PRIVACY POLICY

Last updated: May 9, 2026.

Who we are
1. Who this Privacy Policy applies to:
  Specialised Shutdown Support Pty Ltd (ABN 49 627 692 951), Australia (SSS Australia);
  
  SSS Group Canada Ltd, Ontario, Canada (SSS Canada);
  
  and any other SSS Group entity that we establish, acquire or operate in the future (which may include the United States and other jurisdictions) (each an SSS Entity). Where this Policy refers to SSS Group, it includes each SSS Entity unless the context requires otherwise.
2. Interpretation
  Unless otherwise stated, references to “SSS“, “we“, “us” or “our” mean the SSS Entity that collects or controls the relevant personal information, and may also include other SSS Entities involved in processing that information.
3. The SSS Entity that collects or determines the purposes for which personal information is used will generally be the entity responsible for that information, although other SSS Entities may process personal information on its behalf. Each SSS Entity remains responsible for personal information it controls, including where processing is carried out by another SSS Entity or third-party service provider on its behalf.
4. Contact:
  Group Privacy Officer:
  
  Email: privacy@sssgroup.global
  
  Australia: Unit 30, 63 Knutsford Avenue, Rivervale Western Australia 6103
  
  Canada: 20 Wellington Street East, Suite 500, Toronto, Ontario, M5E1C5, Canada
The personal information we collect
1. We may collect the following categories of personal information:
  Contact and identity details:
  - name, employer, job title
  - email address, phone number, address
  Enquiry and business information:
  - details submitted via contact forms
  - tender, proposal or engagement-related information
  Recruitment and workforce information:
  - CVs, resumes, employment history
  - qualifications, certifications, licences
  - references and referee details
  - work rights, visa or eligibility information
  Sensitive information (where relevant and permitted by law):
  - health or medical information (e.g. fitness for work)
  - diversity information, including Indigenous or cultural background
  - any other sensitive information you choose to provide
  Technical and usage data:
  - IP address, browser type, device identifiers
  - pages visited and interaction data
  - referral URLs and session data
  Any other information you voluntarily provide to us.
How we collect personal information
1. We collect personal information when you:
  - submit a contact form or enquiry
  - communicate with us via email, phone or social media
  - apply for employment or submit recruitment information
  - interact with our Website (including via cookies or analytics tools)
Why we collect personal information
1. Purpose of collection
  - to respond to enquiries and provide information about our services
  - to prepare proposals, tenders and manage business relationships
  - to assess suitability for employment or engagement
  - to support mobilisation, workforce planning and compliance requirements
  - to improve Website performance, usability and security
  - to send communications or updates where permitted by law
  - where we send marketing or business development communications, they are directed to business contacts (for example, client and supplier representatives) and you can opt out at any time where required or permitted by law
  - to comply with legal and regulatory obligations
  - to manage risk, safety and operational requirements
  - we may also use de-identified or aggregated information (which does not identify individuals) for analytics, reporting and business improvement purposes.
  In some cases, consent may be implied where permitted by applicable law and where the collection, use or disclosure is reasonably necessary and would be expected in the context of the interaction.
2. Collection not required
  You are not required to provide personal information to us. However, if you do not provide certain information, we may be unable to respond to your enquiry, assess your application, or provide our services. You may opt out of receiving marketing or business development communications at any time by using unsubscribe mechanisms (where available) or contacting us directly.
Sensitive information and Mobilisation Framework
1. Collection of sensitive information
  We may collect sensitive information about you where it is reasonably necessary for our business activities, including:
  - recruitment, assessment and workforce planning;
  - verification of qualifications, licences and work rights;
  - fitness for work, medical and safety requirements;
  - mobilisation, site access and project-related requirements; and
  - compliance with legal, regulatory or contractual obligations.
2. Sensitive information may include health or medical information, fitness-for-work assessments, and other information required for safety or compliance purposes.
3. We only collect sensitive information with your express consent, unless otherwise permitted or required by applicable law.
4. Use of sensitive information
  Sensitive information will only be used:
  - for the primary purpose for which it was collected;
  - for directly related purposes reasonably necessary to support recruitment, mobilisation, workforce deployment or service delivery; or
  - as otherwise permitted or required by law.
5. Disclosure and mobilisation framework
  Due to the nature of our operations (including mining, shutdown and maintenance services), personal information (including, where reasonably necessary, sensitive information) may be disclosed to:
  - SSS Group entities in Australia, Canada and other jurisdictions for recruitment, workforce planning and operational purposes;
  - clients and prospective clients (including mining operators and principal contractors) where reasonably necessary for:
    - site access and onboarding;
    - mobilisation and project deployment;
    - verification of qualifications, licences and work rights;
    - safety, medical and compliance requirements; and
    - performance of services under a contract or proposed engagement.
  - service providers, including recruitment platforms, IT systems, cloud hosting providers and compliance or verification providers;
  - professional advisers, including legal, accounting and insurance providers; and
  - regulators, authorities or other third parties where required or authorised by law.
6. Where we disclose personal information to clients or third parties for mobilisation or operational purposes, we take reasonable steps to ensure that:
  - the disclosure is limited to information reasonably required for the relevant purpose; and
