Privacy Policy

1. Overview

We respect and protect the personal information and privacy of others. SunCable:

  • collects personal data from a range of individuals in the context of our business activities including our people, job applicants, supplier representatives, contractors, customers, partners, website users and visitors to our offices and sites; and
  • manages and uses personal data in accordance with applicable privacy laws.

This Policy:

  • relates to “personal data” which is any information (including an opinion) about an identified or identifiable person; and
  • explains how we collect, manage, disclose and use personal data and how rights can be exercised.

The privacy laws that apply will depend on the relationship with SunCable and the context in which SunCable processes your personal data.  For example Australian privacy laws will always apply to the Australian businesses and Singapore privacy laws (e.g. Personal Data Protection Act) will always apply to the Singaporean businesses.  Other laws may apply to personal data processed in the context of our businesses in other countries where we operate, for example Indonesia.

2. Coverage

2.1 This Policy applies to SunCable Holdings Pty Ltd (“SunCable”) and all its subsidiaries.

2.2 All SunCable personnel including its officers, employees, contractors, labour-hire, temporary or agency staff are required to comply with this Policy as well as business partners, consultants and suppliers authorised to manage personal data on SunCable’s behalf.

3. Personal Data

3.1 This Policy applies to personal data in SunCable’s possession or under SunCable’s control, including personal data in the possession of organisations which we have engaged to collect, use, disclose or process personal data for our purposes.

3.2 Depending on the nature of your interaction with SunCable, some examples of personal data which may be collected include name and identification information (e.g. in Singapore the NRIC number), contact information such as address, email address or telephone number, nationality, gender, date of birth, marital status, photographs and other audio-visual information, employment information and financial information such as credit card numbers, debit card numbers or bank account information.

4. Collection, Use and Disclosure of Personal Data

4.1 We generally collect personal data;

(a) where it is provided to us voluntarily by you directly or via a third party who has been duly authorised by you to disclose your personal data to us (your “authorised representative”) after;

(i) you (or your authorised representative) have been notified of the purposes for which the data is collected; and

(ii) you (or your authorised representative) have provided written consent to the collection and usage of your personal data for those purposes; or

(b) where collection and use of personal data without consent is permitted or required under applicable laws.  

We will seek your consent before collecting any additional personal data and before using your personal data for a purpose which has not been notified to you, except where permitted or authorised by law.

4.2 We may collect and use your personal data for any or all of the following purposes:

(a) performing obligations in the course of or in connection with our provision of the goods and/or services requested by you or the provision by you of goods and/or services to us;

(b) verifying your identity;

(c) responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;

(d) managing your relationship with us including by utilising platform service providers;

(e) processing payment or credit transactions;

(f) sending you information about our activities including notifying you of our marketing events, initiatives and promotions using the contact data submitted by you;

(g) complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;

(h) any other purposes for which you have provided the information;

(i) transmitting to any unaffiliated third parties including our third-party service providers and agents, and relevant governmental and/or regulatory authorities, for the aforementioned purposes; and

(j) any other incidental business purposes related to or in connection with the above.

4.3 Information that you provide voluntarily

At times SunCable may ask you to voluntarily supply personal data.  We may collect personal data in the course of our business interactions with you, including via a webform and from any communications you send to us.

4.4 Information that we collect automatically

When you visit our website we may collect certain information automatically from your device.  Specifically we may collect information like your device type, unique device identification numbers, browser-type, broad geographical location and other technical information from you.

We use this information for internal analytical and operations purposes and to improve the quality and relevance of our website.  Some of this information may be collected by cookies and similar technology.

4.5 We may disclose your personal data:

(a) where such disclosure is required for performing obligations in the course of, or in connection with, our provision of the goods or services requested by you or the provision by you of goods or services to us;

(b) to third-party service providers, agents and other organisations we have engaged to perform any of the functions listed in clause 4.2 above for us; or

(c) government and law enforcement authorities;

(d) financial institutions;  

(e) IT and other service providers;

(f) auditors, legal and other professional advisers;

(g) HR practitioners, hiring managers and recruitment advisors (including relevant to personal data provided via job posts and for the purpose of considering your career opportunities with SunCable; or

(h) to any other person with your consent to disclosure.

4.6 The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under any contract with you).

5. Withdrawing Your Consent

5.1 The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is withdrawn by you in writing. You may withdraw consent and request us to stop using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email to our Data Protection Officer at the contact details provided below.

5.2 Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within 10 business days of receiving it.

5.3 Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue our business relationship with you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing.

5.4 Withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.

6. Access to Correction of Personal Data

6.1 If you wish to make

(a) an access request for access to a copy of the personal data which we hold about you or information about the ways in which we use or disclose your personal data; or

(b) a correction request to correct or update any of your personal data which we hold about you,

you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below.

6.2 A reasonable fee may be charged for an access request.  If a fee is being charged, we will inform you of the fee before processing your request.

6.3 We will respond to your request as soon as reasonably possible. Should we not be able to respond to your request within 30 days after receiving your request, we will inform you in writing within 30 days, of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the legislation).

7.  Protection of Personal Data

7.1 To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as up-to-date antivirus protection, encryption and the use of privacy filters to secure all storage and transmission of personal data by us, and disclosing personal data both internally and to our authorised third party service providers and agents only on a need-to-know basis.

7.2 Be aware, however, that no method of transmission over the internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.

8. Accuracy of Personal Data

SunCable generally relies on personal data provided by you (or your authorised representative). In order to ensure that your personal data is current, complete and accurate, please update SunCable if there are changes to your personal data by informing our Data Protection Officer in writing or via email at the contact details provided below.

9. Retention of Personal Data

9.1 We may hold your personal data in electronic or in hard copy form.  We may keep this information at our own premises or at sites managed by our service providers.

9.2 We may retain your personal data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.  Our aim is to keep your personal data for no longer than is necessary for compliance or other legitimate business purposes.

9.3 We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected, and is no longer necessary for legal or business purposes.

10. Data Protection Officer

10.1 If you have a question, concern or complaint regarding the way we have handled your personal data or if you believe SunCable has failed to comply with this Policy or breached applicable laws in relation to the management of that information, you can make a complaint.

10.2 Any question, concern or complaint is to be made in writing to our Data Protection Officer to

11. Effect of Policy and Changes to Policy

11.1 This Policy applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.

11.2 We may revise the Policy from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this Policy was last updated. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.


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