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(03) 9587 1577

54-84 Boundary Road, Braeside VIC

Privacy Policy

Dawborn Steels Trading Pty Ltd Privacy and Credit Reporting Policy

Version Date: 02/08/19

Dawborn Steels Trading Pty Ltd (Dawborn Steels) is one of Australia's longest standing independent steel merchant with over 30 years' experience importing, processing and supplying steel in Melbourne. Dawborn Steels trades in both ferrous and non-ferrous metals and its products include hot and cold rolled sheet and coil, galvanised sheet and coil, aluminised sheet and coil, electro galvanised sheet and coil, stainless steel sheet and coil, tubular and bar products, wire and associated products, zincalume, brass, copper and plated steel strip.

We know you care how your Personal Information and Credit Information is collected, used and shared. It is important you make an informed choice regarding the information you voluntarily share with us or that may be collected from you when you engage our services or interact with us. We respect your privacy and are committed to keeping your Personal Information and Credit Information safe.

Our Privacy and Credit Reporting Policy (Privacy Policy) explains how we collect, use, share and protect your Personal Information and Credit Information. It applies when we collect data from clients and guests who voluntarily provide it, we request it or when you use our website and/or Dawborn Steels controlled applications accessed and/or used on a mobile, handheld or other wirelessly connected devices (a Website or Application).

What is your Personal Information?

Personal Information includes, your name, address, date of birth, telephone number, email address and location, which when used either alone or in combination with other information could be used to identify, contact or locate you.

What is your Credit Information?

Credit Information is personal credit information about you and includes credit eligibility information which is collected about you either from you personally, from publicly available information, a credit provider or from a credit reporting body. Credit Information means:

(a) your identification information;

(b) your consumer credit liability information;

(c) your repayment history information;

(d) an information request has been made about you by a credit provider, mortgage insurer or trade insurer;

(e) the type of consumer credit or commercial credit being applied for and the amount of credit sought in your application;

(f) your default information;

(g) your payment information;

(h) new arrangement information;

(i) court proceedings information;

(j) your personal insolvency information;

(k) publicly available information that relates to your activities in Australia and your credit worthiness; and

(l) the opinion of a credit provider, you have committed a serious credit infringement in relation to consumer credit.

By disclosing your Personal Information and Credit Information to us either directly or by using our Websites or Applications, by submitting an application for credit or agreeing to be a guarantor for an application of credit, you consent to the collection, use and distribution by Dawborn Steels of your Personal Information and Credit Information in accordance with this Privacy Policy (which is expressly incorporated into any applicable application for credit, Website or Application terms of use) and with any applicable legislation such as the Privacy Act 1988 (Cth) (the Privacy Act) as amended.

This Privacy Policy will be updated from time to time. The version date will be changed following amendments to the Privacy Policy. Please note the date of this Privacy Policy and check it periodically for date changes, as your continued use of our services and/or products either by submitting an application for credit or visiting our Websites or Applications means you acknowledge, agree to and consent to those changes.

If you require a paper copy of this Privacy Policy, please contact us in one of the following ways:

Phone: 03 9587 1577

Email: nqzva@qnjobeafgrryf.pbz.nh

Post: PO Box 550, Braeside, Vic, 3195

WHY WE COLLECT YOUR INFORMATION AND HOW WE USE YOUR INFORMATION

Dawborn Steels collects and uses your Personal Information and Credit Information for the following purposes:

  • provide you with information about our services and products which includes:
    • accepting and processing applications for consumer credit and commercial credit;
    • assessing applications for credit;
  • respond to requests made for information about our products and services;
  • respond to feedback, complaints or comments whether made by phone, electronic means, mail, or in person;
  • supply our products and services to you or to enable our related bodies corporate such as Contract Slitters (Vic) Pty Ltd ACN 064 180 614 to supply products and services to you;
  • undertake marketing and promotional activities;
  • analyse the impact of our advertisements, and promotions;
  • meet our internal reporting requirements;
  • process employment applications;
  • engage contractors;
  • provide you with important information relating to a change to our Privacy Policy, our Terms of trade, our Website or an Application;
  • conduct market research and product development;
  • improve our Website and its functionality;
  • identify if you have previously visited the Website and help you auto-populate your information so you don't have to re-type it;
  • advise you of a security breach;
  • direct marketing to inform you of special offers and promotions which may be of interest to you;
  • meet our legal and regulatory responsibilities;
  • provide location based functionality in our Website and Application utilising your Location Data for your benefit;
  • contact you by email, SMS or MMS, phone or mail or in any other lawful manner for the purposes set out above.

