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Privacy

1. INTRODUCTION

MMG有限公司(arbn31 150 889 151)及其附属公司(“MMG”), “we”, “our” or “us” in this Privacy Statement) is a global resources company which explores, 在世界各地开发和开采贱金属矿床. We are obliged by law to comply with the relevant privacy laws of the countries where we operate. 本隐私声明 is prepared in accordance with Australian privacy law because our head office is located in Australia. Where privacy laws in other countries apply, we comply with those as far as reasonably practical. 本隐私声明解释我们如何收集, hold, use and disclose (“process”) 个人信息 in the countries where we operate.

2. 适用范围及用途

本隐私声明 applies to all 个人信息 that we process in the course of our business, in compliance with relevant laws and our risk management activities, 包括我们的内部运作(管理), employees, temporary staff, contractors) and external operations (third parties such as business partners and service providers).

3. 个人信息、隐私和员工记录

在本隐私声明中, “个人信息” concerns information or an opinion about an identified individual or an individual that is reasonably identifiable. We make no distinction between employee records and other sources of 个人信息, nor between the format or veracity of 个人信息 which we process. All 个人信息 that we process is classified as being of high value and high sensitivity.

4. 管理个人信息处理的隐私原则

4.1、公开透明的个人信息管理

MMG is committed to managing 个人信息 in an open and transparent way. 为了支持这一承诺, 我们已经实施了内部实践, procedures and systems (“administrative controls”) to align our handling of 个人信息 with principles derived from Australian and relevant international privacy laws, 国际标准和最佳实践.

4.2匿名和假名

Individuals can choose to remain anonymous or to use a pseudonym when dealing with us. 在某些情况下, 取决于个人与我们的交易性质, we may need to know the identity of the individual who we are dealing with in order to provide the service or information requested.

4.3 .收集征集的个人信息

We are committed to collecting 个人信息 by lawful and fair means. Wherever possible, we only collect 个人信息 directly from an individual and with their consent, and only do so where the 个人信息 is reasonably necessary for one or more of our business activities. It is generally not necessary to collect sensitive 个人信息, 内部人力资源活动除外, where the sensitive 个人信息 is required (for employment reasons and/or by operation of relevant laws). 在这种情况下, we will only collect sensitive 个人信息 about an individual after having received the individual’s explicit consent to that collection. We may solicit or request 个人信息 from a third party such as an employment agency or referee in the context of employment.

4.4 .处理未经请求的个人信息

我们不会主动寻求收集未经请求的个人信息. However, 如果此类未经请求的个人信息被提供给我们, we will assess whether the unsolicited 个人信息 should be retained, 去识别或销毁, 并采取相应的行动.

4.5收集个人资料的通知

本隐私声明, legal notices published on our website and intranet and the administrative controls, collectively represent our method for ensuring that individuals know about the 个人信息 that we
process.

4.6个人信息的使用或披露

我们在哪里保存个人信息 about an individual that was collected for a particular purpose, we will not use or disclose that information for another purpose unless:

  • Otherwise required or authorised by law; or
  • The individual has consented to the use of that information for another purpose; or
  • The individual would reasonably expect us to use or disclose that information for a related purpose.

我们使用和披露个人信息:

  • 用于MMG内部业务活动-名称, date of birth, address (physical, postal, 电子邮件及互联网协议地址), telephone numbers, cookies, OHS和设备相关信息, 例如MAC地址, 地理定位和RFID接近卡, next-of-kin, spouse or partner, fatigue, 吸毒和酗酒, payroll, banking, tax, photo identity, 工会会员资格, religious beliefs, gender, 文化和种族认同, qualifications, 培训等. We do not collect biometric forms of 个人信息 such as fingerprints, 除非有关法例另有规定;
  • For external MMG business activities – communicating and transacting with third parties and entering into legal relationships (JVs, M&A, outsourcing, engaging services and purchasing goods); and
  • For record retention – when required for legal, business and evidential reasons. 

4.7 Direct Marketing

我们很少从事直销. If we do, 我们请求(明示)同意, tacit or implied) to communicate directly with the individuals concerned and we allow those individuals to opt-out of receiving direct communications and direct marketing notifications. 我们不透露, sell or share 个人信息 to third parties for direct marketing purposes.

4.8个人信息的跨境披露

MMG在多个国家开展业务. 以促进我们的全球业务, 我们依赖于各种第三方服务提供商, such as telecommunications and internet service providers based in the People’s Republic of China, Hong Kong, Laos, 刚果民主共和国, Peru, Canada, 美国和南非. These service providers may also have separate operations in other countries, which they use to provide the relevant telecommunications and internet services to us.

鉴于我们的全球信息系统, 个人信息 is located and disclosed in transit and in a static format in countries across the world. Individuals are cautioned to consider how their 个人信息 is transferred through and stored on our global information systems, and accordingly make appropriate choices about their 个人信息. While the use of information technologies mean that there can be no reasonable expectation of privacy, MMG遵守相关的监控法律, 它们试图避免对隐私的不合理限制.

