We take our responsibility to protect your privacy very seriously. We apply strict controls to the way we handle your Personal Information.
”We”, “us” and “our” means CloudWave Pty Ltd (ABN 27 162 189 790) (CloudWave) of Level 11, 22 Market Street, Sydney, NSW, 2000
PRIVACY LAW
We are bound by the Privacy Act 1988 (Cth) (Privacy Act)and the Australian Privacy Principles (APPs). This policy explains how and why we collect, use, hold and disclose your personal information.
This Privacy Policy does not apply to Personal Information collected, processed, stored, or hosted by our customers using CloudWave services.
WHAT IS PERSONAL INFORMATION?
Personal information is any information oran opinion about an identified individual or an individual who can bereasonably identified from the information or opinion. Information or an opinionmay be personal information regardless of whether it is true.
PERSONAL INFORMATION WE COLLECT?
We collect Personal Information in the followingways:
We may use cookies on the website. A cookie is asmall text file that the website may place on your device to store information.We may use persistent cookies (which remain on your computer even after youclose your browser) to store information that may speed up your use of ourwebsite for any of your future visits to the website. We may also use sessioncookies (which no longer remain after you end your browsing session) to helpmanage the display and presentation of information on the website. You may refuseto use cookies by selecting the appropriate settings on your browser. However,please note that if you do this, you may not be able to use the fullfunctionality of the website.
WHY DO WE COLLECT, HOLD AND USE YOUR PERSONALINFORMATION?
We collect, hold and use your Personal Information so that we can:
(a) provide you with products and services, and manage our relationship with you;
(b) contact you,for example, to respond to your queries or complaints, or if we need to tellyou something important;
(c) comply with ourlegal obligations and assist government and law enforcement agencies orregulators; or
(d) identify andtell you about other products or services that we think may be of interest toyou.
If you do not provide us with your Personal Information,we may not be able to provide you with our services, communicate with you orrespond to your enquiries.
HOW DO WE STORE AND HOLD PERSONAL INFORMATION?
We store most information about you in computer systems and databases operated by either us or our external service providers.
We implement and maintain processes and securitymeasures to protect personal information which we hold from misuse,interference, or loss, and from unauthorised access, modification, ordisclosure.
These processes and systems include, but notlimited to:
(a) the use ofidentity and access management technologies to control access to systems onwhich information is processed and stored;
(b) requiring allemployees to comply with internal information security policies and keepinformation secure;
(c) requiring allemployees to complete training about information security; and
(d) monitoring andregularly reviewing our practise against our own policies and against industrybest practice.
We will also take reasonable steps to destroy orde-identify personal information once we no longer require it for the purposesfor which it was collected or for any secondary purpose permitted under theAPPs.
WHO DO WE DISCLOSE YOUR PERSONAL INFORMATION TO, ANDWHY?
We may transfer or disclose your Personal Information to our related companies.
We may also disclose your Personal Information to others outside our company where:
(a) we are required or authorised by law to do so;
(b) you may have expressly consented to the disclosure, orthe consent may be reasonably inferred from the circumstances;
(c) we need to share it with our external providers and dataprocessors to operate our business and for our customers to provide productsand services to you;
(d) to external service providers so that they may perform servicesfor us or on our behalf;
(e) you consent to us disclosing your personal information formarketing purposes;
(f) we are otherwise permitted to disclose the information underthe Privacy Act; or
(g) we share it with prospective sellers or buyers of our business orassets and if the ownership or control of all or part of our business changes,we may transfer your personal information to the new owner.
DO WE DISCLOSE PERSONAL INFORMATION TO OVERSEAS RECIPIENTS?
We disclose your Personal Information to our employees located outside Australia. They require access to your personal information to serve you. These employees are in New Zealand, India, and Philippines.
LOCATION OF PERSONAL INFORMATION
CloudWave is in Australia, but our partner providers are locatedin multiple countries. Depending on the scope of your interactions with us yourPersonal Information (and the Personal Information of your customers) maybestored in (and possibly accessed from) other countries, including the UnitedStates. Whenever we transfer Personal Information to another jurisdiction, wewill ensure the information is transferred in accordance with this PrivacyPolicy and is permitted by the Australian Privacy Act.
DO WE USE YOUR PERSONAL INFORMATION FOR MARKETING?
We will use your Personal Information to offer you products andservices we believe may interest you, but we will not do so if you tell us notto. These products and services may be offered by us, our related companies,our other business partners, or our service providers.
Where you receive electronic marketing communications from us, you may opt out of receiving further marketing communications by following the opt-out instructions provided in the communication.
ACCESS TO AND CORRECTION OF YOUR PERSONAL INFORMATION
You may access or request correction of the Personal Informationthat we hold about you by contacting us. Our contact details are set out below.There are some circumstances in which we are not required to give you access toyour Personal Information.
There is no charge for requesting access to yourPersonal Information, but we may require you to meet our reasonable costs inproviding you with access (such as photocopying costs or costs for time spenton collating large amounts of material).
We will respond to your requests to access orcorrect Personal Information in a reasonable time and will take all reasonablesteps to ensure that the Personal Information we hold about you remainsaccurate and up to date.
YOUR RIGHTS UNDER THE EU GDPR
Under the European Union (EU) General Data Protection Regulation (GDPR), as a data subject you have the right to:
(a) access your data;
(b) have your data deleted or corrected where it is inaccurate;
(c) object to your data being processed and to restrict processing;
(d) withdraw consent to having your data processed;
(e) have your data provided in a standard format so that it can be transferred elsewhere; and
(f) not be subject to a decision based solely on automated processing.
Data Subject Rights
We have processes in place to deal with Data Subject Rights (data rights of citizens and residents of the EU based in the EU.)Our actions and responsibilities will depend on whether we are the controller or processer of the personal data at issue. Depending on our role as either a controller or processor, the process for enabling Data Subject Rights may differ, and are always subject to applicable law. Please refer to the Contact Details section of this policy if you would like to make a Data Subject Rights request or have a specific need for assistance with a Data Subject Rights request.
COMPLAINTS
If you have a complaint about the way in which we have handled any privacy issue, including your request for access or correction of your personal information, you should contact us. Our contact details are set out below.
We will consider your complaint and determinewhether it requires further investigation. We will notify you of the outcome ofthis investigation and any subsequent internal investigation.
If you remain unsatisfied with the way in whichwe have handled a privacy issue, you may approach an independent advisor orcontact the Office of the Australian Information Commissioner (OAIC)(www.oaic.gov.au) for guidance on alternative courses of action which may beavailable.
CONTACT DETAILS
If you have any questions, comments, requests, or concerns, pleasecontact us at:
Privacy Officer
Email: privacy@cloudwave.com.au
Ph: +61 1800 941 117
CHANGES TO THIS POLICY
From time to time, we may change our policy on how we handle personal information or the types of personal information which we hold. Any changes to our policy will be published on our website.
You may obtain a copy of our current policy from our website or by contacting us at the contact details above.
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