Dawborn Steels only collects information it considers necessary for the activities of its business. Most of the information collected is obtained directly from you so you will normally be aware of the purpose of its collection. Dawborn Steels may obtain credit reports from credit reporting bodies such as illion Australia Pty Ltd, formerly Dun & Bradstreet (illion) and Equifax Australia Information Services & Solutions Pty Ltd is part of Equifax Inc, (Equifax) for the purposes of assessing applications for credit submitted by you or your organisation. Dawborn Steels only uses and discloses your Personal Information and Credit Information for the purposes for which it was originally collected, unless required or authorised by or under law, or if you have consented to the intended use. For the purposes of the Privacy Act we are a credit provider.

HOW WE COLLECT YOUR INFORMATION

Dawborn Steels collects your Personal Information in a number of ways.

For example, we collect information when you:

  • use our Website or an Application to make an enquiry about our products or services;
  • when you request we send you information on our products or services;
  • complete an application for credit;
  • supply information with your applications for credit, applications for employment or applications to be engaged as a contractor or agent, such as driver's
  • licence, passports and financial statements and tax file numbers.;
  • post a comment on our Website, Facebook page or an Application;
  • use our Website or an Application and this information is captured by Google Analytics;
  • enter into written agreements with us, our agents or third party service providers;
  • send us an email or letter or make a telephone enquiry or complaint;
  • when you submit an employment application and through the employment process;
  • ask to be included on a mailing list; or
  • provide your information to a third party that provides services to us or we supply services to, such as a contractor, agent, our related body corporates, another credit provider or regulatory authorities.

TYPES OF INFORMATION WE COLLECT

We collect the following types of information:

  • Name, email address, telephone and fax numbers and delivery details;
  • Age;
  • Date of birth;
  • Gender;
  • Occupation and employment status;
  • ABN, if you are a customer, contractor or supplier of goods;
  • IP Address;
  • Credit card details;
  • Location Data;
  • Device type (iPhone, laptop etc);
  • Domain name;
  • Web browser eg. Safari, Firefox, Dolphin;
  • Date and time of access to the Website or Application and which website you came from;
  • Content of emails;
  • Hyperlinks you have clicked;
  • Information you post on our Website, Facebook page or your webpage;
  • Credit Information and Credit Eligibility Information of individuals and entities who submit an application for credit to us or who offer to be a guarantor for an application for credit; and
  • any other information you voluntarily provide to us.

Credit Eligibility Information means:

(a) credit reporting information about you that was disclosed to us by a credit reporting body as permitted by the Privacy Act; or

(b) CP derived information about you.

CP derived information about you means any personal information (other than sensitive information) about you:

(a) that is derived from credit reporting information about you, disclosed to us by a credit reporting body under the Privacy Act; and

(b) has any bearing on your credit worthiness; and

(c) is used, has been used or could be used in establishing your eligibility for consumer credit.

Location Data and other information you provide to us or that may be accessed in connection with your use of our Website or our App enables us to offer location based functionality. We then disclose this information to third parties to enable us to provide this service.

Online Services - When you interact with us online (which may include electronically submitting an application for credit), you will be submitting the types of information specified above which is needed to assess, process and complete your application for credit.

CREDIT INFORMATION, CREDIT ELIGIBILITY INFORMATION AND CREDIT REPORTING BODY

As part of an application for credit, we may collect both Personal Information, Credit Information and Credit Eligibility Information in relation to you. By providing your Personal Information, Credit Eligibility Information and Credit Information to us, you are consenting to the collection, use and disclosure of that information by and to Dawborn Steels, other credit providers and credit reporting bodies (who have an agreement with Dawborn Steels for credit related purposes and/or credit guarantee purposes) for the purposes identified above. The purposes include, without limitation, assessing the credit application and any offer to provide a guarantee, making an assessment of credit worthiness, processing the credit application and/or managing the credit.

