PRIVACY POLICY

Soprano Design Limited, Redcoal Pty Ltd and their related bodies corporate (collectively, Soprano Design) respect your privacy and the security of your personal information. It is important to us that the information you provide to Soprano Design and the knowledge the company holds about you is kept in accordance with applicable privacy legislation.

Privacy legislation places certain requirements on Soprano Design in relation to the personal information we collect, hold and handle. Nothing in this privacy policy is intended to limit Soprano Design’s obligations or permitted handling of personal information under applicable privacy legislation. To the extent that any applicable privacy legislation includes any exceptions and exemptions, we may make use of those exceptions and exemptions to the extent that they are applicable to Soprano Design.

Collection of Personal Information

Depending on the particular circumstances, Soprano Design may collect personal information about you in connection with the provision of our products and services, including our secure messaging and website products and services. The personal information Soprano Design collects may (amongst other things) include your name, date of birth, contact details (including your email, home or billing address and telephone number), user names and passwords, internet address and screen name, the type of computer or device you are using as well as information about your use of our products and services. We may also collect personal information about your communications, interactions and transactions with us, including any contact we have with you by telephone, text message or email.

In relation to job applicants, we will collect, use and disclose your personal information for the purpose of assessing your application and your suitability for the role advertised and for other roles that may become available in the future.

Where practicable, we will collect personal information from you directly. We also collect and handle personal information as a data processor on behalf of our corporate clients in the course of providing them with our secure messaging and website products and services. We handle personal information provided by our corporate clients in accordance with their lawful directions. We may also collect personal information from our share registry service provider, your organisation, your representatives (e.g. your broker), information service providers, our related companies and other trusted parties with whom we exchange information and also from public sources. By accepting this privacy policy, you specifically consent to those third parties providing us with your personal information.

Use and Disclosure of Personal Information

We collect, hold, use and disclose personal information to conduct our business activities and comply with legal, regulatory, business, stakeholder and research requirements. Soprano Design collects information from a range of sources to provide, administer, improve and personalise our products and services (including messaging and website services) and customer experience. Soprano Design uses the information we collect to understand your needs, interests and behaviour, verify your identity and personal information, maintain and update our records, manage our relationship with you, conduct product and market research, train and manage our people, protect our lawful interests and deal with enquiries and disputes. Soprano Design may, on occasion, use your information to notify you of any important changes to our website or this policy. We may also collect, hold, use and disclose your personal information in relation to lawful requests from courts, government agencies and lawyers, suspected unlawful activity and acquisitions or potential acquisitions of our business or assets.

The provision by you of your personal information to us is voluntary. If you choose not to provide your information, Soprano Design may not be able to do some or all of the things described in this policy. For example, we may not be able to provide a particular service or product to you. We hope that you will find it beneficial to provide information about yourself to us, or to authorise us to collect information about you from other persons.

If you provide information about any other person, you represent and agree that you have obtained their consent to disclose their information to Soprano Design for it to use that information for the purposes set out in this policy.

Soprano Design has operations in Australia, New Zealand, Europe, North America, South America, and Southeast Asia. We may exchange your personal information with your and our representatives, trusted affiliates, regulatory authorities, the Australian Stock Exchange and with our service providers. Our service providers include those that assist us with archival, auditing, accounting, customer contact, legal, business consulting, banking, payment, mailing, delivery, data processing, data analysis, document management, information broking, research, share registry, investigations, insurance, website and technology services. Some of these third parties may be located in Australia, the United Kingdom, Spain, the Netherlands, Belgium, Romania, United States, Brazil, Colombia, Chile, Singapore, Malaysia, the Philippines and other countries. Where we transfer your personal information outside of your country, we take steps to ensure that your information is treated securely. You agree that we may use and share your information in the manner described in this policy and accept that the obligations imposed by privacy laws in these and other countries may be less stringent than the requirements established by the privacy laws in your country.

In relation to job applicants, we may exchange personal information with academic institutions, recruiters, screening check providers, health service providers, professional and trade associations, law enforcement agencies, referees and your current, previous and prospective employers as part of our consideration of your suitability for potential employment or engagement with Soprano.

If you are a customer of Soprano Design, your personal information may be used to inform you on an ongoing basis of additional products and services or special promotions that may be of interest to you. That is, Soprano Design may contact you about such products, services or promotions by electronic messages (e.g. email), online (e.g on the Soprano Design website) and by other means, unless you opt out or Soprano Design is subject to legal restrictions. You can choose not to receive such information when you are registering for a product or service on the Soprano Design website. Soprano Design’s electronic marketing communications will provide you with a simple means to opt out of receiving similar communications in the future.

