SPEE3D Global Privacy Policy

1. Introduction

SPEE3D respects the rights and privacy of all individuals and is committed to protecting your personal data. This policy sets out how SPEE3D collects and processes your personal information. It also sets out your rights in relation to the personal information we hold about you. If you have questions about this policy, please contact SPEE3D at contact@spee3d.com.

What does this policy do?
This policy describes how SPEE3D deals with personal information of individuals that interact with SPEE3D – this includes representatives of our suppliers; customers; staff; business partners; users of the SPEE3D website; shareholders; and job applicants.

For the purposes of this policy, “personal information” means any information about an identified or identifiable person. This includes where you can be identified, directly or indirectly, including by reference to an identifier (for example, a name or email address, or an online identifier such as a unique device identification number). We use the words “process” and “processing” to describe the various things we may do with your personal information – including using, disclosing, holding, recording, storing, transferring or otherwise handling that information.

Who we are
References to “SPEE3D”, “we” or “us” in this policy mean Effusiontech Pty Limited, SPEE3D Pty Ltd and Effusiontech IP Pty Ltd of 2/2 Darby Way, Dandenong South VIC 3175 Australia, SPEE3D Inc of 112 S. French Street, Wilmington, DE 19801, SPEE3D GmbH of Youco24 Business Center, Meierottostraße 1, 10719 Berlin, Germany) and all subsidiaries within the SPEE3D group of companies worldwide (together “SPEE3D”, “we”, or “us”).

Your consent to collection
By providing personal information to us, you consent to our collection, use and disclosure of your personal information in accordance with this Privacy Policy.

It is important that you read this SPEE3D privacy policy together with any other notice which we may provide you on specific occasions when we are collecting or processing your personal information, so that you are fully aware of how and why we are using your information, and the legal rights that you have.

2. Types of personal information we collect

We collect and process different types of personal information depending on how you interact with us. In some cases, this may include information that shows who you are and/or is linked to you as a result of your interactions with SPEE3D. In some circumstances, we may also collect sensitive personal information about you.

How we collect personal information
We will primarily collect personal information from you either directly (such as when you subscribe to a news alert or request information from us, including through the Contact form available on our website) or indirectly from your interactions with us (such as by monitoring your use of the SPEE3D website). In some cases, we may also to collect personal information about you from third parties (such as recruitment agencies).  Some examples of when we collect your personal information include:

• registering on the website via various means or otherwise contacting us to obtain information relating to us or our products and/or services;
• communicating with us by phone, e-mail or otherwise, or when you complete a questionnaire or competition entry form;
• subscribing to our newsletter or emails;
• purchasing of goods and services, and other interactions in-store;
• engaging with us on social media;
• registering to attend an event or providing us with your personal information at an event;
• contacting us by any means with queries or complaints;
• when accessing and using our chatbot facility; and
• applying for a role with us or sending us a resume.

We may also collect technical information through the use of cookies when you access and interact with the Website (see the section below on Cookies).

Information from other sources
We may also receive personal information about you from various third parties that we engage with in order to assist us with providing products and/or services to you, including:

• delivery and address information from our carriers who deliver products to you;
• marketing information from marketing companies who send customer communications and direct marketing materials on our behalf; and
• data analytics information from companies that provide us with data analytics services.

Types of personal information we collect
The types of personal information that we collect about you may include:

