the resolution offered by the Privacy Officer, the individual may request that the complaint be referred to the Chief Financial Officer or Company Secretary, who will use reasonable endeavours to review the complaint and the resolution offered by the Privacy Officer within 30 days after the complaint is referred to them.

If an individual is not satisfied with Bellavista’s handling of a complaint, the individual may wish to contact the Office of the Australian Information Commissioner using the contact details listed at www.oaic.gov.au/about-us/contact-us/.