You also expressly consent to Dawborn Steels' collection, use and disclosure of Credit Eligibility Information and CP Derived Information about you for the purposes identified above.

We may obtain credit reports from credit reporting bodies such as illion and Equifax for the purposes of assessing applications for credit received from individuals and corporate entities and to manage the credit. The credit reports includes information which is used by us and other credit providers in assessing your individual credit worthiness.

The Privacy Act and our agreements with credit reporting bodies do or may require us to provide the credit reporting bodies with Credit Information relating to any application for credit, the credit provided, and any guarantee provided. This includes, providing default information for consumer credit for amounts owing over $150 that remain unpaid for at least 60 days, (provided certain criteria have been met such as you have been notified in writing of the outstanding debt and requesting payment and payment has not been made), or where you have committed a serious credit infringement.

We may provide credit reporting information such as Credit Information and Credit Eligibility Information (Credit Reporting Information) to illion and Equifax who include the information we provide to other credit providers. illion and Equifax have their own credit reporting policies as required by the Privacy Act and Privacy (Credit Reporting) Code 2014 (CR Code).

The credit reports contain the following types of CP Derived Information:

  • Name, contact details and ABN;
  • Registration status, directors, ownership details, related entities and financials if an entity;
  • Overall conclusion;
  • Credit reference checks;
  • Details of trade payments and default on payments;
  • Risk Score;
  • Past enquiries;
  • History and Operations;
  • Bank and Finance details;
  • Information sources.

Credit reporting bodies may also use your Credit Reporting Information to pre-screen direct marketing by a credit provider. If you do not wish illion or Equifax to do this you should contact both organisations and request they not use your Credit Reporting Information for pre-screening.

It is important to note, if you believe you have been or are likely to be the victim of fraud, you should contact illion and Equifax and request they not use or disclose your Credit Reporting Information.

illion's contact details are:

Address: Ground Floor, 479 St Kilda Road, Melbourne, Vic, 3000

Mail: PO Box 7405 St. Kilda Road, Melbourne VIC 3004 Phone: 1300 734 806 Fax: 03 9828 3118

Email: cnpnhfgeny@vyyvba.pbz.nh or pup-nh@vyyvba.pbz.nh (for complaints)

Website: http://www.checkyourcredit.com.au

A copy of illion's privacy and credit reporting policy can be obtained from its website or by contacting its office and requesting a copy.

Equifax's privacy and credit reporting policy can be obtained from its website: www.equifax.com.au/privacy or by requesting a copy. If you have an issue with the information recorded about you on a credit file obtained from Equifax, you should contact Equifax in writing:

Equifax - Public Access

Equifax Australia Information Services and Solutions Pty Limited GPO Box 964 NORTH SYDNEY NSW 2059 https://www.equifax.com.au/understanding-your-credit-file

DIRECT MARKETING

Provision of your Personal Information to us such as an address, email address and/or phone number, means you are consenting to receive direct marketing material from Dawborn Steels, our related bodies corporate including Contract Slitters (Vic) Pty Ltd ACN 064 180 614 and third party service providers by way of phone calls, mail, email, SMS text messages, mobile message services (MMS) or instant messaging.

Your Personal Information is disclosed to third parties for the purpose of allowing them to direct market our products and services to you in the ways described above. We have disclosed the types of third parties that may contact you with direct marketing in the section below headed

DISCLOSURE TO THIRD PARTIES AND OTHER USES.

You may opt out of receiving any direct marketing by:

  • unsubscribing from the emails, by clicking on the link within the email;
  • by email: nqzva@qnjobeafgrryf.pbz.nh,
  • by phone: 03 9587 1577; or
  • by mail: Dawborn Steels
    PO Box 550
    Braeside VIC 3195

CONSUMER'S SENSITIVE PERSONAL INFORMATION

Sensitive Personal Information includes information relating to race, religious beliefs, trade or professional associations, sexual orientation or health information etc. Dawborn Steels does not usually require consumers to provide Sensitive Personal Information.

