The Privacy Policy (the Privacy Policy) applies to Danakali Limited (ACN 097 904 302) , contact details info@danakali.com Brookfield Place, Level 11, 125 St Georges Terrace, Perth WA 6000, Australia and its related entities and any subsidiaries of the company, including but not limited to STB Eritrea Pty Ltd (ACN 137 639 359), (collectively defined in this Privacy Policy as Danakali or the Company) and all staff anywhere in the world.

Aligned to Danakali’s value of Integrity and in accordance with the Company’s Code of Conduct, this Privacy Policy affirms the Company’s responsibility and commitment to protect the privacy of individuals’ personal information. This Privacy Policy sets out the principles that Danakali will follow in collecting, using, holding, disclosing and otherwise managing personal information.

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

• “Personal Information” is defined as information and data, relating to an identified or identifiable natural person that is collected, used, disclosed or processed in any other manner by or on behalf of Danakali; and
• Danakali Limited is considered the “data controller” who is responsible for the Personal Information that it collects, uses, and manages in connection with this Privacy Policy.

Danakali is bound by the Privacy Act 1998 (Commonwealth Act), the Australian Privacy Principles that are contained in that Act, and other applicable data protection and privacy laws.

Collection of Personal Information from Data Subjects

Danakali may collect Personal Information about an individual in a variety of ways, including when an individual interacts with Danakali in person or electronically, for example, when an individual accesses our website.

The Company collects Personal Information from a range of individuals in the context of its business activities, including:

• Collecting Personal Information from shareholders for the purposes of enabling proper records to be kept and for reporting purposes;
• Collecting Personal Information from individuals who enter into service agreements, joint venture agreements or other transactions with Danakali for the purpose of administering those agreements or transactions or for reporting purposes; and
• Collecting Personal Information from representatives of our suppliers, customers, sponsors and business partners, users of the Danakali website, and job applicants.

We collect Personal Information from you where it is relevant for our purposes as further detailed below.

If you do not provide us with the Personal Information described in this Privacy Policy, some or all of the following may happen:

• Danakali may not be able to provide you with the requested products or services, either to the same standard or at all; or
• Danakali may not be able to provide you with information that you may want to hear.

Purpose of Processing and Categories of Data

Danakali may collect a range of Personal Information in a business context, such as your name, gender, job title, photographic identification, email address, home address and other contact details, details of your business and other interests, experience and/or academic and professional qualifications, third party references, communications with you (including notes from meetings and telephone call recordings), feedback or survey responses that you provide to us, financial and payment information, and information collected from clearance questionnaires and/or interviews.

Danakali uses Personal Information collected from you for business-related purposes, including negotiating, concluding and performing contracts, managing business relationships, administering real estate leases and licences, recruitment, conducting clearance procedures, managing accounts, and records, communicating with you and third party contacts, supporting sustainability activities, security, legal, regulatory and internal investigations, and debt administration.

At times, the Company may ask you to supply Personal Information, such as your name, email address, location, telephone number and preferred means of communication, for purposes such as subscribing to Danakali news alerts or requesting further information from Danakali, including through the Contact Us Form available on our website.  In such case we will use Personal Information you gave us to provide you with the information or services that you have requested from us.

Legal Basis for Processing of Personal Information

In order to comply with applicable data protection and privacy laws, Danakali is 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 Danakali 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;
• Danakali or our third parties’ legitimate business interests; or
• Compliance with our legal obligations.

Website

When you use our website, Danakali collects certain standard information that is sent by your browser to our website. This includes technical information, such as your IP address, browser type, operating system, language, time zone setting, access times, and any referring website addresses.

The Company uses this information to administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical, and survey purposes. Danakali also collects certain information to provide users with a personalised experience when visiting our websites. Through the use of a ‘cookie,’ Danakali can record information about your visit to our website including the clickstream to, through and from our site (including date and time), the pages visited, page interaction information and methods used to browse away from the page. This information is used anonymously and in aggregate and is collected and logged for statistical purposes. Through analysis of these records, we are able to provide an improved service when users revisit our websites. See below for information on our use of cookies and related technologies.

Other than as stated in this Privacy Policy, no attempt is made to identify our website users or their browsing activities except it is our mandatory legal obligation to do so.

Access to Other Websites via Hyperlink

Other websites that may be accessible via hyperlinks from the Danakali website are owned and operated by third parties and are not subject to the Danakali Privacy Policy. The Company has 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.

