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PRIVACY STATEMENT
Aatrox Communications Pty Ltd
Introduction This statement includes:
> our collection statement, explaining aspects of our collection and
use of personal information
> our privacy policy, further explaining how we manage personal
information
> our credit reporting policy, explaining how we manage we manage
credit information and credit eligibility information.
COLLECTION STATEMENT
Who we are Aatrox Communications Pty Ltd ABN 91 622 636 266 ACN 622 636 266
Our contact details > Phone: (03) 8397 2990
> Email: accounts@aatroxcommunications.com.au
> Web site: https://www.aatroxcommunications.com.au
Collection from third We may collect personal information from someone other than you,
party sources and you may not be aware of the collection, when it is not reasonable
or practicable to collect it from you, and it is available from:
> publicly available sources like phone books
> other companies in our group that you may have dealt with
> third parties like our business partners, your authorised
representative/s and wholesalers
> information brokers
> other telecommunication and information service providers that
interact with us in providing products to you (eg overseas when
you use a roaming mobile service)
> credit reporting bodies, credit providers, fraud checking agencies
> our dealers, contractors and other representatives that you may
deal with
> our websites and how you use them
> various parties listed under Disclosing personal information in our
Privacy Policy.
Collection under law We may be required to collect personal information under the
Telecommunications Act 1997 and laws made under it (eg if we supply
a pre-paid public mobile telecommunications service, we are required
by law to carry out an identity check.)
We may be required to collect information, relating to an individual or
a communication to which an individual is a party, under the ‘data
retention’ provisions of the Telecommunications (interception and
Access) Act 1979 (‘Data Retention Law’).
Why we collect and We collect and hold personal information because:
hold personal > we may need to use it to operate our business
information
> we may need to provide it to other parties in connection with our
business
> we may need it to comply with the law, including the Data
Retention Law.
The uses and disclosures we may make of personal information are
detailed in our Privacy Policy.
Unavailability of If we cannot collect the information we need about you, we may not
personal information be able to supply the products or service you want.
Disclosing personal We may disclose personal information as reasonably required to
information contractors and suppliers who goods and services that we use to
operate our business and provide products and support to you, and to
other parties detailed in our Privacy Policy. We may also disclose it to
authorised agencies under the Data Retention Law.
Some of these parties may be based overseas and countries where you
use roaming services while travelling.
Access and correction Our privacy policy contains information about how the you can access
and seek correction of the personal information about you that we
hold.
Complaints Our privacy policy explains how you can complain about a breach of
the Australian Privacy Principles, and how we will deal with such a
complaint.
Credit related Our Credit Reportng Policy is on our web site and contains informaton
information about:
> how you may access credit eligibility information we hold about
you
> how you may seek correction of credit information or credit
eligibility information we hold about you
> how you may complain about our failure to comply with the credit
reporting rules in the Privacy Act
> how we will deal with a complaint.
Web site and credit If there are any Credit Reporting Bodies (CRB) to which we are likely to
notifiable matters disclose your credit information, our web site also contains
information about credit reporting, including details of each CRB and a
statement of 'notifiable matters' that explains:
> that the CRB may include the information in credit reports;
> that we may disclose certain credit defaults to the CRB;
> how to obtain the credit-related information management policies
of us and the CRB;
> your right to access and seek correction of credit-related
information about you, and make a complaint;
> your right to ask the CRB not to use credit reporting information to
facilitate direct marketing;
> your right to ask the CRB not to use or disclose credit reporting
information about you where there may have been fraud.
You can ask for the statement of notifiable matters in an alternative
form, such as a hard copy.
PRIVACY POLICY
Personal information This refers to information or an opinion about a living person who is
identified or reasonably identifiable, whether or not true and whether
or not recorded in material form. For the purposes of the Data
Retention Law, it also refers to information retained for the purposes
of that law, if it relates to an individual or a communication to which
the individual is a party.