Occasionally, a consumer may advise us of Sensitive Personal Information but we do not actively seek this information. If you do disclose your Sensitive Personal Information to us, you consent to our collecting, using and disclosing this Sensitive Personal Information for the purpose for which you disclosed it to us and as permitted under the Privacy Act and other relevant laws.

DAWBORN STEELS' CONTRACTORS

If Dawborn Steels engages you as a contractor we may collect information relating to your engagement. The types of information that may be collected include details of your qualifications, training records and logs, references, length of engagement, resume, pay rate, salary, bank account details and ABN. By disclosing your Personal Information and Sensitive Personal Information to us you consent to our collecting, using and disclosing this Personal Information and Sensitive Personal Information for the purpose for which you disclosed it to us and as permitted under the Privacy Act and other relevant laws.

EMPLOYMENT APPLICATIONS

If you submit an employment application to us you must submit your Personal Information which will be used to assess your application. We may use third party service providers to assist us in assessing your application and you consent to us disclosing your Personal Information to those third party service providers when you submit your application. Third party service providers to assist us with the following types of assessment: screening; aptitude tests; human resources management purposes, such as: background checks; undertaking discussions with your referees; medical tests and health assessments.

During the application process you may provide us directly and voluntarily with Sensitive Personal Information. If this occurs you consent to us collecting the Sensitive Personal Information. Types of

Sensitive Personal Information that may be collected during the employment process includes: tax file numbers, race, religion, professional or trade association memberships, health or criminal records.

Dawborn Steels does not collect and/or process any Personal Information or Sensitive Personal Information against the express wishes of an individual, unless Dawborn Steels is required by law to do so.

DISCLOSURE TO THIRD PARTIES AND OTHER USES

Dawborn Steels does not use or disclose any Personal Information, Sensitive Personal Information and Credit Reporting Information to third parties without your consent and as disclosed in this Privacy Policy or unless required by law. The third parties we choose to work with demonstrate the same level of commitment to your privacy as Dawborn Steels does. Our third party service providers may occasionally have access to the Personal Information and Sensitive Personal Information held by us under conditions of confidentiality.

We do not use or pass onto others any Personal Information, Sensitive Personal Information, Credit Information and Credit Eligibility Information without the consent of the individual(s) concerned and as disclosed in this Privacy Policy or unless required by law. You acknowledge, agree and consent to Dawborn Steels using and disclosing your Personal Information, Credit Information and Credit Eligibility Information to third party credit providers and credit reporting bodies when you submit a credit application to us or offer to be a guarantor to a credit application submitted to us. You acknowledge and consent to Dawborn Steels using and disclosing your Sensitive Personal Information to third party service providers to assist us with the following types of assessment: screening; aptitude tests; human resources management purposes, such as: background checks; undertaking discussions with your referees; medical tests and health assessments.

Dawborn Steels' credit reporting body third party service providers will have access to your Credit Information and you expressly consent to their use, collection and disclosure of your Credit Information and Credit Eligibility Information to other credit providers provided such collection, use and disclosure is in compliance with the Privacy Act and the CR Code.

Our third party service providers are only permitted to use your Personal Information for the purpose for which we supply the information. Your information may be disclosed to the following types of third parties:

  • related bodies corporate of Dawborn Steels such as Contract Slitters (Vic) Pty Ltd ACN 064 180 614;
  • Dawborn Steels partners and suppliers or their respective related bodies corporate;
  • other credit providers;
  • credit reporting bodies;
  • employees and contractors;
  • web hosting, data housing providers and other IT suppliers;
  • third party websites or applications where an interface or hyperlink has been allowed and that information is required to permit a connection to be made to the third party website or application;
  • when we provide location based services enabled through a third party, we may share data with those services in order to provide the related location based service or functionality;
  • web analytics such as Google or Unica;
  • insurers, lawyers, financiers, human resources consultants and other professional advisers;
  • service providers engaged by Dawborn Steels to provide a particular service on our behalf such as:
    • transport companies;
    • advertising, marketing, promotional and printing organisations who produce our marketing and promotional material;
    • mailing houses, postal and delivery services;
    • marketing and research agencies who conduct and analyse our marketing, promotions or competitions and undertake market research and trend analysis;
  • entities that process credit card payments;
  • Australian Tax Office;
  • a Court or to a third party under a subpoena issued by a Court;
  • a regulatory authority; or
  • for law enforcement purposes.