4.政府标识符的采用、使用或披露

We do not adopt, use or disclose individuals’ government identifiers as our own identifiers for those individuals. However, 当法律要求或授权时这样做, 我们使用并披露个人的政府标识符, including individuals’ Australian Tax File Numbers for human resource purposes.

4.10个人信息的质量

We are committed to ensuring that all 个人信息 which we process is accurate, up-to-date, 完整且相关. To do so, we provide various technical and other means for individuals to access, verify and update the 个人信息 records that MMG holds about those individuals.

4.11个人信息安全

We are committed to taking reasonable steps to protect all 个人信息 that we hold from misuse, 干扰和损耗. We are also committed to securing 个人信息 from unauthorised access, 修改和披露. 遵守相关法律，管理相关风险, 我们的行政管制旨在保护资料的机密性, 我们信息系统的完整性和可用性, and the 个人信息 that we process on those information systems.
Where there is no legal obligation to retain records and evidence of 个人信息, and in circumstances where we no longer require that 个人信息 for our business activities, we will take steps to destroy or de-identify that 个人信息.
Our information security and privacy practices include circumstances where our data handling practices are outsourced to third parties. 在这种情况下, we require that relevant third party service providers comply with our standards and relevant laws by entering into appropriate legal agreements with those third party service providers. Where possible, we also continue to monitor the third party service providers’ privacy and security practices, 确保他们符合我们的标准.

4.12个人信息的访问

Where we (or any third parties on our behalf) process 个人信息, 我们会应有关人士的要求, (or any third parties on our behalf) normally give that individual access to their own
个人信息. In considering an individual’s request for access to their own 个人信息, 在决定允许或拒绝接触那个人之前, 我们将要求有关人士提供身份证明. We reserve the right to refuse access where such a refusal is authorised by law, in cases of commercial sensitivity and/or where a third party may be negatively affected by giving the individual access to their 个人信息. 我们将提供所有拒绝访问的理由. We will respond to an individual’s request for access to their own 个人信息 within a reasonable time (generally within thirty (30) business days). 一般情况下，个人的申请不收取任何费用
access to their own 个人信息, or upon MMG deciding to grant or refuse access. We do, however, reserve the right to charge a fee for the granting of access to an individual’s 个人信息, 我们在什么情况下会产生费用.

4.13个人信息的更正

我们在哪里保存个人信息, we take reasonable steps to ensure that the 个人信息 is accurate, up-to-date, complete, 切题而不误导. Where it is not, an individual may request that we correct their 个人信息. 在考虑改正请求时, we will require identification and we reserve the right not to effect the changes sought. 我们将提供所有拒绝更正的理由. We will respond to a request to correct 个人信息 within a reasonable time (generally within sixty (60) business days), although giving effect to any associated corrections which are sought by an individual may take longer if we need to contact any third party organisations or notify other individuals about the request. No charge applies for the making of a request to correct 个人信息, 由于MMG拒绝执行所要求的更正, or upon correction of any relevant 个人信息 by or on behalf of MMG.

5. BREACH

如果MMG怀疑或发现:

  • 网络或信息系统的破坏, resulting in unauthorised access to or unauthorized disclosure of one or more individuals’ 个人信息, which is likely to result in serious harm to the relevant individual(s); or
  • 个人信息丢失, in circumstances which may result in unauthorised access to or unauthorised disclosure of one or more individuals’ 个人信息,

MMG will:

  • 采取补救行动;
  • 当补救措施未能充分限制风险时, notify the relevant individual(s) and the Office of the Australian Information Commissioner (“Commissioner”); and
  • Work with the relevant individual(s) concerned and the Commissioner to protect everyone and everything concerned.

Any person who suspects (or becomes aware of) a breach (or an impending breach) in relation to 个人信息 held by MMG should contact MMG’s Privacy Officer as a matter of urgency in accordance with the Data Breach Response Procedure.

6. COMPLAINTS, ENQUIRIES AND REQUESTS FOR ACCESS OR CORRECTIONS TO PERSONAL INFORMATION

在大多数情况下, the Commissioner will not investigate an individual’s complaint in relation to 个人信息 held by MMG if the individual has not first raised the matter with us. For this reason, we ask that individuals submit all complaints relating to this privacy statement to MMG first, so that we have an opportunity to resolve complaints before they proceed to any relevant authority (including the Commissioner). 请直接投诉, enquiries and requests for access or corrections to 个人信息 to MMG’s
联络私隐主任，联络方式如下:

如果你对我们处理投诉的方式不满意, ，你可透过以下途径向专员提出正式投诉:

  • Telephone: 1300 363 992 (if calling from outside Australia including Norfolk Island please call: +61 2 9284 9749)
  • 全国中继服务:

−TTY用户拨打133377，然后拨打1300 363992
− Speak and Listen users phone 1300 555 727 then ask for 1300 363 992
− Internet relay users connect to the National Relay Service then ask for 1300 363 992

7. 技巧，勤奋，细心

At all times, 在处理个人信息时, MMG会锻炼合理的技能, diligence and care that may reasonably be expected of a similar global resources company.

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