Kinds of personal Broadly, we may collect and hold:
information we collect > personal details like name, date of birth, gender, occupation and
and hold driver licence number
> contact details like physical, postal, work and email addresses and
phone numbers
> financial details like bank account, credit card numbers and your
billing and payment history with us
> service-related details like your user name, encrypted password
and service usage history, support incidents, enquiries and
complaints
> other details relating to special situations like specific health
information if you apply for priority assistance and information
about any authorised representative you appoint
> Data Retention Law details (where that law applies) like subscriber
and account details, service details, detaild about
telecommunications devices, the source and destination of
communications, the date and time of communications and
connection to services, the type of a communication or service
and location details.
In any case, we only collect personal information that is reasonably
necessary to support our functions and activities. If we cannot collect
the information we need about you, we may not be able to supply the
products or service you want.
Collecting personal Unless it is not reasonable or practicable to do so, and in other cases
information allowed by law, we will collect personal information about you directly
from you (eg when you contact us by phone or online, or at our
premises, or fill in an application form).
In other cases, we may collect personal information about you from:
> publicly available sources like phone books
> other companies in our group that you may have dealt with
> third parties like our business partners, your authorised
representative/s and wholesalers
> information brokers
> other telecommunication and information service providers that
interact with us in providing products to you (eg overseas when
you use a roaming mobile service)
> credit reporting bodies, credit providers, fraud checking agencies
> our dealers, contractors and other representatives that you may
deal with
> our websites and how you use them
> various parties listed under Disclosing personal information below.
Holding personal We hold personal information in hard and/or soft copy at our offices
information and in other facilities that we own or license from third parties, like
data centres. We take reasonable steps to keep it secure and to
protect it from unauthorised access, use or alteration. Where required
by the Data Retention Law, it will be encrypted.
Why we collect and We collect and hold personal information because:
hold personal > we may need to use it to operate our business
information
> we may need to provide it to other parties in connection with our
business
> we may need it to comply with the law, including the Data
Retention Law.
Using personal We may use personal information:
information > to identify you
> for credit checks
> to prevent fraud
> to supply products (including goods and/or services) to you
> to give you information about us and our products, and product
offers
> for direct marketing – see Direct marketing for details
> to improve our products, our marketing and our website
> to answer your enquiries
> to give you customer support and service
> to better understand your needs and respond to them
> to manage and plan our products and business
> to charge and bill you for products you use
> to collect payment from you
> to monitor, manage, test and improve our network and facilities
> to comply with various laws that apply to us, including the
Telecommunications Act 1997, the Data Retention Law and our
obligations under any carrier licence that we hold
> for other purposes related to the operation of our business.
Disclosing personal We may disclose personal information as reasonably required:
information > to contractors and suppliers who supply or support us in:
• market research, sales and marketing
• direct marketing – see Direct marketing for details
• identity and fraud checking
• credit-related matters like credit rating, creditworthiness and
credit provision
• credit management
• service provisioning
• installation, maintenance and repairs
• helpdesk and enquiries
• support and complaint management
• communications and mailing
• billing, debt recovery and credit management
• network and product design and maintenance
• corporate strategy
• legal and regulatory advice and compliance
• accounting and financial planning
• risk management
• otherwise providing goods and services that we use to operate
our business and provide products and support to you
> to your authorised representative/s
> if you ask us to do so
> to our agents, dealers and members of our corporate group
> to our business partners and wholesale suppliers
> to other telecommunication and information service providers
that interact with us in providing products to you (eg overseas
when you use a roaming mobile service)
> to the manager of the Integrated Public Number Database, the
Australian Communications and Media Authority, police, law
enforcement and national security agencies and other authorities
when and as required by law
> to authorised agencies under the Data Retention Law
> to organisations that provide credit or finance to us
> to persons who invest in or acquire all or part of our business or
company, or are considering doing so.
Some of these parties may be based overseas and countries where
you use roaming services while travelling.
We may use and disclose personal information to direct market to
Direct marketing you products offered by us, our agents, dealers and members of our
corporate group, and our business partners, where we think the
offers will be of interest to you, using:
> post
> email
> electronic messaging
> social media
> targeted web content
> other direct marketing channels.