  - recipients are subject to contractual or other obligations to handle personal information appropriately.
7. Controls and safeguards for sensitive information
  We implement additional safeguards in relation to sensitive information, including:
  - restricting access to authorised personnel on a need-to-know basis;
  - using secure systems and access controls for storage and transfer; and
  - taking reasonable steps to ensure information is accurate, up-to-date and relevant to its intended use.
8. Consequences of not providing information
  If you do not provide personal information (including sensitive information) where required:
  - we may be unable to assess your suitability for employment or engagement;
  - we may be unable to proceed with mobilisation or site access requirements; or
  - we may be unable to provide services or facilitate your engagement with a client.
9. Acknowledgement regarding mobilisation disclosures
  By providing your personal information to us, you acknowledge that:
  - your information may be disclosed to clients and other third parties as described in this Policy where reasonably necessary for recruitment, mobilisation and service delivery; and
  - such disclosures are an essential part of our business operations in industries with strict safety, compliance and onboarding requirements.
Cross-border transfers and mobilisation-related disclosures
1. Due to the global nature of our operations (including recruitment, workforce deployment and service delivery across jurisdictions), personal information may be transferred, disclosed to, or accessed from locations outside the country in which it was originally collected.
2. This may include transfers:
  - between SSS Group entities in Australia, Canada and other jurisdictions;
  - to clients or prospective clients located in different jurisdictions for mobilisation, onboarding, site access, safety, compliance and project-related requirements; and
  - to third-party service providers (including cloud hosting, IT systems and recruitment platforms) that store or process personal information outside your country of residence.
3. Where personal information is transferred across borders, we take reasonable steps to ensure that the information is handled in a manner consistent with applicable privacy laws and this Policy, or otherwise rely on permitted exceptions under applicable law (including where you consent to the disclosure). These steps may include:
  - implementing contractual protections with recipients;
  - assessing the privacy and security practices of recipients;
  - limiting disclosures to information reasonably required for the relevant purpose; and
  - applying technical, organisational and access-control safeguards.
4. Where required by applicable law (including under the Privacy Act 1988 (Cth)), we take reasonable steps to ensure that overseas recipients do not breach applicable privacy obligations in relation to personal information.
5. In some circumstances, you may consent to the transfer of your personal information to overseas recipients, including in connection with recruitment, mobilisation and client onboarding processes, and acknowledge that:
  - the recipient may not be subject to the same privacy laws as those in your country of residence; and
  - those laws may provide a different or lower level of protection.
6. Cross-border transfers and disclosures are an essential part of our business operations, particularly in connection with mobilisation and the delivery of services to clients operating across multiple jurisdictions.
Cookies and analytics
1. We use cookies and similar technologies to:
  - operate and maintain the Website
  - improve functionality and user experience
  - analyse traffic and usage patterns
2. We use Google Analytics to collect and analyse website usage information. Google Analytics collects information such as how users access and use the Website, including pages visited, time spent on pages and navigation paths, to the extent permitted by applicable law.
3. This information is generally aggregated and does not directly identify individuals. Google may store this data on servers outside your country of residence. Google’s privacy policy can be located at https://policies.google.com/privacy?hl=en
4. You can manage or disable cookies through your browser settings, noting that some features may not function correctly if cookies are disabled.
Security
1. We maintain reasonable administrative, technical and physical safeguards to protect personal information from:
  - misuse or interference
  - loss
  - unauthorised access, modification or disclosure
2. These safeguards include, where appropriate: access controls, authentication measures, encryption, secure data storage, and internal policies governing access and handling of personal information. However, no method of transmission over the internet or electronic storage is completely secure, and we cannot guarantee absolute security. You are responsible for maintaining the confidentiality of any credentials or account details used to access our systems (where applicable).
Retention
1. We retain personal information only for as long as necessary to:
  - fulfil the purposes outlined in this Policy; and
  - meet legal, regulatory or contractual requirements.
2. Retention periods vary depending on the nature of the information. We retain recruitment information for a reasonable period (typically up to several years) unless a longer period is required or permitted by law. We will also take reasonable steps to destroy or de-identify personal information when it is no longer required.
Your rights
1. Australia
  If you are located in Australia, you may request:
  - access to personal information we hold about you; and
  - correction of personal information to ensure it is accurate, up-to-date, complete and not misleading, in accordance with the Privacy Act 1988 (Cth).
  We will respond to such requests within a reasonable period and may require verification of your identity before processing your request. In some circumstances, we may refuse access or correction where permitted by law, in which case we will provide reasons where required.
2. Canada
  If you are located in Canada, you have the right to:
  - request access to your personal information held by us;
  - request correction of inaccurate or incomplete personal information;
  - withdraw your consent to our collection, use or disclosure of personal information, subject to legal or contractual restrictions and reasonable notice; and
  - request information about our use and disclosure of your personal information.
  Withdrawal of consent may affect our ability to provide services, assess your application, or facilitate your engagement.
  
