This Privacy Statement is effective as of January 2019.

At Astracore we recognise the importance of protecting your personal information and are committed to processing it responsibly and in compliance with applicable data protection laws in all countries in which Astracore operates.

This Privacy Statement describes Astracore's general privacy practices that apply to personal information we collect, use and share about consumers and other individuals within our clients, business partners, supplier and other organisations with which Astracore has or contemplates a business relationship.

Why and how we collect and use your personal information

We may collect your personal information as an individual for various purposes, such as the following:

• Access and use of websites or other online services
  When entering one of our websites, or using an online service, we will record information necessary to provide you with access, for the operation of the website and for us to comply with security and legal requirements in relation to operating our site, such as passwords, IP address and browser settings. We also collect information about your activities during your visit in order to personalise your website experience, such as recording your preferences and settings, and to collect statistics to help us improve and further develop our websites, products and services.
• Responding to your request for information, order, or support
  When you contact us (online or offline) in connection with a request for information, to order a product or service, to provide you with support, or to participate in a forum or other social computing tool, we collect information necessary to fulfill your request, to grant you access to the product or service, to provide you with support and to be able to contact you. For instance, we collect your name and contact information, details about your request and your agreement with us and the fulfilment, delivery and invoicing of your order and we may include client satisfaction survey information. We retain such information for administrative purposes, defending our rights, and in connection with our relationship with you.
  
  When you provide your name and contact information to register in connection with such a request, the registration may serve to identify you when you visit our websites. For ordering of most services and products we require you to have registered an Astracore id. Registration may also allow you to customise and control your privacy settings.
• Your use of Astracore Cloud services
  We collect information about your use of Astracore Cloud services to enable product features to operate, improve your user experience, tailor our interactions with you, inform our clients on the overall use of the services, provide support and improve and develop our products and services. For details regarding the technologies we employ, the personal information we collect, as well as how to control or block tracking or to delete cookies, please refer to the Astracore Online Privacy Statement.
• Contacting employees of our clients, prospects, partners and suppliers
  In our relationship with clients or prospects, partners and suppliers, they also provide us with business contact information (such as name, business contact details, position or title of their employees, contractors, advisors and authorised users) for purposes such as contract management, fulfilment, delivery of products and services, provision of support, invoicing and management of the services or the relationship.
• Visitor information
  We register individuals visiting our sites and locations (name, identification and business contact information) and use camera supervision for reasons of security and safety of persons and belongings, as well as for regulatory purposes.
• Marketing
  Most information we collect about you comes from our direct interactions with you. When you register for an event we may collect information (online or offline) in relation to the event organisation, and during an event, such as participation in sessions and survey results. We combine the personal information we collect to develop aggregate analysis and business intelligence for conducting our business and for marketing purposes. You can choose to receive information by email, telephone or postal mail about our products and services, or sign-up for subscriptions. When visiting our websites or using our services we may provide you with personalised information. You can always opt-out from receiving personalised communication by sending an e-mail to NETSUPP@us.ibm.com. More information can be found in the Astracore Online Privacy Statement.

Where we reference that we use your personal information in connection with a request, order, transaction or agreement (or preparing for the same), or to provide you with services that you requested (such as a website), we do this because it is necessary for the performance of an agreement with you.

Where we reference that we use your personal information in relation to marketing, improvement or development of our products or services, for reasons of safety and security, or regulatory requirements other than in connection with your agreement or request, we do this on the basis of our or a third party’s legitimate interests, or with your consent. When we collect and use your personal information subject to the EU Privacy Legislation this may have consequences for Your Rights.

Sharing of Personal Information

Where appropriate, Astracore may share your personal information with selected partners to help us provide you, or the company you work for, products or services, or to fulfill your requests, or with your consent. When selecting our suppliers and partners, we take into account their data handling processes.

If Astracore decides to sell, buy, merge or otherwise reorganise businesses in some countries, such a transaction may involve the disclosure of personal information to prospective or actual purchasers, or the receipt of such information from sellers. It is Astracore's practice to require appropriate protection for personal information in these types of transactions.

Please be aware that in certain circumstances, personal information may be subject to disclosure to government agencies pursuant to judicial proceeding, court order, or legal process. We may also share your personal information to protect the rights or property of Astracore, our business partners, suppliers or clients, and others when we have reasonable grounds to believe that such rights or property have been or could be affected.

International Transfers

The international footprint of Astracore may involve transfers of personal information between different jurisdictions, as well as to third parties located in the countries where we do business. Some countries have implemented transfer restrictions for personal information, in connection with which Astracore takes various measures, including:

• Where required, Astracore implements Standard Contractual Clauses approved by the EU Commission, or similar contractual clauses in other jurisdictions. This includes transfers to suppliers or other third parties.

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Information Security and Accuracy

We intend to protect your personal information and to maintain its accuracy. Astracore implements reasonable physical, administrative and technical safeguards to help us protect your personal information from unauthorised access, use and disclosure. For example, we encrypt certain sensitive personal information such as credit card information when we transmit such information over the Internet. We also require that our suppliers protect such information from unauthorised access, use and disclosure.

Retention Period

We will not retain personal information longer than necessary to fulfill the purposes for which it is processed, including the security of our processing complying with legal and regulatory obligations (e.g. audit, accounting and statutory retention terms), handling disputes, and for the establishment, exercise or defense of legal claims in the countries where we do business.

How to contact us

If you have a question related to this Privacy Statement, please contact us at info@astracore.com . Your message will be forwarded to the appropriate member of Astracore's Data Privacy Team, such as Data Protection Officers or members of their teams.

For the purposes of the EU General Data Protection Regulation (GDPR), the controller of your personal information is Good Grahams Pty. Ltd., Australia, Trading as Astracore, unless indicated otherwise.

Your Rights

You can request to access, update or correct your personal information. You also have the right to object to direct marketing.

You may have additional rights pursuant to your local law applicable to the processing. For example, if the processing of your personal information is subject to the EU General Data Protection Regulation ("GDPR"), and your personal information is processed based on legitimate interests, you have the right to object to the processing on grounds relating to your specific situation. Under GDPR you may also have the right to request to have your personal information deleted or restricted and ask for portability of your personal information.

Right to Lodge a Complaint

In the event you consider our processing of your personal information not to be compliant with the applicable data protection laws, you can lodge a complaint:

• Directly with Astracore by emailing info@astracore.com
• With the competent data protection authority. The name and contact details of the Data Protection Authorities in the European Union can be found at http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm.

Changes to our Privacy Statements

From time to time we may update this Privacy Statement, as well as any other specific privacy statement. When making changes to this Privacy Statement, we will add a new date at the top of this Privacy Statement.