Dawborn Steels may disclose Personal Information, Sensitive Personal Information or Credit Information without the consent of the individual, where the law requires it to make the disclosure. The types of bodies to whom such a disclosure may be required to be made are:

  • Australian Tax Office;
  • credit reporting bodies;
  • a Court or to a third party under a subpoena issued by a Court;
  • a regulatory authority; or
  • for law enforcement purposes.

Dawborn Steels has a Facebook page and these may be used to run promotions. If you participate in a promotion via Facebook it may result in the collection of your Personal Information occurring directly by the service provider on their website. The promotion will state the policies governing the collection of such information if they should differ from this Privacy Policy.

Our authorised service providers may occasionally have access to aggregate statistics about our customers, sales, traffic patterns, and related Website or Application information. Transfers of aggregate statistics do not involve Personal Information.

If you continue to purchase Dawborn Steels' products or services, or to use its Facebook page, Websites and Applications, you are consenting to such disclosures to third parties.

OVERSEAS TRANSFER OF INFORMATION

We may disclose Personal Information, Credit Reporting Information or Sensitive Personal Information (if provided by you) to third party service providers who are located outside Australia.

We use Adobe Acrobat PDF and Microsoft Outlook to manage and transmit our data. These software programs use the cloud to store, process and transmit information to locations overseas. The countries we may send your Personal Information, Credit Information or Credit Eligibility Information to through the use of this software includes the United States (US), Singapore and Hong Kong.

As advised above, we process applications for credit and we send your Personal Information, Sensitive Personal Information, Credit Information or Credit Eligibility Information to credit reporting bodies as part of the process of assessing the credit application and any application to be a guarantor. The credit providers we send your Personal Information, Sensitive Personal Information, Credit Information or Credit Eligibility Information to, may send that information overseas to third parties.

We are not parties to the contractual arrangements between any other party and their overseas third party service providers and accordingly cannot comment further on those arrangements or be responsible for any breach of the Australian Privacy Principles by overseas third party service providers who might become recipients of your Personal Information, Sensitive Personal Information, Credit Information or Credit Eligibility Information. We believe the third parties we use to store, process and transmit information have appropriate privacy policies in place but we are not able to enforce their compliance with the Privacy Act, the CR Code or any other Commonwealth or State privacy legislation in force in Australia. Accordingly, section 8.1 of the Australian Privacy Principles will not apply to the disclosure by us (directly or indirectly) of your Personal Information, Sensitive Personal Information, Credit Information or Credit Eligibility Information to a third party or to an overseas third party.

By submitting your Personal Information, Sensitive Personal Information, Credit Information or Credit Eligibility Information to us and having been advised section 8.1 of the Australian Privacy Principles does not apply to our disclosures of this information either directly or indirectly to overseas third parties, you consent to our disclosure of that information to other parties knowing your information may be disclosed to overseas third party service providers over which we have no control to ensure compliance with the Privacy Act the CR Code or any other Commonwealth or State privacy legislation in force in Australia.

ANONYMITY AND PSEUDONYMS

You may deal with us anonymously or by using a pseudonym, unless to do so would be considered unlawful or impracticable. We cannot accept a credit application or process a product order on this basis, however, there may be other circumstances where it is possible to answer your queries anonymously or where you may use a pseudonym. Please advise if you wish to deal with us anonymously or by a pseudonym.