• Identification data – such as your name, gender, job title, photograph, marital status and date of birth.
• Contact details – such as your home and business address, email address and telephone numbers.
• Recruitment-related information – such as your name, email address, location, telephone number, qualifications, employment history, interests, types of roles you are interested in, your work application form and resume or CV. If you progress through the interview process, we may also collect interview notes, references, results of any psychometric tests and background checks (including criminal records checks), your work visa and other information to verify your identity and right to work.
• e-Business information – this includes information required to provide access to SPEE3D website or software, interact with chatbots on the website, expression of interest or customary inquiry forms, software or portals (such as login information, password, IP addresses), and records of your use of those websites or portals.
• Business information – this may include your first and last name, address, email address, phone number, date of birth, and signature.
• Communications: including your correspondence with us and any feedback that you provide us with.
• Marketing Data: your preferences in receiving marketing and communications.
• Social media related information – such as your name or username on LinkedIn, X (Twitter), Facebook and YouTube.
• Usage information – information we collect when you use our websites, such as server log information (your IP address, browser type, operating system, browser language, time zone, browser plug-in types and versions, access times and any referring addresses), website performance statistics, traffic, what you searched for, and location information.
• Other information – this includes information about access and attendance to SPEE3D premises and physical assets (such as security records about times of entry and exit, and information collected through CCTV), details about your use of our assets, communications with you (including complaints or concerns raised by you or any feedback or survey responses that you provide to us) and other information you voluntarily provide to SPEE3D.

We may also collect, use and share aggregated data such as statistical or demographic data. Aggregated data may be derived from your personal information but is not considered personal information as this data does not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal information so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

Sensitive Personal Information
Some types of personal information are considered to be more private than others (which, depending on jurisdiction, includes information about someone’s racial or ethnic origin, political opinions, religious beliefs or affiliations, health or medical conditions, genetic information, biometric information, sexual orientation, criminal record, trade-union membership and political association membership). This type of information is called “sensitive personal information”.

Sometimes we may collect sensitive personal information about you (such as health or medical information, criminal history checks, or your racial or ethnic origin), but we will only do this as described in section 3 (Why we process your personal information) below.

3. Why we process your personal information

We process personal information to conduct our business – this includes managing our contractual relationships, recruitment, marketing, social media, monitoring access to our websites, managing safety and security risks, and complying with our legal obligations. We also process sensitive personal information where you have provided your consent or it is necessary to comply with legal obligations.

The purposes for which we process your personal information will depend on the type of personal information collected and the context in which it was collected. However, the primary purposes for which we process personal information include:

• managing our relationship with you – this includes providing you with information or services, improving our products and services and communicating with you;
• business-related purposes – this includes negotiating, managing, and fulfilling our contracts with customers, suppliers and third parties; managing business relationships; administering real estate leases and licences; shipping product; conducting clearance procedures; managing accounts and records; supporting corporate social responsibility activities; resource planning and workforce management; activities and operations; internal investigations; and debt administration;
• marketing and public relation purposes – this includes analysing the characteristics of visitors to our website; to prepare analytics and profiling for business intelligence purposes; to personalise your experience on our website; managing our newsletters and communications and, where SPEE3D collects details in the membership database relevant to SPEE3D’s website, for demographic analysis and personalisation of the website;
• recruitment-related purposes – this includes considering you for career opportunities (including internship positions) with SPEE3D and inviting you to participate in recruitment activities and events;
• managing safety and security risks – this includes managing and monitoring access and use of our premises and sites, safety and security at our sites (including through the use of CCTV), and our IT environment (including monitoring electronic communications) and the health of those on our sites;
• website administration and internal operations – this includes troubleshooting, data analysis, testing, research, statistical and survey purposes;
• managing shareholder relationships – this includes for the purposes of undertaking share transactions, dividend payments (where applicable) and communications with shareholders; and
• legal obligations – this includes meeting obligations imposed under law; responding to lawful requests from governments and public authorities; and responding to potential or actual litigation.

We may also collect and process your personal information for any other purposes for which you have provided your consent or if there is another lawful basis for doing so.

If we do not collect your personal information, it may affect our ability to perform these functions.

Sensitive personal information
As flagged above, sometimes we may need to collect and process sensitive personal information about you, but we will only do this:

• where you have explicitly provided your consent; or
• where otherwise permitted by applicable laws and regulations.

