Last revised and updated in March 2021

TM Insight Operations Pty Ltd ACN 638 506 340 trading as TMX Global and its related entities (collectively referred to as “TMX Global”, “we”, “us” or “our”) recognise the importance of your privacy and are committed to the protection of your Personal Information in accordance with the Privacy Act 1988 (Cth) as updated or amended from time to time (“Privacy Act”) and the Australian Privacy Principles set out in the Privacy Act.

1. Application of our Privacy Policy

This Privacy Policy describes the way in which TMX Global collects, holds, uses and discloses your Personal Information. This Privacy Policy also covers how TMX Global makes the Personal Information it holds available for access and correction by you and how you can make a complaint. This Privacy Policy must be read together with any other privacy statement that TMX Global may provide to you when it collects your Personal Information or provides its services (“Privacy Statement”).  If there are any inconsistencies between this Privacy Policy and a Privacy Statement, the terms of the Privacy Statement will prevail. By using or accessing our website https://tmx.global/ (“Website”) and any services operated or made available to you by TMX Global (“TMX Global Systems”), whether using your mobile phone, personal computer, or any other means, or by otherwise providing Personal Information to us, you are taken to have agreed to the provisions of this Privacy Policy and you consent to the collection, use and disclosure of your Personal Information in accordance with this Privacy Policy and any Privacy Statement we may give to you. To avoid doubt, this Privacy Policy does not apply to information about or relating to a company or other entity that is not an individual.

2. What is Personal Information?

Personal Information is defined in section 6 of the Privacy Act and means information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information is true or not, and whether recorded in a material form or not.

3. What kinds of Personal Information we collect?

We only collect Personal Information about you that is necessary to provide our services to you and to perform our functions and activities. The categories of Personal Information which TMX Global may collect and hold includes the following types of Personal Information:

• contact information (including full name, email address, mailing address and telephone/mobile phone number);
• information provided in connection with the use or purchase of any services supplied by TMX Global; and
• information provided by you through TMX Globalrelated communication channels such as social media sites managed or owned by TMX Global, telephone and/or email support, customer service or customer surveys.

4. When and how we collect information?

We collect Personal Information in a number of ways, including:

• directly from you, including when you:
  • buy or use our services;
  • when you provide information online, by phone, in application forms or in agreements;
  • request information about us or our services;
  • provide feedback to us;
  • contract with us; and
  • contact us by our Website, telephone, facsimile, email, post or in person;
• from an associated entity of TMX Global; and
• from social media sites managed, used or owned by TMX Global.

5. Information collected via our Website

TMX Global will not collect any Personal Information from you when you use our Website except when you knowingly provide it or as otherwise described below. For example, TMX Global may collect Personal Information from you when you:

• complete an online form on our Website; and/or
• complete one or more of our surveys; and/or
• otherwise correspond with TMX Global.

Cookies When you use our Website, the relevant server may cause a small data file called a “cookie” to be saved to your computer’s memory. Cookies are pieces of information that may be transferred to your computer’s memory when you visit a website.  Most web browsers are configured to accept cookies, however you may configure your browser to reject cookies or notify you when a cookie is sent.  If you reject all cookies, you may not be able to access our Website.  The use of cookies on its own does not identify an individual but it does provide us with statistics on how people use our Website and helps us to know what they find interesting and useful on our Website.  We do not link this information back to your identity or other information that you have provided to us.  We do not store any information in cookies that identifies you. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org. How TMX Global uses cookies? TMX Global tracks visitor and prospect activities on our website and landing pages by setting cookies on their browsers. Cookies are set to remember preferences (like form field values) when a visitor returns to our site. TMX Global (Pardot) cookies don’t store personally identifying information, only a unique identifier. Types of Cookies used There are two cookies used