COOKIES AND COLLECTION OF NON-PERSONAL INFORMATION

We, or others acting on our behalf may use cookies, web beacons, pixel tags, website Analytics such as Google analytics and other similar technologies to collect non-personal information about you. This may occur when you submit an application electronically or visit our Website or an Application.

The technologies referred to above assist us to better understand how our Websites and Applications are used by our customers. This then helps us improve our products and services to better meet your needs, to personalize your online experience with Dawborn Steels and for general advertising and marketing purposes.

We may remove our session cookies at the end of your visit. However, this may not always occur and some cookies placed by Dawborn Steels or its vendors or suppliers (as applicable) may remain on your computer until you remove them.

Your internet browser is most likely set up to accept cookies, but you can set your browser to notify you when you receive a cookie or to block a cookie. Please note, that if you block our cookie we may not be able to provide our full services to you as it may prevent, affect or interfere with the functionality on our Website or Application.

OPTING OUT

You may stop receiving communications from Dawborn Steels at any time by contacting us in one of the following ways:

Email: nqzva@qnjobeafgrryf.pbz.nh

By mail: Dawborn Steels
PO Box 550
Braeside VIC 3195

MERGERS, ACQUISITIONS AND INSOLVENCY

Dawborn Steels may decide to sell the whole or part of its business, merge with another business or become insolvent. In these types of circumstances, your Personal Information Credit Information, Credit Eligibility Information and Sensitive Personal Information data may be transferred to a prospective purchaser, an actual purchaser, a merger party or be released to a liquidator, receiver or administrator. This information will remain subject to the Privacy Act and until you are further notified, will remain subject to Dawborn Steels' Privacy Policy.

ACCURACY OF INFORMATION

We take all reasonable steps to ensure the Personal Information, Sensitive Personal Information, Credit Information and Credit Eligibility Information we hold is accurate, up to date, complete, relevant and is not misleading. To maintain the integrity of this information, we may contact you on occasion to check your Personal Information, Sensitive Personal Information, Credit Information or Credit Eligibility Information is still accurate, up to date, complete, relevant and not misleading. If, at any time, you believe any of your Personal Information, Sensitive Personal Information, Credit Information or Credit Eligibility Information held by us is incorrect, please contact us immediately by:

Email: nqzva@qnjobeafgrryf.pbz.nh

By mail: Dawborn Steels
PO Box 550
Braeside VIC 3195

If we refuse to correct your information after receiving your written request, you may ask us to include a statement with the information noting your opinion the information is incorrect, out of date, incomplete, irrelevant or misleading. If we refuse to correct your information we will advise you why and how you may complain about the decision.

SECURITY OF INFORMATION

We take all reasonable steps to ensure your Personal Information, Sensitive Personal Information, Credit Information and Credit Eligibility Information is kept safe from misuse, interference, loss and

unauthorised access, modification and disclosure. The electronic database storing your information is protected from unauthorised access and access is restricted to authorised persons. We cannot secure the internet so Personal Information, Sensitive Personal Information, Credit Information or Credit Eligibility Information you send to us via the internet is done so at your own risk.

If Dawborn Steels discovers a security breach, involving your Personal Information, Sensitive Personal Information, Credit Information or Credit Eligibility Information we may attempt to notify you so you can take appropriate protective steps. You consent to Dawborn Steels contacting you in these circumstances.

Except to the extent liability cannot be excluded under statute, we exclude all liability (including in negligence) for the consequences of any unauthorised access to, disclosure of, misuse of or loss or corruption of your Personal Information, Sensitive Personal Information, Credit Information and Credit Eligibility Information. Nothing in this Privacy Policy restricts, excludes or modifies or purports to restrict, exclude or modify any statutory consumer rights under any applicable law including the Competition and Consumer Act 2010 (Cth). If you become aware of any breach of security involving your Personal Information, Sensitive Personal Information, Credit Information and Credit Eligibility Information, please contact us immediately.

Dawborn Steels takes all reasonable steps to destroy or permanently de-identify Personal Information, Sensitive Personal Information, Credit Information and Credit Eligibility Information that is no longer needed for a permitted purpose and is not required to be retained by law.

