Privacy Policy

Taronga Mines Pty Ltd (ACN 126 854 288) Privacy Policy

Last Updated: 5th June 2025

1. Introduction

Taronga Mines Pty Ltd (ACN 126 854 288) ("we", "us", "our" or "wholly owned subsidiary of First Tin PLC") is committed to protecting the privacy of individuals and ensuring the security of personal information. This Privacy Policy outlines how we collect, use, disclose, and protect personal information in compliance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).

We are legally bound by the APPs and are committed to handling personal information responsibly and securely.

2. Collection of Personal Information

We collect personal information in various ways, including but not limited to:

  • Direct interactions: When individuals communicate with us via email, phone, or in person (e.g., community engagement events, employment applications, or sponsorship enquiries).
  • Website interactions: When individuals submit forms on our website or sign up for newsletters.
  • Automated collection: When users interact with our website, certain information (such as IP addresses and browsing behaviour) may be collected via cookies and analytics tools.

The types of personal information we collect may include:

  • Name
  • Address
  • Phone number
  • Email address
  • Employment-related details (availability, experience, resumes, health, etc.)
  • Communications and inquiries made to us

We will only collect personal information when it is reasonably necessary for one or more of our functions or activities.

3. Use and Disclosure of Personal Information

We use personal information for various purposes including:

  • Responding to enquiries and feedback
  • Managing employment and contracting opportunities
  • Sending newsletters and updates
  • Handling sponsorships, environmental matters, and road safety initiatives

Personal information will only be disclosed:

  • For the purpose it was collected
  • For a related purpose that would be reasonably expected
  • As required by law
  • With the individual's explicit consent

Examples of third parties we may disclose personal information to include:

  • Mailchimp (for managing newsletters and marketing communications)
  • Google Analytics (for website performance monitoring)
  • Government agencies and regulatory authorities, if legally required
  • Service providers who assist us in carrying out our functions (these providers are required to maintain confidentiality)

We do not sell or disclose personal information for marketing purposes.

4. Data Security Practices

We employ industry-leading security measures to safeguard personal information:

Encryption & Data Protection

  • Industry-standard encryption methods are used to ensure the confidentiality and integrity of personal data, both in transit and at rest.
  • Advanced cryptographic techniques are implemented to protect sensitive information from unauthorised access and potential cyber threats.
  • Robust key management practices ensure encryption keys remain secure and inaccessible to unauthorised entities.

Secure Data Synchronization

  • Encrypted data is temporarily stored on a public-facing webserver with strict access controls.
  • A secure automated sync script regularly fetches encrypted data and transfers it to an internal private server that is inaccessible to the public.
  • Data is decrypted only after transfer and securely stored in an internal database.
  • Successfully synced records are deleted from the webserver after completion.

Access Restrictions

  • Role-Based Access Control (RBAC) ensures only authorised personnel can access sensitive data.
  • Multi-Factor Authentication (MFA) is enforced for administrative users.
  • Audit Logs track all access and modifications to sensitive data.

Data Retention & Deletion

  • We retain personal data only as long as required for business or legal purposes.
  • Once no longer necessary, personal information is securely deleted or anonymised, subject to any legal obligations.

5. Access to and Correction of Personal Information

Individuals can request access to or correction of their personal information by contacting us at admin.taronga@firsttin.com.

We will provide access unless:

  • It would have an unreasonable impact on the privacy of others
  • It would reveal commercially sensitive information
  • Providing access would be unlawful

If a request for correction cannot be fulfilled, we will provide a written explanation.

6. Complaints and Concerns

If you have concerns about how we handle your personal information, you may contact us at admin.taronga@firsttin.com. We will:

  • Acknowledge receipt of your complaint within 5 business days
  • Investigate and respond within a reasonable timeframe
  • Take appropriate corrective actions if necessary

If you are not satisfied with our response, you may contact the Office of the Australian Information Commissioner (OAIC).

7. Cookies and Tracking Technologies

We use cookies and tracking technologies, including:

  • Analytics Cookies (Google Analytics) for monitoring visitor behaviour and improving website performance.
  • Marketing Cookies (Mailchimp) for managing newsletter subscriptions.

Users can manage cookie preferences via their browser settings.

8. reCAPTCHA and Bot Protection

We use Google reCAPTCHA v3 to protect our website forms from spam and automated abuse. This service:

  • Collects information about user interactions with our website to assess whether the user is human or an automated bot.
  • Processes data including IP addresses, browser information, and user behaviour patterns.
  • Operates invisibly in the background without requiring users to solve puzzles or challenges.
  • Helps protect our contact forms, job applications, newsletter signups, and admin login from malicious activity.

Data Processed by reCAPTCHA:

  • IP address
  • Browser and device information
  • Mouse movements and click patterns
  • Time spent on pages
  • Cookies and similar tracking technologies

This information is processed by Google in accordance with their Privacy Policy and Terms of Service. The data is used solely for security purposes and to improve the reCAPTCHA service.

Legal Basis: We process this information based on our legitimate interest in protecting our website and users from spam, fraud, and abuse.

Data Retention: Google retains reCAPTCHA data for varying periods as outlined in their privacy policy. We do not store reCAPTCHA data beyond what is necessary for security logging and monitoring purposes.

9. Cross-Border Disclosure

Personal information may be processed in the following locations:

  • United States (Mailchimp, Google reCAPTCHA)
  • United Kingdom (Website hosting)

We ensure that all international data transfers comply with applicable privacy laws.

10. Changes to this Privacy Policy

This Privacy Policy is reviewed periodically. The Last Updated date at the top reflects the latest changes.

If significant updates are made, we will notify individuals via our website and email notifications.

11. Contact Us

For any privacy-related enquiries, please contact us at:

Email: admin.taronga@firsttin.com