• visitor_id
• pi_opt_in

visitor_id The visitor cookie, set by the tracking code on website visitors. This is shown as “visitor_id” followed by the unique identifier for that visitor, eg. “visitor_i6780”. You can see an example below. No personally identifiable information is stored in the cookie, and the visitor remains anonymous. pi_opt_in If Tracking Preferences Opt-in banner is enabled, and: The visitor clicks ‘yes’: they will be tracked The visitor clicks ‘no’: they won’t be tracked The visitor does nothing: they won’t be tracked

6. Use of Personal Information

TMX Global uses the Personal Information it collects about you to provide services and for our business functions and activities, which may include the following:

• to provide you with information or services you have requested;
• to communicate with you;
• to operate, protect, administer, maintain and manage the TMX GlobalSystems;
• to personalise and customise your experiences on our Website or any TMX Global System;
• to screen for potential risk or fraud;
• to help TMX Global research the needs of its customers;
• to conduct research for the purposes of improving existing services or creating new products or services;
• to provide you with information, marketing or promotional messages or advertising which we believe may be of interest to you, including information on our services or activities and information on third parties (who may or may not have a relationship with us);
• to comply with regulatory or other legal requirements;
• for purposes related to the employment of our personnel and providing internal services to our staff; and
• for any other purpose communicated to you at the time that the Personal Information was collected or for which you provided your consent.

TMX Global may use your Personal Information for a secondary purpose if that secondary purpose is related to the purposes listed in the previous paragraph, and you would reasonably expect us to use it for that secondary purpose, if we have your consent or if otherwise provided for under the Privacy Act. TMX Global may use your Personal Information to provide you with direct, targeted, or other marketing materials on an ongoing basis. Subject to and in accordance with applicable law, TMX Global may provide you with these materials by telephone, electronic messages (e.g. email), through social media sites managed, used or owned by TMX Global and other means. TMX Global will only provide you with direct marketing materials where you would reasonably expect us to, or if you consent to receive direct marketing materials. We will seek your consent to provide you with direct marketing materials if we have obtained your Personal Information from a third party.  Direct marketing communications may include promotional material about TMX Global or may relate to the services TMX Global, and our related entities provide and other products and services which may be of interest to you. You may opt out of receiving direct marketing material by contacting us in any of the ways specified in the direct marketing materials or as set out in the “Contact us” section below. Generally, we will only collect and use your Personal Information in accordance with this Privacy Policy.  In the event that we collect or use Personal Information in ways other than as stated in this Privacy Policy, we will ensure that we do so in accordance with the Privacy Act.

7. Disclosure of Personal Information

Who we may disclose Personal Information to Depending on the nature of your engagement with TMX Global, we may disclose your Personal Information to our shareholders, officers, employees, contractors, consultants, advisers, agents and related bodies corporate of TMX Global, third parties that provide products and services to or through TMX Global or our Website or TMX Global Systems, directly to you (at your request), suppliers and other third parties, or otherwise as required by law. TMX Global may also disclose your Personal Information to our Website host or software application providers in certain limited circumstances, for example when our Website experiences a technical problem or to ensure that it operates in an effective and secure manner. We may also share non-personal, de-identified and aggregated information for research or promotional purposes.  We will not sell your Personal Information to third parties for marketing purposes. Unless otherwise specified in this Privacy Policy, TMX Global or our Website host will not disclose any of your Personal Information to any other organisation unless the disclosure is required by law or is otherwise permitted by the Privacy Principles. Overseas disclosure We use every reasonable step to ensure data is stored onshore (within Australia).  However, we cannot guarantee that data never leaves Australian shores due to technical limitations with internet routing systems. However, all data is encrypted in transit.  We may also share data with our related bodies corporate that are located in Singapore and New Zealand. We will only consciously transfer your Personal Information overseas if:

• we reasonably believe that the recipient of the information is subject to a law or a contract which effectively upholds privacy principles substantially similar to the privacy principles set out in the Privacy Act;
• you have consented to the transfer; or
• we are otherwise required or authorised by law.

