Privacy policy.
GEOZEN RESOURCES GROUP
PRIVACY POLICY
Last updated: 3 September 2026
1. WHO WE ARE
This Privacy Policy is issued jointly by:
Geozen Resources Group Co., Limited
Unit B, 25/F, Far East Finance Centre, 16 Harcourt Road, Admiralty, Hong Kong
Business Registration Number: 69242267
Geozen Resources (Australia) Pty Ltd
804/370 Pitt Street, Sydney NSW 2000, Australia
ABN: 13 680 333 804
(together, "Geozen", "we", "us" or "our").
We are committed to protecting the privacy of the personal information
and personal data we handle. This Policy explains how we collect, hold,
use and disclose personal information in accordance with:
- the Privacy Act 1988 (Cth) and the Australian Privacy Principles
("APPs"), in respect of our Australian operations; and
- the Personal Data (Privacy) Ordinance (Cap. 486) ("PDPO") and its
Data Protection Principles, in respect of our Hong Kong operations.
Where this Policy refers to "personal information", the term includes
"personal data" as defined under the PDPO.
2. WHAT WE COLLECT
Depending on your dealings with us, we may collect:
a. Identity and contact details - your name, title, organisation,
postal address, email address and telephone number, for example
when you contact us through our website or correspond with us.
b. Professional and investment information - information about your
professional background, investor classification or wholesale/
professional investor status, investment preferences and the
nature of your interest in working with us.
c. Verification information - where required by law (including
anti-money-laundering and counter-terrorism financing laws in
Australia and Hong Kong), identity documents and related
verification records.
d. Correspondence - records of your communications with us.
e. Website and technical data - information collected automatically
when you visit our website, such as IP address, browser type,
device information, pages visited and referring pages. Our website
is hosted on third-party infrastructure and includes third-party
components (for example, embedded market-data widgets and web
fonts) that may collect technical data subject to their own
privacy policies.
We do not knowingly collect sensitive information (such as health
information, or information about racial or ethnic origin, political
opinions or religious beliefs) and ask that you do not provide it to us.
3. HOW WE COLLECT IT
We collect personal information directly from you when you contact us,
meet with us, correspond with us or use our website. We may also collect
information from publicly available sources, from your advisers or
representatives with your authority, and from third-party service
providers engaged for identity verification or compliance screening.
If you provide us with personal information about another person (for
example, a colleague or co-investor), you must ensure you are authorised
to do so and that the person is aware of this Policy.
4. WHY WE COLLECT AND USE IT
We collect, hold and use personal information for the following
purposes:
a. to respond to your enquiries and communicate with you;
b. to assess and manage actual or potential investment, co-investment
or business relationships;
c. to carry out due diligence, verification and compliance checks
required or authorised by law;
d. to perform our contractual and legal obligations;
e. to operate, maintain and improve our website;
f. to keep records required for legal, regulatory, accounting and
risk-management purposes; and
g. with your consent, to send you updates and materials about Geozen
and our activities.
We will only use personal data for the purposes for which it was
collected or a directly related purpose, unless we have your consent or
the use is otherwise permitted by law.
5. DIRECT MARKETING
We will only use your name and contact details to send you marketing or
promotional communications where you have consented to receive them or
where otherwise permitted by applicable law. In respect of data subject
to the PDPO, we will not use your personal data in direct marketing
without your consent or indication of no objection.
You may opt out of receiving marketing communications at any time, free
of charge, by contacting us using the details in section 12 or by using
any unsubscribe facility included in a communication. We will action
opt-out requests as soon as practicable.
6. WHO WE DISCLOSE IT TO
We may disclose personal information to:
a. related entities within the Geozen group, including between our
Hong Kong and Australian entities;
b. our professional advisers, including lawyers, accountants,
auditors and compliance consultants;
c. service providers who assist us to operate our business, such as
IT, website hosting, data storage, identity verification and
communications providers;
d. counterparties and their advisers in connection with transactions
you are involved in, where appropriate; and
e. regulators, government agencies, courts, exchanges and law
enforcement bodies where required or authorised by law.