Cookies
Our websites may use cookies to help us keep track of your visits and activity on our website(s). Cookies are small pieces of data stored on the web browser of your device. These are used by us for site administration and analysis purposes and to deliver tailored content. If you wish not to take advantage of cookies, you may configure your browser not to accept them (although this may disable or render unusable some of the features our online services). 

Hyperlinks

Our websites and apps may contain links to other websites. We are not responsible for the privacy practices or the content of other websites. The privacy practices applicable to other websites may differ substantially from ours. Please read the privacy policy of any other websites you visit before using such websites.

4. Who we share your personal information with

We may share your personal information within our corporate group as well as with third parties involved in the running of our business and your authorised representatives. This may involve sharing information across national borders.

Disclosures within our corporate group
We may share your personal information (which may sometimes include sensitive personal information) within our corporate group who require the information for the purposes in this policy. This will include sharing your personal information with SPEE3D entities in countries other than where the information was originally collected.

An overview of SPEE3D’s global corporate group and the countries in which SPEE3D entities operate can be found in SPEE3D’s website (see the Contacts section of the main SPEE3D page). Some members of our corporate group also perform shared services for other SPEE3D entities. As a result, your personal information (which may sometimes include sensitive personal information) may be processed by SPEE3D in any of the jurisdictions in which we have entities.

Disclosures outside our corporate group
We (or the third parties that we share your personal information with) may also need to share your personal information (which may sometimes include sensitive personal information) with:

• people you have authorised to interact with us on your behalf (such as recruitment agencies);
• third parties who provide services we use to run our business (such as external service providers that assist SPEE3D to perform HR, information technology and other shared services functions, that provide marketing or social media services, manufacturing services, shipping and freight services, debt recovery functions, IT services, or that provide security for SPEE3D sites or systems);
• external marketing and customer relationship management platforms;
• prospective purchasers of all or part of our business or of any shares in SPEE3D entity;
• our professional advisors (such as our lawyers and accountants);
• third parties to assert any legal or equitable claim or where required to conduct an alternative dispute resolution process;
• government and law enforcement where required to lessen or prevent a serious threat to the life, health or safety of any idnvidiual, or to public health or safety;
• thid parties where such use or disclosure is required to take appropriate action in relation to suspected unlawful activity or serious misconduct; and
• government, regulatory and law enforcement authorities or other persons where obliged, required or permitted to do so by an applicable law.

If we (or the third parties that we share your personal information with) need to disclose personal information to third parties in a different country to where the information was collected, we will take steps to ensure that there is a lawful basis for the disclosure and that the disclosure complies with all applicable laws. This may include entering into a legally binding contract with the recipient under which they are obliged to handle your information in accordance with applicable laws.

5. How we store and protect your personal information

We take steps to ensure that your personal information is kept secure and protected against unauthorised access or use. We only keep your personal information for as long as we need it to carry out the purposes described in this policy.

Information security
We place great importance on the security of all information of our customers, clients, employees (past, current and potential), and contractors. We have security measures in place to attempt to protect against the loss, misuse and alteration of personal information under our control.

Personal information is de-identified or destroyed securely when no longer required by us.

We retain the information you provide or is provided by another party on your behalf or is collected about you including without limitation for the purposes described above. This information is held on secure servers in controlled facilities.

Information stored within our computer systems can only be accessed by those entrusted with authority and computer network password sanctions.

No data transmission over the internet can be guaranteed to be 100% secure. While we strive to protect all personal information, we cannot ensure or warrant the security of any information transmitted to us or from its online portals or services, and users do so at their own risk.  Once we receive your transmission, it makes every effort to ensure its security on its systems.

Ultimately, you are solely responsible for keeping your passwords and/or account information secret.  Please also note that due to the nature of the internet, email correspondence with us may not be entirely secure, so please do not send any sensitive information such as credit card details or passwords via email.

Storing personal information
If the information provided is held by us, we generally store the personal information that we collect in electronic databases. These databases are generally hosted in our dedicated data centres in Australia, USA, and Japan.

