Sugar Terminals Limited ACN 084 059 607 (“STL”, “we”, “our” or “us”) is a public company owned by shareholders in the raw sugar industry. It owns the bulk sugar terminal buildings, specified plant and equipment at each terminal and leases the bulk sugar terminal land at Cairns, Mourilyan, Lucinda, Townsville, Mackay and Bundaberg. Queensland Sugar Limited subleases the 6 bulk sugar terminals from STL and is charged commercial rent for the use of these facilities.
We respect the privacy of the personal information you may provide to us. The way we manage your personal information is governed by the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles (APPs) established under the Privacy Act.
2. Link Market Services Limited
STL’s relationship with its shareholders is managed by Link Market Services Limited ACN 083 214 537 (Link), who provides share registry services to STL. Link maintains STL’s share registry and in the process collects and maintains personal information belonging to STL’s shareholders. As a result, STL and Link exchange personal information about STL’s shareholders.
Like STL, Link is also regulated by the Privacy Act and the APPs.
3. Collecting personal information
3.1 What kinds of personal information do we collect?
The types of personal information we may collect include, but are not limited to:
- your name (current and any former) and date of birth;
- your personal and/or business contact details (including your address, landline or mobile telephone numbers, fax number and e-mail address);
- your employment details (including your company name, job title and business sector);
- banking and tax details (including your tax file number and ABN if applicable);
- personal information provided when you commence a shareholder or other relationship with us;
- the capacity in which you grow sugar cane (e.g. as trustee, executor, partner in a partnership or as a party to a share farming agreement);
- contact and identification details of any third party that you have authorised to negotiate or provide your personal information on your behalf (including any attorneys appointed by you under a power of attorney);
- any correspondence between you and us; and
- any other personal information provided to us when you make an inquiry, request information, respond to marketing or lodge a complaint.
We may also collect sensitive information from you. Sensitive information is defined by the Privacy Act to be certain kinds of personal information. Examples of sensitive information that we may collect from you through providing information and other services to you include health information and member of professional or trade associations.
3.2 How do we collect personal information?
Where possible, we will always try to collect personal information directly from you, for example when you:
- request information or contact us by telephone;
- correspond with us in writing (such as letters and emails);
- provide your identification or other documents to us; or
- meet with us in person.
We may also obtain your personal information from third parties we deal with, such as:
- government and law enforcement agencies;
- our professional advisers;
- our contracted service providers; and
- any other organisation with whom we do business.
Where we collect personal information from third parties you refer to us, we will assume and you will ensure that you have made that third party aware of the referral and the purposes of collection, use and disclosure of the relevant personal information
3.3 Dealing with us anonymously
For certain transactions, you have the option of dealing with us anonymously or by using a pseudonym (for example, if you contact us asking for general information about us or our website).
However, it is generally not possible for us to enter into a business relationship or carry out commercial transactions with you without first collecting your personal information.
4. Why do we collect, hold, use and disclose your personal information?
We collect, use and disclose your personal information to perform our functions and activities, carry out our operations and to otherwise enable us to provide the services, products and information you request. In particular, we may collect, use and disclose your personal information for the purposes of:
- responding to your requests or inquires and providing you with any information or other services requested by you;
- your shareholder or other relationship with us;
- where necessary, updating and maintaining our records;
- making our website easier for you to use and providing you with access to all parts of our website;
- notifying you about important changes or developments to our functions, activities, services or our website;
- administering, supporting, improving and developing our business and services;
- any other purpose which relates to or arises out of requests made by you;
- if you lodge a complaint with us, processing and responding to your complaint;
- doing anything which you authorise or consent to us doing; or
- taking any action we are required or authorised by law to take.
If you do not provide us with your personal information, it may not be possible for us to carry out the above functions and activities.
