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OPERATIONS PRIVACY POLICY

This policy relates to how we use your data in our business operations. This is in addition to our website privacy policy which summaries how the information we collect about you on the website is used by us.

All Star Minerals Plc (‘ASMO’) will be the organisation which has control of your data (the data controller). ASMO is Incorporated in England and Wales with Company Registration Number 04228788 and the registered address 165 Fleet Street, London, England, United Kingdom, EC4A 2DY. ASMO is registered with the UK Information Commissioner’s Office on the Data Protection Register, registration number ZB119152. 

We follow legal requirements and best practice for implementing obligations under the Data Protection Act 2018 and GDPR legislation.

This document is a summary of how we collect and use your personal information. If you would like more details about how we collect and use your personal information, please contact us.

This policy was last updated 01st September 2021. Any changes we may make to our privacy policy in the future will be posted on this page.

Why We Use Your Personal Information

As part of our service to our clients, we need to collect various information from you in order to provide those services. In some cases, this is to fulfil contractual obligations with our clients, and otherwise is required for us to provide an explicit service, in which case we make it clear why we need that information and by providing the information you are consenting to us using it for the purposes described.

Nevertheless, the processing and sharing of this personal data will likely be done for (but not limited to) the following purposes:

  • to review and improve your experience with us

  • to respond to enquiries you place with us, either via the website, phone or via e-mail

  • to allow you to participate in our services

  • for our internal operations 

  • to assist you with any future interactions with us

  • to inform you about products, services and events which we feel may be of interest to you

  • to notify you about changes to our practices, services or to online content

  • to administer our website

Information About You

We will generally only collect data about you directly from you and this will be done when you communicate with us and explicitly provide this information to us, and is likely to include your name, address, e-mail address, telephone numbers and if you are a shareholder, information about your current or past shareholding and (if you elect to receive dividends by bank transfer) your bank account and sort code details. We collect information about you solely for the purposes of communicating, and the operational provision of services that you have specifically requested for us to do so. 

Sometimes information about you may come from other organisations such as our brokers, PR consultants or our registrar if you have made an enquiry to them which they have to pass to us. We may also receive information about you from people instructed by you such as solicitors, brokers and nominees who hold shares (directly or indirectly) on your behalf. These businesses will mainly be data controllers themselves and we encourage you to read their privacy notices for information about how they deal with information about you. A number of organisations will deal with data about you on our behalf and we will therefore deal with any matters that arise about the way they handle your data; these include our registrars (whose details can be found on our Investor Page under Rule 4.14) and the companies that host our website and our other computer systems.

If we have asked for your consent to use your data, you may withdraw that consent at any time by contacting us.

How We Use Your Information

If you are a shareholder, we use your information to keep track of your shareholding, to pay dividends (through our registrars) and to deal with enquiries you make of us. In any other circumstances we will only use your data in connection with any business that we or our subsidiaries might have with you.

Sharing Your Information

We will only share data about you where we have a legitimate interest to do so. 

ASMO may share your personal information and data with the following parties:

  • other ASMO staff in locations around the world

  • third-party suppliers who help us maintain our Website and support our business e.g. hosting provider, Website developers, marketing agencies, IT support team, brokers etc

  • law enforcement, regulatory bodies and fraud prevention agencies, to comply with our legal obligations

  • other ASMO company partners or subsidiaries

  • any prospective buyer of our business or assets

 

Other than in a purely business context we are only likely to share details of our shareholders with companies that process your data on our behalf or our business advisers such as brokers and PR consultants or with other parties instructed by you (such as your brokers, advisers or nominees). We may have to disclose, or allow inspection of, our share register where such a request is made in the form laid down by statute and we have to comply unless we can prove that the information is not being requested for a “proper purpose” (this is a broad term that is not defined in the relevant legislation).

There may be occasions when we must share information (including with regulators) about you so that we comply with a legal obligation, to enforce or apply our website terms of use, other agreements or to protect the rights, property, or safety of ourselves or someone else. We will also exchange information with other companies and organisations for the purposes of fraud protection, crime prevention or detection and credit (and other) risk reduction.

Where We Store Your Personal Information

All information you provide to us is stored securely. Where we have given you, or where you have chosen a password which enables you to access certain parts of our systems (including any hosted for us such as by our registrars), you are responsible for keeping this password confidential. We ask you not to share a password with anyone. In line with GDPR legislation ASMO will store personal data in a form that permits identification of the individual for no longer than is necessary for the purposes for which it was processed.

International Data Transfers

We do not generally process personal information outside of the European Economic Area but should this occur from time to time (for example our use of Google Analytics involves some personal data being transferred to the USA) it will be done only in a way that complies with current laws and regulations.

Access to Information

You may obtain the information we hold about you by making a written request to us – see our contact details.

Subject to compliance with any laws and regulations, when you ask us about the information we hold on you, we will give you confirmation that your data is being processed, access to it and any other supplementary information we consider relevant to your request

Your Other Rights

In addition to having access to your information (see above) and your right to the information set out in our privacy statements you have the rights to ask us to rectify any incorrect information about you, to delete information we hold about you, to restrict what we do with information about you, and to require us to send information we hold about you either to you (or someone you designate) in a commonly used machine-readable form. Additionally, you may object to how we are using information about you and have the right not to have automated decisions made about you.

 

The above rights are not all absolute and whether you can use one of these rights may depend on the way we obtained your information or the legal basis on which we use your personal information. More information about how and when you can exercise these rights is available from the Information Commissioner’s Office.

You may obtain the information we hold about you by making a written request to us - see our contact details.

Subject to compliance with any laws and regulations, when you ask us about the information we hold on you, we will give you confirmation that your data is being processed, access to it and any other supplementary information we consider relevant to your request.

Complaints

We are committed to protecting and respecting information about you in compliance with relevant laws and regulations and for this reason we take complaints we receive about this very seriously. Please address any concerns to us at the contact address given above. We encourage you to contact us directly if you are unhappy, but if you are not satisfied with our response or if you prefer not to raise the issue with us you may at any time complain to the Information Commissioner’s Office; for more information on this see the ICO’s report a concern links, the ICO’s contact links or one of its regional offices.