Mobile Privacy Policy

We are Spacetalk Mobile (Spacetalk Holdings Pty Ltd). We sell and administer the Spacetalk Mobile Services directly in Australia. This Privacy Policy explains how we collect, use, disclose and protect information that applies to our Services to Spacetalk Mobile users, owners, and visitors to our website www.spacetalk.com/mobile.

As used in this Privacy Policy, Spacetalk Mobile” Service”, “our Service” or” the Service” means the Service provided by Spacetalk Mobile for utilising our SIM Cards and mobile network Service, including all features, functionalities, user interfaces as well as all content and software associated with our Service.

When you use our products and Services, we understand that you trust us with your information - we are committed to keeping that trust. That starts with helping you understand our privacy practices and your choices regarding this information, in accordance with the Privacy Act 1988 (Cth) (The Privacy Act) are applicable.

Overview

Nothing is more important to us than our customers’ safety and privacy. We take all reasonable steps to ensure that data in our possession or control is kept secure and not misused. Making our customers aware of our Privacy Policy is part of our commitment to providing you with the best possible Service, so please take a moment to read the following policy and learn how we handle personal data.

Holders of parental, guardian or other legal responsibility are responsible for considering privacy of the SIM user or person in their care and providing consents as desired for them.

We maintain and regularly review this Privacy Policy and take reasonable steps to comply with the Privacy Act, to the extent applicable and as far as is reasonably practical in the circumstances of managing our business.

To ensure your personal information remains confidential, we communicate this Privacy Policy to all our employees and make this Privacy Policy readily available and accessible to all customers, clients, and Service providers.

This Privacy Policy document outlines how we, at Spacetalk Mobile, collect, use, store and disclose your personal information. This privacy policy applies to our website spacetalk.co/mobile, as well as our apps, and the communications we may have with you through any medium.

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

What Personal Data We Collect, Hold and Use

We will only collect personal data from you if it is reasonably necessary to provide Services to you. We will only collect personal data for the purposes for which we advised you we were collecting it for or a related purpose which would reasonably be expected or otherwise with your permission.

Personal data we may collect, and hold includes:

Personal Information: first name, last name, username, or similar identifier and title
Contact Data: billing address, email address and telephone numbers
Third-Party Contact Data: name (or nickname), phone number
Financial Data: payment card details
Transaction Data: details about payments to and from you and other details of products and Services you have purchased from us
We will generally not be required to collect sensitive information about you. We will only do so if it is considered reasonably necessary for us to collect such information for us to perform our functions or activities and you consent, or collection is required by law or another exception in accordance with The Privacy Act.

How We Collect Your Personal Data

We will generally collect the above personal data from you directly. We collect personal data from you in various ways, such as when you communicate with us, when you fill in an application or form or survey, if you apply for a job with us, if we provide a product or Service to you, or when you participate in any of our activities. We may also retain any messages you send through the Service.

We may use this information to operate, maintain, and provide to you the features and functionality of the Services. We may also use this information to correspond with you, and to address any issues you raise about the Services.

We may also collect data and personal information about individual from third parties and automatically, including through Web Servers and Location Data (as further set out below). When you interact with us through third-party Services like Facebook Messenger or Twitter Direct Message, your communications are also governed by these companies’ privacy policies:

Website Servers

When you access our website and online Services, the Web Server Data listed above is collected. We advise Google Analytics Demographic and Interest reporting may be used to develop specific offers or advertising from time to time.

The legal basis for processing of this data is for performance of the contract of provision of our Services, entered into between you and us.

In addition, we may process personal data, if applicable law, regulation, legal process, or enforceable governmental request, obliges us to do so, where we have legitimate interests that are not overridden by data protection interests.

Please note that we store or transmit actual location data away from the device itself on our servers.

Website Cookies

When you use and access our websites, we may place a number of cookies files in your web browser. We use cookies to help us recognise you, to improve your experience, increase security and measure use of our Services. We may also use cookies to ensure that content from our websites is presented in the most effective manner for you and your computer or mobile device and to enable certain functions of the Service, such as to enable advertisements delivery.

Our Cookies Policy details the types of Cookies we use to run our Service and your options regarding Cookies. Our current Cookies Policy can be viewed and downloaded from our website www.Spacetalk Mobile.com.

If you have any questions about opting out of the collection of cookies and other tracking/recording tools, you can contact us directly at mobileprivacy@spacetalkwatch.com.