We may also use third parties to store and process your personal information, for example but not exclusively external online marketing tools or customer relationship management software.

Information retention
We store your personal information as long as necessary to provide our services to you (i.e., fulfilling contractual obligations with you) or if we have a legitimate interest in doing so (e.g., providing marketing material to you). In all other cases, your personal information will be deleted or anonymised as soon as practicable, or as otherwise required by law.

Job applicants
If you are a job applicant, and your application is unsuccessful, we may retain your personal information for a period of time for the purposes of considering you for other roles within SPEE3D. We are under no obligation to retain your personal information for this purpose and may elect to delete your personal information at any time following an unsuccessful application.

You may request that we delete your personal information from our database at any time. You can do this by managing your profile on our job vacancy website or by emailing us at careers@spee3d.com.

6. Your rights and choices

You have rights relating to your personal information held by SPEE3D. Let us know if you want to correct your personal information or if you have concerns about how we are handling your personal information.

Your rights
You have certain rights in relation to your personal information that we hold about you, though the details of these may vary depending on the country where you are based. We respond to all requests we receive from individuals wishing to exercise their rights in relation to any information we hold in accordance with applicable data protection laws.

If you wish to access, correct or update any personal information that we hold about you, please send a request to ‘Contact’ using the contact form available on our website.

If you are a job applicant, you can update your personal information at any time by sending a request to careers@spee3d.com.

It is important to us that all of the information we hold about you is correct and up-to-date, so let us know promptly if there are any errors or other changes should be made.

Raising concerns about how we deal with personal information
If you are concerned about how we are dealing with your personal information, then you may have the right to complain to an applicable data protection authority. The relevant authority will depend on which country you are located in.

Before raising a complaint with a data protection authority, we recommend that you first raise the issue with us so we can address your concerns as quickly as possible. We will make a record of your complaint and will deal with it as quickly as we can, usually within 30 days. Even if we are not able to address your concern, we will be able to provide further information about how you can contact a relevant data protection authority. For more information, please email contact@spee3d.com.

Opting out of marketing materials
You can unsubscribe from marketing emails using the ‘unsubscribe’ link in any marketing email we send you.

7. Country-specific rules

Additional privacy rules and restrictions relating to our management of your personal information may apply in some countries where we operate.

European Union
The additional provisions in this section apply to all individuals that are based in the EU.

Interpretation
For the purposes of all applicable EU and UK legislation, references in this notice to ‘personal information’ shall be read as references to ‘personal data’ and SPEE3D is the “controller” in relation to your personal information.

Legal bases for processing your personal information 
SPEE3D will only process your personal information where we have a legal basis for doing so. This means we will process your personal information:

• where necessary in connection with the entry into or performance of a contract between you and us;
• to comply with our legal obligations;
• where it is in SPEE3D’s legitimate business interests; or
• where you are given a genuine choice as to whether or not we collect your data and you have given us your consent. Where you have consented, you will always have the option to withdraw this consent at a later stage and you will never suffer any detriment if you choose not to consent.

Your Rights
In addition to the rights set out above, you have the right, in certain circumstances, to request:

• the erasure of any personal information that we hold about you;
• the restriction of processing of any personal information that we hold about you; and
• the transfer of your personal information from SPEE3D to a third party.

You also have the right to object to the processing of your personal information by SPEE3D in certain circumstances.

If you wish to make a request, or raise an objection, of this nature, email contact@spee3d.com.

8. Updates to this policy

We will update this policy from time to time where necessary to reflect changes in applicable laws or in our privacy compliance practices. The latest version of this policy will always be available online through the SPEE3D website.

9. How you can contact us

If you have any questions about this policy or privacy-related queries (either related to this policy or otherwise) please contact us by:

• Emailing us at contact@spee3d.com
• Phoning us on +61 3 8759 1464
• Sending a letter to 2/2 Darby Way, Dandenong South VIC 3175 Australia

Last updated 31 January 2024