ACCESS TO YOUR PERSONAL INFORMATION AND COMPLAINTS

At all times, Dawborn Steels strives to ensure your Personal Information, Sensitive Personal Information, Credit Information and Credit Eligibility Information is treated confidentially, and in accordance with the Privacy Act. If you believe your Personal Information, Sensitive Personal Information, Credit Information or Credit Eligibility Information has been handled in a way that does not comply with the Privacy Act or the CR Code (only applicable to Credit Information and Credit Eligibility Information), or if you wish to access information that Dawborn Steels holds about you, please contact us.

If you have any questions, concerns or complaints or wish to access the information Dawborn Steels holds about you, please contact us in writing:

Email: nqzva@qnjobeafgrryf.pbz.nh

By mail: Dawborn Steels
PO Box 550
Braeside VIC 3195

For security reasons, we ask you submit requests for access or complaints regarding your Personal Information, Sensitive Personal Information, Credit Information or Credit Eligibility Information in writing.

We will investigate your complaint, concern or query in a timely and efficient manner and will seek to resolve the issue directly with you.

For complaints made about a breach of Part IIIA of the Privacy Act, (other than section 21T or 21V) or a breach of the CR Code, we will respond within 7 days after the complaint is made by giving the complainant a written notice acknowledging the making of the complaint and setting out who at Dawborn Steels will deal with the complaint.

It may be necessary to consult a credit reporting body about the complaint. We will make a decision and respond to the complaint during the following 30 day period which commences on the date the complaint is made (unless unusual circumstances apply) or such longer period as you may agree to in writing.

We may charge you a fee for accessing your Personal Information, Sensitive Personal Information, Credit Information and Credit Eligibility Information which will reflect our reasonable costs of retrieving and supplying the information to you.

We may refuse you access to your information. If we do, written reasons for the refusal and the mechanisms available to complain about the refusal will be provided to you. Access can be refused

where the information relates to anticipated legal proceedings, the request is frivolous or vexatious or giving access would have an unreasonable impact on the privacy of other individuals.

PUBLIC AREAS

If you disclose information to us through websites or applications including, without limitation, Dawborn Steels' Website or Application, or social medium forums or sites such as Facebook, YouTube, Twitter, Pinterest etc.) it will be accessible by the general public. Dawborn Steels has no control over the use of information disclosed in public forums, such as social media forums, platforms, bulletin boards, blogs, wikis, chat rooms, and networking functions of mobile-device applications. Please exercise caution when disclosing your information in these public forums as you are solely responsible for any content you post in public areas of our Websites or Applications.

Content may be posted on our Website, Facebook page and Applications that we do not endorse, support, verify, or agree with and we reserve the right to remove any comments we consider to be offensive, derogatory or otherwise inappropriate.

CHILDREN

Our products and services are not for the use of children. We do not market our Website, Facebook page or Applications to children. If you are under 18 years of age or otherwise require a parent or guardian to consent to the disclosure of your information, you should not send any Personal Information, Sensitive Personal Information, Credit Information or Credit Eligibility Information about yourself to us. If we receive Personal Information, Sensitive Personal Information, Credit Information or Credit Eligibility Information from a person under 18 and we become aware of it, we will attempt to delete this information as soon as possible. We do not knowingly collect such information from persons under 18 and do not knowingly pass this information onto third parties.

LINKS TO OTHER STES

Our Website, Facebook page or Applications may contain links to other Internet sites owned by third parties. We provide these links solely for your convenience and do not expressly or by implication endorse the commentary, products or services included on other Internet sites. If you access third party Internet sites through links or advertising on our Website, Facebook page or Applications and use those products and/or services, you do so at your own risk. Dawborn Steels is not responsible for and cannot control the privacy practices of these other websites or applications. We encourage you to read the privacy policies for these other websites and applications, as they may differ from ours.

This Privacy Policy applies solely to Dawborn Steels'and its related bodies corporate handling of your Personal Information, Sensitive Personal Information, Credit Information and Credit Eligibility Information which it collects from you directly or is collected through its Website and Applications or from credit reporting bodies and other credit providers.