We do not sell personal information.
7. CROSS-BORDER TRANSFERS
Because we operate in both Hong Kong and Australia, personal information
may be transferred between those jurisdictions, and may be stored on
servers located in other jurisdictions used by our hosting and IT
service providers.
Where we disclose personal information collected in Australia to
recipients outside Australia, we take reasonable steps as required by
APP 8 to ensure the overseas recipient handles it consistently with the
APPs, unless an exception applies. Where we transfer personal data from
Hong Kong, we take steps to ensure it is protected to a standard
comparable to that required under the PDPO.
8. SECURITY
We take reasonable steps, and implement appropriate technical and
organisational measures, to protect the personal information we hold
from misuse, interference, loss, and unauthorised access, modification
or disclosure. These measures include access controls, use of reputable
service providers and staff confidentiality obligations. No method of
transmission or storage is completely secure, and we cannot guarantee
absolute security of information transmitted over the internet.
9. RETENTION
We retain personal information only for as long as it is needed for the
purposes for which it was collected, or as required by applicable law
(including company, tax and anti-money-laundering record-keeping
requirements). Personal data will not be kept longer than is necessary
for the fulfilment of the purpose for which it is used, after which it
will be deleted or de-identified.
10. COOKIES, ANALYTICS AND THIRD-PARTY CONTENT
Our website may use cookies and similar technologies provided by our
hosting platform to enable site functionality and to collect aggregated
statistics about site usage. You can control or disable cookies through
your browser settings; some features of the site may not function fully
if cookies are disabled.
Our website includes content served by third parties, including embedded
market-data widgets (for example, TradingView), web fonts and links to
external sites such as the Australian Securities Exchange. These third
parties may collect technical data (such as your IP address) when the
content loads. Their handling of that data is governed by their own
privacy policies, and we encourage you to review them. We are not
responsible for the privacy practices of external websites.
11. ACCESS, CORRECTION AND YOUR RIGHTS
You may request:
a. access to the personal information we hold about you; and
b. correction of personal information that is inaccurate, out of
date, incomplete or misleading.
Requests may be made using the contact details in section 12. We will
respond within a reasonable time and, for requests subject to the PDPO,
within the timeframe prescribed by the Ordinance. We may need to verify
your identity before actioning a request. We may charge a reasonable fee
for processing a data access request where permitted by law; we will not
charge for making a correction. If we refuse a request, we will give you
written reasons and information about how you may complain.
12. CONTACT US
Questions, requests or complaints about privacy may be directed to:
Privacy Officer / Data Protection Officer
Geozen Resources Group
Hong Kong: Unit B, 25/F, Far East Finance Centre, 16 Harcourt Road,
Admiralty, Hong Kong
Australia: 804/370 Pitt Street, Sydney NSW 2000, Australia
Or via the contact form on our website: www.geozen-group.com/contact
13. COMPLAINTS
If you have a concern about how we have handled your personal
information, please contact us first using the details above. We take
complaints seriously and will investigate and respond within a
reasonable period.
If you are not satisfied with our response:
- In Australia, you may complain to the Office of the Australian
Information Commissioner (OAIC), www.oaic.gov.au.
- In Hong Kong, you may complain to the Office of the Privacy
Commissioner for Personal Data (PCPD), www.pcpd.org.hk.
14. CHANGES TO THIS POLICY
We may update this Policy from time to time to reflect changes in our
practices or in applicable law. The current version will always be
available on our website, with the "Last updated" date shown at the top.
Your continued dealings with us after an update constitutes acceptance
of the revised Policy to the extent permitted by law.
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This Policy is provided in English. If a Chinese translation is made
available, the English version prevails to the extent of any
inconsistency.