Direct marketing may continue until you opt-out by calling the number
in Contacting us even if you are no longer our customer.
Accessing and Please contact us for these purposes using the details in Contacting us
correcting personal below. We shall process and respond to your request in accordance
information with Australian Privacy Principle 12. There is no charge for making a
request but a reasonable administrative charge, on a cost recovery
basis, may be payable before we agree to provide access.
Complaints If you wish to complain about a breach of the Australian Privacy
Principles, please contact us using the details in Contacting us below.
We shall:
> acknowledge your complaint within a reasonable time
> give you an estimated first response time
> allocate your complaint to a suitably senior staff member
> process and respond to your complaint as soon as we reasonably
can.
Contacting us Questions, requests and complaints regarding our Privacy Statement
or our compliance with privacy laws should be directed to us by
telephone on (03) 8397 2990 or email to
accounts@aatroxcommunications.com.au
CREDIT REPORTING POLICY
Credit information This refers to information such as:
> identification information
> basic details of a credit account (eg establishment date)
> details of enquiries we make to Credit Reporting Bodies (CRBs)
about you
> details of some overdue payments and serious credit
infringements and of payments or later arrangements in relation
to either of these
> publicly available information like bankruptcy and court judgments
for debts,
more fully defined in the Privacy Act.
Credit eligibility This refers to credit information (together with other credit-related
information information that CRBs derive from it) we obtain from a CRB together
with credit-related information that we derive from it, and is more
fully defined in the Privacy Act.
Dealing in credit-related If we provide credit, as defined in the Privacy Act, we may collect and
information deal in credit information, credit reporting information and credit
eligibility information (eg if we supply equipment on credit terms or a
post-paid product).
Collecting credit We may collect credit information in the same was as other personal
information information. See Collecting personal information above for details.
Collecting credit We may collect credit information from CRBs and other credit
eligibility information providers.
Holding credit-related We hold and protect credit information and credit eligibility
information information in the same way as other personal information. See
Holding personal information above.
Using credit information We use credit information in the same way as other personal
information. See Using personal information above.
Using credit eligibility We use credit eligibility information in ways permitted by the the
information Privacy Act and the Credit Reporting Privacy Code, such as:
> processing credit applications
> managing credit we provide
> helping you avoid defaults
> collecting credit-related debts you owe us
> dealing with serious credit infringements
> participating in the credit reporting system
> transferring our debts to third parties
> dealing with complaints relating to credit or credit reporting
> for regulatory compliance purposes
> in accordance with laws.
Disclosing credit We may disclose credit information:
information > in the same way as other personal information. See Disclosing
personal information above; and
> to CRBs, which may disclose it to other credit providers.
Disclosing credit We may disclose credit eligibility information for purposes permitted
eligibility information by the the Privacy Act and the Credit Reporting Privacy Code, such as
those detailed in Using credit eligibility information above.
Some of these disclosures may be to parties based overseas.
Please contact us for these purposes using the details in Contacting us.
Accessing and There is no charge for making a request but a reasonable
correcting credit administrative charge, on a cost recovery basis, may be payable before
information or credit we agree to provide access.
eligibility information
If you wish to complain about a breach of Part IIIA of the Privacy Act or
Complaints about credit the Credit Reporting Privacy Code, please contact us using the details
compliance in Contacting us. We shall:
> acknowledge your complaint within seven days, and sooner if
practicable
> try to investigate and resolve the matter within 30 days
> explain any delay if we need more time, and seek your agreement
(but if you do not agree, we might be unable to finalise the matter)
> communicate, if necessary, with any other credit provider or CRB
relevant to the matter.
If you are dissatisfied with the result of a complaint, you may escalate
it to any external dispute resolution scheme (EDR) we are a member
of, the Australian Information Commissioner (www.oaic.gov.au) or the
Telecommunications Industry Ombudsman (www.tio.com.au).