By consenting to provide us with Personal Information (whether by using the TMX Global Systems, through a Privacy Statement or otherwise), you consent to the disclosure of your Personal Information to third parties who reside outside Australia and, if you are a European Union (EU) citizen, to third parties that reside outside the EU.  Where the disclosure of your Personal Information is solely subject to Australian privacy laws (and not subject to the European Union’s General Data Protection Regulation), you acknowledge that we are not required to ensure that those third parties who reside outside Australia comply with Australian privacy laws.

8. Employee records

Employee records are not generally subject to the Privacy Act.  As such this policy may not apply to the handling of officer, employee, contractor or consultant information.  Please contact us directly for information about these information handling practices.

9. Access to Personal Information

How you can access your Personal Information You have a right to access your Personal Information.  If you would like to do so, please direct your request to TMX Global by email or post using the contact details set out in the “Contact us” section below. Sometimes, we may not be able to provide you with access to all of your Personal Information.  This may include where giving access would be unlawful or would have an unreasonable impact on the privacy of other individuals.  If we refuse you access, we will tell you why. We reserve the right to charge a fee for searching for and providing access to your Personal Information (but not for the request itself).  We may need to verify your identity as part of this process. Accuracy of Personal Information We will take reasonable steps to ensure that the Personal Information that we hold is accurate, up-to-date and complete. You have a right to request that your Personal Information be corrected.  If you think that Personal Information we hold about you is not accurate, complete and up-to-date, please contact us using the contact details set out in the “Contact us” section below and we will take all reasonable steps to correct the information.

10. Security of Personal Information

Precautions taken We understand the importance of protecting your Personal Information.  We take all reasonable precautions to protect the Personal Information we hold about you from misuse, interference and loss, and from unauthorised access, modification or disclosure. TMX Global aims to keep your Personal Information secure and up to date. We will comply with our obligations under the Privacy Act in relation to any Personal Information that we handle, including information which is held on any TMX Global Systems. Personal Information that is held by TMX Global in hard copy is stored securely on its premises and is only disclosed or used for the purposes described in this Privacy Policy. Links The TMX Global Systems may link to other websites which are outside our control, and other websites outside our control may link to TMX Global Systems.  We are not responsible for the protection and privacy of any Personal Information which you provide while you are visiting or using those other sites, online products or services.  Those websites are not governed by this Privacy Policy.  You should exercise caution and review the privacy policies applicable to those other sites. How long we keep your Personal Information for TMX Global will keep your Personal Information only for as long as required for the purposes described in this Privacy Policy and otherwise as required by Australian law. Where we no longer need to keep your Personal Information in accordance with this Privacy Policy, we will take reasonable steps to destroy or de-identify your Personal Information. If you wish to have your Personal Information destroyed or de-identified, please let us know and we will take reasonable steps to do so (unless we need to keep it for legal, auditing or internal risk management reasons).

11. Contact us

If you have any questions or would like further information about our privacy policies or practices, please contact us by any one of the following means:

• Email: admin@tmx.global
• Telephone: +61 3 9908 3040
• Post: 387 City Road, South Melbourne, Victoria 3205

12. Data breaches or complaints

If you wish to report a data breach or make a complaint about the way we have collected, used, held or disclosed your Personal Information, please contact us using the contact details listed in the “Contact us” section above. To assist us in helping you, please gather all supporting documents about the matter of complaint, think about the questions you want answered and decide on what you want us to do. We will use the information you provide to investigate and respond to your data breach report or privacy complaint.  We aim to resolve all complaints as quickly as possible.  Some complaints are resolved within weeks, but more complex complaints may take longer.  You may withdraw your complaint at any time. If we do not resolve your complaint to your satisfaction and no other complaint resolution procedures are agreed or required by law, we will inform you that your complaint may be referred to the Privacy Commissioner for further investigation and will provide you with the Commissioner’s contact details.

13. Changes to our Privacy Policy

We reserve the right to change our Privacy Policy at any time.  We will notify you about changes to this Privacy Policy by posting an updated version on our Website.