  We will respond to requests in accordance with applicable Canadian privacy laws and may require verification of identity before processing your request.
3. Other jurisdictions (including the United States) B2B context
  Privacy rights vary depending on your location and the nature of your interaction with us.
  
  Outside Australia and Canada, our Website and services are primarily directed to:
  - business-to-business contacts (such as client and supplier representatives); and
  - recruitment-related interactions (such as applicants and contractors).
4. Where applicable law provides rights to access, correction or deletion of personal information, or the ability to opt out of certain uses, we will comply with those obligations to the extent they apply to us.
Requests and enquiries
To exercise your rights, or to make an enquiry about how we handle personal information, please contact us using the using the contact details set out in this Policy. We may:
- require you to verify your identity before processing your request; and
- charge a reasonable fee where permitted by law (for example, for extensive access requests).
Recruitment information
If you submit employment or contractor information to us:
- it will be used for recruitment, assessment and workforce planning;
- it may be shared within the SSS Group including, but not limited to, Australia and Canada;
- it may be shared with clients or prospective clients as described elsewhere in this Policy, including for mobilisation, compliance and client onboarding purposes; and
- it may be retained for a reasonable period for future opportunities unless you request otherwise.
Complaints escalation
If you have a complaint about how we handle personal information, please contact us first. If you are not satisfied with our response:
- Australia: You may contact the Office of the Australian Information Commissioner (OAIC).
- Canada: You may contact the Office of the Privacy Commissioner of Canada or applicable provincial regulator.
- Other jurisdictions: You may contact the relevant privacy or data protection regulator in your jurisdiction, where one applies.
Updates
We may update this Privacy Policy from time to time. The latest version will be published on our Website.