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Privacy Policy

1. About this Privacy Policy

Protecting your privacy is very important to Imagion Biosystems Limited ACN 616 305 027 and its subsidiaries (‘Imagion’ or ‘we’ or ‘us’). We are committed to maintaining the security of all personal information provided to us, whether by shareholders, individuals with whom we do business, visitors to and users of our websites or otherwise. We comply with the Australian Privacy Act 1988 (Cth) and applicable European data protection regulations, in respect of the collection, management and disclosure of your personal information.

This Privacy Policy details how we collect, use and manage your personal information, and how to contact us if you have any queries about our management of your personal information.

For the purposes of this Privacy Policy and applicable data protection and privacy laws:

  • “personal information” means information which identifies you, or from which you can reasonably be identified, such as your full name or name and postal address.
  • Imagion is considered the “data controller” in respect of the personal information that it collects, uses and manages in connection with this Privacy Policy.

By providing your personal information directly or indirectly you accept the terms of this Privacy Policy. Providing your personal information indirectly includes via one of our service providers or a person authorised by you to provide your personal information.

2. Whose information do we collect?

In the course of our business, we may collect personal information from a range of individuals in the context of our business activities, including:

  • representatives of our suppliers, service providers, customers, sponsors and business partners;
  • our shareholders;
  • our employees and contractors;
  • industry association representatives;
  • users of our websites; and
  • job applicants.

We will only collect personal information about you by lawful and fair means and not in an unreasonably intrusive manner.

3. What information we collect

We collect personal information from you where it is relevant for our purposes. The types of personal information we may collect and hold varies depending on the nature of our interaction with you and may include the following:

If you are a shareholder:

  • We may collect your identifying and contact information such as your name, address, date of birth, contact details, tax file number (TFN) and details of security holdings in Imagion.
  • Information such as your bank account details and TFN may also, or instead, be collected by our share registry (Boardroom Pty Limited). Please refer to their privacy policy for further details:

If you are an employee, contractor or candidate for employment, we may collect information relating to your employment history, working eligibility rights, suitability for the role you are applying for, and your referee details.

If you are a representative of our suppliers, service providers, customers, sponsors and business partners, we may also collect information on:

  • details of the products and services you have purchased from us or which you have enquired about, together with any additional information necessary to deliver those products and services and to respond to your enquiries;
  • marketing preferences, including the type of marketing materials you wish to receive and the method of delivery (email, SMS, direct mail, or other);
  • responses to customer satisfaction, service development, quality control and research surveys and similar activities; and
  • information you provide to us through our customer surveys or visits by our representatives from time to time.

If you use our website, we may collect certain standard information that is sent by your browser to our website. This may include technical information, such as your IP address, browser type, operating system, language, time zone setting, access times and any referring website addresses. See the section headed ‘Online and digital services’ below for further information.

We may collect information you voluntarily supply to us, such as your name, email address, location, telephone number and preferred means of communication, for purposes such as subscribing to our news alerts or requesting further information from us, including through the contact us form available on our website.

4. How do we collect your personal information?

Normally, we collect personal information about you directly from you. We may collect information from you when you:

  • access and interact with our website (See the section headed ‘Online and digital services’ below for further information).
  • apply to invest in Imagion;
  • apply for employment with Imagion;
  • request information from us or from our service providers;
  • telephone, email or write to us or our service providers;
  • attend our presentations to investors, potential investors and financial planners; or
  • subscribe to receive information through our website.

We may also collect your personal information from third parties including public sources, your adviser(s), agents, referrers, brokers and service providers. However, we will only collect information from third parties where it is not reasonable and practical to collect the information from you directly.

If someone other than you provides us with personal information about you that we did not ask for, or you provide us with unsolicited personal information, we will only hold, use or disclose this information if we determine that we could have collected this information from you had we asked for it. In this circumstance we will take all reasonable steps to notify you of the collection of that information. If we could not have collected this personal information, we will lawfully de-identify or destroy that personal information.

5. How we hold your personal information

We may hold your personal information in hard copy (paper) or electronic form.

If you provide information to us electronically, we retain this information in our computer systems and databases. Information held in electronic form is generally held on servers controlled by us or on servers controlled by third parties under contractual arrangement with us. We use physical security, password protection and other measures to ensure that personal information stored in electronic form is protected from misuse, interference and loss; and from unauthorised access, modification and disclosure.

Personal information collected in hard copy (paper) form may be converted to electronic form. Information held in paper-based form is generally securely stored at our premises or premises of our service providers. We use physical security and other measures to ensure that personal information in hard copy form is protected from misuse, interference and loss; and from unauthorised access, modification and disclosure.

6. Use of information

We will only use personal information for the purposes for which it was given to us, or for purposes which are directly related to the provision of our services. The main purposes for which we collect, hold and use your personal information are:

  • to provide products and services to you and to send communications requested by you;
  • to answer enquiries and provide information or advice about existing and new products or services;
  • for marketing (including direct marketing), planning, product or service development, quality control and research purposes;
  • to update our records and keep your contact details up to date;
  • to comply with any law, rule, regulation, lawful and binding determination, decision or direction of a regulator, or in co-operation with any governmental authority of any country; and
  • to consider and respond to requests or complaints made by you.

If you are a candidate for employment, we may use your personal information to assess your suitability for a position at Imagion.

We may also use and disclose your personal information for other purposes required for the administration and operation of Imagion, including:

  • administering billing (including administration of insurance and other third-party payment arrangements) and debt recovery;
  • managing, monitoring, planning and evaluating our services;
  • safety and quality assurance and improvement activities;
  • training of staff;
  • testing and maintenance of information technology systems;
  • product and service development, quality control and research to improve the way we provide services to you; or
  • to seek your feedback in relation to customer satisfaction and our relationship with you and perform research and statistical analysis using such feedback.