Cookies and Related Technologies

Our websites uses cookies. A cookie is a small text file that is placed on your computer or mobile device when you visit a website. 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.

Danakali uses first and third party cookies and other technologies to facilitate your internet sessions, offer you services according to your preferred settings, track use of our website, and to compile statistics about activities carried out on our website and for advertising purposes.

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 and apps.

Sensitive Personal Information

Sensitive Personal Information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, health or medical conditions, genetic or biometric information, sexual orientation, or criminal convictions and offences may be collected and used or processed by Danakali if such collection and use or processing is necessary to comply with laws and regulations or where you provide this information voluntarily.

Email Monitoring

Danakali may monitor emails sent to and from its workforce, which may contain Personal Information relating to third parties. The information contained in such emails may be used for business-related purposes, for example when investigating incidents within the Company. Although Danakali endeavours not to review the contents of personal emails, there may be occasions on which this is necessary, for example, to investigate a breach of security within the Company, or in the context of legal proceedings.

Disclosure of the Information We Collect

Danakali may share your Personal Information with people within the company 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 the Company.

We may disclose your Personal Information to third parties including the authorities, Danakali’s advisors, suppliers of IT services and third parties engaged by Danakali 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; to respond to a legal request or comply with a legal obligation, and to enforce Danakali’s website Terms and Conditions of Use.

We may 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. Danakali may also disclose the Personal Information you provide to us within the job application process to our HR practitioners, Hiring Managers, and to recruitment advisors for the purpose of considering you for career opportunities with the Company.

Because Danakali operates in several jurisdictions, we may share the Personal Information you submit to us with any entity within the Company. 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.

Transfer of Personal Information to Other Countries

Please note that any person to whom Danakali 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.

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 the applicable laws. You can request a copy of the safeguards which we have put in place to protect your Personal Information and privacy rights in these circumstances, using the Contact Us Form available on our website.

Security and Retention of Personal Information

Danakali may hold your Personal Information in electronic or physical format. Danakali will take reasonable steps to ensure that the personal information that it holds is protected from misuse, interference, and loss and from unauthorised access, modification, and disclosure. However, the internet is an unsecure environment. Danakali cannot guarantee the security of the information it receives from electronic means.

Danakali keeps your Personal Information for no longer than is necessary for regulatory or business reasons. The amount of time that records are kept varies depending upon the purpose of processing and the type of Personal Information they contain.

Your Rights in Relation to Your Personal Information

You have the right to access the Personal Information that Danakali holds about you. If you would like to access or obtain a copy (which may be in machine-readable form) of the Personal Information Danakali holds about you, please send a request on the Contact Us Form available on our website.

Danakali endeavours to ensure that the Personal Information it holds 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 or ask for restriction of the processing of any of the Personal Information we hold about you, if you want to exercise your right to data portability or you want to object to legitimate interest we use as legal basis for processing, or if you want to withdraw your consent, again please send a request via the form on our website.

Please note that if you withdraw your consent for processing, this will not affect the lawfulness of processing based on consent before its withdrawal.

There may be certain circumstances where Danakali Limited will not accept your request to exercise certain rights, based on the application of the relevant laws. If that happens, we will give you written reasons for any refusal.

Complaints and Concerns

Danakali takes complaints very seriously and will respond shortly after receiving written notice of the complaint.

If you have a concern or complaint about how Danakali has used your Personal Information, as a first step, please raise this in writing with the Company Privacy Officer, using the contact details available on our website, below or via the Contact Us Form.

If you are not satisfied with the handling of your concern or complaint by Danakali, you may escalate this to your national Data Protection Authority, in Australia this is the Office of the Australian Information Commissioner.

Changes to This Privacy Policy and Contact

Danakali may amend this Privacy Policy from time to time. Any changes Danakali may make to this Privacy Policy in the future will be posted on this page.

Questions, comments and requests regarding this Privacy Policy are welcomed and should be submitted via the Contact Us Form available on our website.

Further Guidance

If you require any guidance on this Privacy Policy, please contact the Privacy Officer to find out more information. Our Privacy Officer can be contacted at the contact details below:

Privacy Officer
Danakali Limited
Level 11, Brookfield Place
125 St Georges Terrace
Perth, Western Australia 6000
Phone: +61 8 6189 8635
Email: info@danakali.com