The Purposes for Which We Collect, Hold, Use and Disclose Personal Data

We collect personal data which is reasonably necessary for one or more of our functions as noted above and including to:

maintain your account and contact details;
allow you to download and purchase our products and Services;
process transactions and end user related information, including confirmations and invoices;
communicate with you;
provide you with access to protected areas of the site;
verify data for accuracy or completeness;
improve the quality of our Services and develop new ones;
Help our Services deliver more useful, customised content such as location tracking;
Keep you posted on software updates, technical updates, security alerts and support and administrative messages;
send marketing communication to you (only after you have given us a free, specific, and unambiguous consent to do so);
conduct surveys to determine use and satisfaction;
detect, investigate, and prevent potentially unlawful acts or omissions or acts or omissions with the potential to breach our Privacy Policy or any other policy;
comply with our legal obligations;
combine or aggregate your personal data with data we collect from third parties and use it for the purposes set out in this Privacy Policy;
protect a person’s rights, property, or safety;
credit reporting purposes; and any other purpose made known in this Privacy Policy or other policy.

We will not use or disclose this data for a secondary purpose unless you consent to us doing so, or under the circumstances involved we believe you would reasonably expect us to use or disclose the data for a secondary purpose and that that secondary purpose is related to the primary purpose.

In the unlikely event that we hold sensitive data about you, we will only disclose or use that data with your consent or if the use or disclosure is directly related to the primary purpose.

Please note that we will also use or disclose your personal data or sensitive data if we are required to do so by law or a court/tribunal order; or if we reasonably believes that the use or disclosure of the data is reasonably necessary for an enforcement related activity or on behalf of an enforcement body, in which case we will make a written note of the use or disclosure or another exception applies under The Privacy Act.

We Share Your Personal Data Within Spacetalk and Spacetalk Mobile

We share information within our core groups, including Spacetalk Ltd and Spacetalk Mobile for a variety of purposes, including providing you with the latest information about our products and Services and offering you our latest promotions.

In the unlikely event that we hold sensitive data about you, we will only disclose or use that data with your consent or if the use or disclosure is directly related to the primary purpose.

Children’s Privacy

Whilst some of our products are aimed for child safety and supporting guardians and the holders of parental responsibility to monitor and protect their child’s safety, we do not knowingly solicit personal information from children and the Services are not offered to children.

Anonymity and Pseudonymity

Spacetalk Mobile will allow its customers to transact with it anonymously or by using a pseudonym, wherever that is reasonable and practicable. However, this will not be possible if Spacetalk Mobile is required or authorised by law or other instrument to deal with customers who have been appropriately identified; or where it is impracticable for us to deal with individuals who have not identified themselves or who would prefer to use a pseudonym.

Who do We Disclose your Personal Data to?

Because Spacetalk Mobile is part of a global business and group of companies, information may be shared with other related business units around the world. Information will be treated confidentially and only disclosed on a need-to-know basis.

Data will be protected in accordance with this Privacy Policy. We will not rent or sell your information into third parties outside Spacetalk Mobile and its group companies (including any parent, subsidiaries, and affiliates) without your consent, except as noted in this section:

We work with other companies that help us provide our systems and Services to our customers, and we may provide data to these companies for the purpose of providing the Services and products to you and to facilitate our interests as stated above. Those Service providers will only be provided with access to your information as is reasonably necessary for the purpose that we have engaged the Service provider, and we will require that such third parties comply with our Standards and all applicable laws.

We may also disclose your personal data to third parties to whom you expressly ask us to send the personal data to or to third parties you consent to us sharing your persona data with.

Furthermore, we may provide location information or any other usage data in a non-personal, aggregate format for statistical and research purposes to third parties. Such data is not considered as personal data.

We, however, do not disclose your personal information to third-parties other than the ones that need this information to execute the Agreement and will not be provided to third parties or organisations beyond the scope set forth in this Privacy Policy, unless you have given consent.

To avoid ambiguity, we will not share your personal information with third parties for marketing purposes, unless we have your explicit consent through an opt-in.

Dealing with Unsolicited Personal Data

If we happen to receive personal data about you from a source other than you, or it is data provided by you which we did not request, we undertake to determine, within a reasonable period, if we could have requested such personal information in accordance and where applicable to the Privacy Act and handle the unsolicited information accordingly.

International Transfer of Personal Data

We operate on a global scale – as such the international transfer of data is an essential element of our business operations.

We have a rigorous selection process and work only with affiliates and Service providers that offer the same level of security and data protection as we do. We make sure to have a contract signed with each third party that guarantees their confidentiality and dedication to the safekeeping of your personal data in accordance with the applicable laws.