Investors

If you apply for or do invest with Soprano Design, we may collect information we receive from you in subscription agreements and other related documents and forms and information about your transactions with us and our related bodies corporate. We collect, use and disclose your personal information to assess your application, manage your investment with us and provide investor services. We may exchange your personal information with our investment registry service providers and they may also exchange your personal information with other services providers of the kinds described above in this privacy policy. We are required or authorised to collect your personal information under certain laws including the Australian Income Tax Assessment Acts 1936 and 1997 (Cth) and the Corporations Act 2001 (Cth), and we are also required to make limited shareholder details available to members of the public on request.

Privacy and Security

Soprano Design implements a number of security measures to protect personal information and to avoid any unauthorised use, modification or disclosure. Our focus is on maintaining and improving existing security systems as well as taking steps directed towards complying with internationally recognised standards of personal data privacy protection (where applicable). For example, depending on the circumstances, we may make use of electronic access controls, premises security and network firewalls. We may hold personal information electronically and in hard copy form, both at our own premises and with the assistance of our service providers. We retain personal information for as long as is necessary to fulfil the purposes described in this privacy policy and deal with disputes unless a longer period is required or authorised by law.

The transmission of information via the internet and other electronic means is not completely secure. Soprano Designs takes reasonable steps to protect your personal information once it is in our possession, however we cannot guarantee the security of your data transmitted to us via the internet or by other electronic means.

Cookies

The Soprano Design Mobile Enterprise Messaging (MEMS) platforms employ the use of ‘cookies’. A ‘cookie’ is a small piece of data sent from a website and stored in a user’s web browser while a user is browsing or using a website. When the user browses or uses the same website in the future, the data stored in the cookie can be retrieved by the website to notify the website of the user’s previous activity. Cookies allow our platforms to track user sessions and interaction preferences on our MEMS portal. In addition, cookies assist us to quantify visitor information including; user name, date, time, areas visited and length of time spent visiting. These cookies are stored with permission on your local computer and tracked by website managers to identify new and registered users’ behaviour. The use of cookies is predominantly for website monitoring, measurement and improving user experience. Please note; if you delete or disable our cookies you will not be permitted to login to our MEMS portal.

Google AdWords and Website Beacons

The Soprano Design website may use the Google AdWords remarketing service to advertise on third party websites (including Google) to previous visitors to our site. It could mean that we advertise to previous visitors who have not completed a task on our site, for example using the contact form to make an enquiry. This could be in the form of an advertisement on the Google search results page, or a site in the Google Display Network. The Soprano Design website may also use other services such as Google Analytics from time to time. Third-party vendors, including Google, use cookies to serve ads based on someone’s past visits to the Soprano Design website. Any data collected by us will be used, held and disclosed by us in accordance with this privacy policy.

For more information about how Google collects and processes data, please see Google’s privacy policy and their information at www.google.com/policies/privacy/partners.

Electronic Records and Communications

In some jurisdictions, including Columbia, a printed version of this document and of any notice given in electronic form shall be admissible in judicial or administrative proceedings based upon or relating to this policy to the same extent and subject to the same conditions as other business documents and records originally generated and maintained in printed form.

Your Privacy Concerns

You can contact us (as set out below) if you have any questions, comments or concerns about our handling of your personal information. We will respond to let you know who will be handling your matter and when you can expect a further response. We may request additional details from you regarding your concerns, and may need to engage or consult with other parties in order to investigate and deal with your issue. We will keep records of your request and any resolution. For information about privacy generally, or if your concerns are not resolved to your satisfaction, you may contact the government agency or judicial body in your country that administers the applicable privacy law.

• In Australia, you may contact Office of the Australian Information Commissioner at www.oaic.gov.au and on 1300 363 992.

• In the UK, you may contact the Information Commissioner’s Office at www.ico.org.uk and on 0303 123 1113.

• In New Zealand, you may contact the Office of the New Zealand Privacy Commissioner at www.privacy.org.nz and on 0800 803 909.

How you can access, correct or delete your information

Soprano Design respects your right to oppose the processing of your personal information by us and to request access to and the correction or deletion of personal information about you held by us. You can contact us (as set out below) to request access to or the correction or deletion of your personal information. You may also exercise your right to oppose the processing of your information by Soprano Design. In normal circumstances we will give you full access or make the requested corrections to, or deletion of, your information. However, there may be some lawful reasons to deny these requests. If your request is denied, we will provide you with reasons to explain the denial. Where we decide not to make a requested correction to, or deletion of, your personal information and you disagree with our decision, you may ask us to make a note of your requested correction/deletion.

Contacting Soprano Design Information Management Officer

Requests to access, correct or delete any of your personal information held by us, or for any questions regarding our privacy policy, or if you have any privacy concerns about our handling of your personal information, please contact:

Personal Information Management Officer, Soprano Design

E: info@sopranodesign.com

T: +61-2-9900-2200

Amendments to this policy

Soprano Design may update this privacy policy from time to time. We encourage you to visit this page regularly to see the latest version of our privacy policy. If any changes relate to the purported handling of your information, we may also take steps to notify you of these in a timely fashion in accordance with the requirements of the privacy laws as may be required by the privacy laws in your country.

Last updated: 27 July 2017