Under applicable data protection and privacy laws, we are required to set out the legal basis for the processing of your personal information. In accordance with the purposes for which we collect and use your personal information, as set out above, the legal basis for us processing your personal information will typically be one of the following:

  • your consent;
  • the performance of a contract that we have in place with you or other individuals;
  • Imagion or our third parties’ legitimate business interests; or
  • compliance with our legal obligations.

7. Disclosure of the information we collect

We may share your personal information with people within Imagion who need to know that information for business or legal reasons, for example, in order to carry out an administrative function such as processing an invoice, or to direct a query that you have submitted to the relevant department within Imagion.

We may disclose your personal information to third parties including the authorities, our share registry, professional advisors, data analysts; insurers; auditors; suppliers of IT services and third parties engaged by us for the purpose of providing services requested by you; to protect any intellectual property rights in any materials displayed on or otherwise available from our website; for the purposes of seeking legal or other professional advice; and to respond to a legal request or comply with a legal obligation. If you apply for employment with Imagion, we may disclose the personal information you provide to us to recruitment advisors for the purpose of considering you for career opportunities with us.

We may also disclose your personal information to anyone authorised by you, or to whom you have provided your consent (either expressly or impliedly) or where another permitted general situation applies under applicable regulations.

We may also disclose your personal information to third parties in the event that we sell, buy or merge any business or assets, including to the prospective seller or buyer of such business or assets.

Because Imagion operates globally, we may share the personal information you submit to us with any entity within the Imagion group worldwide. These entities are required to maintain the confidentiality of this information and are restricted from using it for any purpose other than the purposes set out in this Privacy Policy.

8. Transfer of your personal information to other countries

Please note that any person to whom we may disclose your personal information under this Privacy Policy may be situated in a country other than your own and that such country may provide a lower level of data protection requirements than your own country. By agreeing to this Privacy Policy, you consent to the transfer of your personal information to a country other than your own.

Whenever we transfer personal information across borders, we take steps to put in place adequate safeguards to protect your personal information and to make sure it is treated in accordance with this Privacy Policy.

9. Online and digital services

Direct marketing

We may use your personal information to keep you informed of the range of products and services offered by us. This includes sending you information about new products and services by post, telephone or any form of electronic communication. We may use an email address or other contact information you provide to us at any time for this purpose.

You can opt out of receiving direct marketing material information from us at any time. You agree and acknowledge that even if you opt out of receiving marketing material, we will still send you essential information that we are required to send you relating to the services we provide.

Cookies and related technologies

Our websites use cookies. A cookie is a small text file that is placed on your computer or mobile device when you visit a website or use an app. Cookies collect information about users and their visit to the website or use of the app, such as their Internet protocol (IP) address, how they arrived at the website (for example, through a search engine or a link from another website) and how they navigate within the website or app. A cookie cannot read data from your hard disk or read cookie files created by other websites.

We may use cookies and other technologies to facilitate your internet sessions, offer you services according to your preferred settings, track use of our websites and to compile statistics about activities carried out on our web sites.

You may set up your web browser to block cookies or remove cookies stored from your computer or mobile device. However, if you do so, you may not be able to use certain features and functions of our websites.

Other websites

Other websites that may be accessible via hyperlinks from our website are owned and operated by third parties and are not subject to our Privacy Policy. We have no control over the content of those websites.

Please review the privacy policy of each individual website you access and assess whether the policy is satisfactory to you before you use the other websites.

10. Retention of personal information

Our aim is to keep your personal information for no longer than is necessary for regulatory or Imagion business reasons. The amount of time that records are kept for varies depending upon the type of personal information they contain.

If we no longer need your personal information, unless we are required under law or a court or tribunal order to retain it, we will take reasonable steps to destroy, securely delete, or de-identify your personal information as appropriate.

11. Your rights in relation to your personal information

You may request access to the personal information we hold about you. You may request this information by writing to our Privacy Officer on the details below. If you do so we will respond to your request within a reasonable period of time.

Where we hold information that you are entitled to access, we will try to provide you with suitable means of accessing it (for example, by mailing or emailing it to you). This will be subject to any exemptions allowed under applicable privacy regulations, and there may be instances where we cannot grant you access to the personal information we hold. For example, we may need to refuse access if granting access would interfere with the privacy of others or if it would result in a breach of confidentiality. If that happens, we will give you written reasons for any refusal.

We endeavour to ensure that the personal information we hold about you is complete, accurate and up to date. If you consider that your personal information is incomplete, inaccurate or out of date, you have the right to require us to correct it. In order to correct, erase or limit the processing of any of the personal information we hold about you, again please contact us on our details below.

12. Complaints and Concerns

If you have a concern or complaint about how we have used your personal information, as a first step, you should raise this in writing with us, using the contact details below.

We will consider and respond to your complaint within a reasonable period. We may seek further information from you in order to provide a complete response.

If you are not satisfied with our handling of your concern or complaint, you can escalate this to your national Data Protection Authority.

The Office of the Australian Information Commissioner can be contacted by telephone on 1300 363 992. Full contact details for the Office of the Australian Information Commissioner can be found online at

13. Changes to this Privacy Policy

We reserve the right, at our discretion, to modify or remove portions of this Privacy Policy at any time.

This Privacy Policy is in addition to any other terms and conditions applicable to our website.

Any updated versions of this privacy policy will be posted on our website and will be effective upon posting. Please review it regularly.

14. Contacting us

If you would like to contact us in relation to this Privacy Policy or your personal information please contact us at:

Jovanka Naumoska
Telephone: +1 619 693 4432

Last updated 5 September 2018