5. Disclosing your personal information
We may disclose your personal information to:
- our business partners and service providers (such as contractors who provide website, IT, marketing, administration and other services to support STL);
- any suppliers we may engage for data processing and other administrative and support functions;
- our professional advisers (for example, our insurers, accountants, auditors, lawyers and consultants);
- any entity to whom we are required or authorised by law to disclose your personal information (for example, the Australian Taxation Office, law enforcement agencies and government and regulatory authorities); and
- with your consent (express or implied) – other entities.
The above entities may in turn disclose your personal information to other entities as described in their respective privacy policies or notices.
6. Dealing with STL online
When you visit our website, we and/or our contractors may collect certain information about your visit. Examples of such information may include:
- Site visit information – we may collect general information about your visit to the STL website. The information we may collect is not used to personally identify you, but instead may include your server address, the date and time of your visit, the pages you accessed and the type of internet browser you use. This information is aggregated and used for the purposes of system administration, and to prepare statistics on the use of our website.
7. Storage, retention, security and location of your personal information
We will take reasonable steps to protect your personal information from loss, misuse, unauthorised access, modification or disclosure. We may store your personal information in different forms, including in hardcopy and electronic form. We have implemented policies, procedures and systems to keep your personal information secure.
We may be required by law to retain certain information for a set period of time. Once this period of time expires, or we no longer need to hold your personal information, we will take reasonable steps to destroy, delete or de-identify your personal information in a secure manner.
8. Overseas disclosure of personal information
From time to time, STL may engage service providers located in one or more overseas countries to perform certain functions and activities. In the course of providing services to STL, we may need to disclose your personal information to these service providers.
If overseas service providers are engaged and personal information is sent overseas, we will take reasonable steps to ensure that our service providers are carefully chosen and have policies, procedures and systems in place to ensure your personal information is otherwise handled in accordance with the Privacy Act.
9. Access and correction
To effectively conduct business with you, it is important that the personal information we hold about you is complete, accurate and current. At any time while we hold your personal information, we may ask you to tell us of changes to your personal information.
You can request us to update or correct your personal information if you believe that the personal information we hold about you is inaccurate, out-of-date, incomplete, irrelevant or misleading or otherwise needs to be corrected or updated. Our contact details are provided below. We will respond to a request to correct your personal information within a reasonable period after the request is made.
If we refuse to correct your personal information, you may request that we associate with the information a statement that the information is inaccurate, out-of-date, incomplete, irrelevant or misleading.
You can also request access to the personal information we hold about you by contacting us using our details provided below. We will respond to a request for access within a reasonable period after the request is made, either by giving you access to the personal information requested, or by notifying you of our refusal to give access.
We will not charge you an application fee for making a request to access the personal information we hold about you or for making any corrections to your personal information.
However, we may charge a reasonable fee to cover our costs of providing you with access to your personal information, for example, if you make multiple requests for information, where your request relates to a large volume of information, or we incur third party costs in providing you with access.
We may request to verify your identity before responding to any request.
If we decide not to provide you with access to or correct your personal information, we will give you reasons for our decision.
10. Lodging a complaint
If you have a complaint about how we handled your personal information, please contact us using the contact details below. Please note that we will ask you to lodge your complaint in writing.
We will acknowledge receipt of your complaint as soon as possible after receiving your complaint in writing. We will then investigate the circumstances of your complaint and provide you with a response within a reasonable timeframe.
f you are not satisfied with how your complaint is handled by us, then you may lodge a formal complaint with the Office of the Australian Information Commissioner at:
- Telephone: 1300 363 992 (if calling from outside Australia including Norfolk Island please call: +61 2 9284 9749)
- National Relay Service:
- TTY users phone 133 677 then ask for 1300 363 992
- 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
- Post: Office of the Australian Information Commissioner, GPO Box 5218, SYDNEY NSW 2001
- Fax: +61 2 9284 9666
- Email: email@example.com
- Website: www.oaic.gov.au/privacy/making-a-privacy-complaint
11. Contacting us
- By post at: Sugar Terminals Limited, GPO Box 945, BRISBANE QLD 4001
- By email: firstname.lastname@example.org
- By phone: (07) 3221 7017
12. Changes to this Policy