We may also transfer your personal data overseas, for example if we receive a legal or regulatory request from a foreign law enforcement body. We will always take steps to ensure that any international transfer of data is carefully managed to protect your rights and interests and only transfer your personal data utilising encryption and pseudonymisation activities.

You have the right to ask for more information about the safeguards we have put in place as mentioned above. Contact us as set out in the details below if you would like further information.

Adoption, Use or Disclosure of Government Related Identifiers

A government related identifier is a number, letter or symbol, or a combination of any or all of those things, that has been assigned by certain government entities and is used to identify the individual or to verify the identity of the individual.

As a general practice, we do not collect or use government related identifiers. In any event, we will not use or disclose a government related identifier unless it is reasonably necessary for an enforcement related activity by or on behalf of an enforcement body. We may also use or disclose a government related identifier related to you if we are allowed or required by law or regulation to do so.

Quality of Personal Data

We take all steps reasonable in the circumstances to ensure that the personal data we collect from you is accurate, up to date and complete. Where we collect data from you directly, we rely on you to supply accurate data and we may not consider that further steps are required. We will also ensure that all steps reasonable under the circumstances to ensure that the personal data we use or disclose is, when considered in relation to the purpose for which we are using or disclosing the data, accurate, up to date, complete and relevant.

Protection of Personal Data

We will take all reasonable steps to protect your personal data from misuse, interference, loss, unauthorised access, modification, and unlawful disclosure. Personal data that is no longer needed will be deleted or anonymised.

How you can protect your data

We urge customers to take every precaution to protect their personal data and the watch user data by changing passwords often, using a combination of letters and numbers, and make sure a secure browser and internet connection is used.

How we protect your data

We safeguard the security of the data with physical, electronic, and managerial procedures. We use industry best practice encryption all our Services including Devices, Applications, Websites and Communications.

All data is stored and processed in infrastructure restricted centres. The environment utilises state-of-the-art network security electronic surveillance, physical security, and multi-factor access control systems to protect client data. The data centres are staffed 24x7 by trained security teams.

Network Security

We use purpose-built, integrated firewall and virtual private network (VPN) security appliances and systems which ensures the highest level of protection.

Police Background Checks

A condition of engagement of all our employees, consultants, contractors and sub-contractors, communication Service providers and advisors is that they successfully pass Police Background Checks for any prior child safety and/or sexual offences. Any child safety or related offence results in the immediate termination of our relationship with that individual or organisation.

Notifiable Personal Data Breach

In the event that there is a personal data breach, and we are required to comply with the notification of eligible data breaches provisions under privacy laws and/or any other regulations or legislation, we will take all reasonable steps to contain the suspected or known breach where possible and follow the following process set out in this clause.

Privacy – Enquiries, Requests, Complaints, Breaches

Enquiries regarding this Privacy Policy or the personal data we may hold on you, should be made to our customer Service team, whose contact details are below.

If you think your personal data, held by us, may have been compromised in any way or you have any other Privacy related complaints or issues, you should also raise the matter with a representative of our customer Service team as soon as possible.

We will take all reasonable steps to ensure your claims are investigated and a formal response will be provided to you, within a reasonable time, considering the circumstances of your claims. If any corrective action is determined to be required, as a result of that investigation, we will take all reasonable steps to rectify the situation and advise you of such, again within a reasonable time considering the circumstances.

Spacetalk Mobile

Email Address: mobileprivacy@spacetalk.co

Office Address: Level 2, 104 Frome Street, Adelaide SA 5000

Postal Address: Level 2, 104 Frome Street, Adelaide SA 5000

Website: www.spacetalk.co/mobile

If we do not resolve your enquiry, concern or complaint to your satisfaction or you require further information in relation to any privacy matters, please contact the relevant Supervisory Authority, whose contact details are below.

Office of the Australian information Commission (Aust)

Telephone 1300 363 992 Email enquiries@oaic.gov.au

Office Address Level 3, 175 Pitt Street, Sydney NSW 2000

Postal Address GPO Box 5218, Sydney NSW 2001

Website www.oaic.gov.au

Changes to our Privacy Policy

We may make changes to this privacy policy, so please check back periodically. You will be able to see that we made changes by checking the Updated date above. If we decide to use or disclose information that identifies you personally in a way that is materially different from what we stated in our privacy policy at the time we collected that information from you, we will give you a choice about the new use or disclosure by appropriate means, which may include an opportunity to opt-out.