Last updated 12 February 2022
Thanks for visiting our Privacy Policy (Policy). We are Castlerock Consulting Pty Ltd (ACN 001 784 818), trading as voipl, of PO Box 1516, Neutral Bay Junction NSW 2089, Australia (we, our, us and other similar terms). We are committed to providing quality services to you and this Policy outlines our ongoing obligations in respect of how we manage your Personal Information. It applies to any agreements we may form with you.
When we talk about Personal Information, we mean information or an opinion about an identifiable individual (not a company), whether or not that information or opinion is true or in a material form (Personal Information).
1.1 How we collect Personal Information
We collect Personal Information in the ordinary course of our business, which is the provision of goods and services relating to our cloud business telecommunications platforms known as either voipl or Enfonica (Our Platforms). Personal Information is collected when you:
1.2 What Personal Information is collected?
The types of Personal Information we collect include your name, address, telephone number, email, communication records made via Our Platforms, IP address, device identification, your social media details and any additional information you provide to us. Where you contact us on behalf of your employer, the information you provide often contains information about your employment, position and employers contact details. In those circumstances certain employment information is collected.
2.1 Why we collect Personal Information.
We collect your Personal Information for the primary purpose of providing our goods and services to you. We may also use your Personal Information for secondary purposes closely related to the primary purpose, in circumstances where you would reasonably expect such use or disclosure. Examples of when we may use your Personal Information include:
3.1 What are cookies
Cookies are small text files that are placed on your computer by the websites you visit. They are processed and stored by your web browser. When you visit a website or engage with a business through social media, certain information is collected by cookies. This is generally anonymous information and it does not reveal your identity. In and of themselves, cookies are harmless and serve crucial functions. They are widely used in order to make websites work more efficiently and improve the user experience, as well as to provide information about the use of a website.
3.2 Why we use cookies
By storing and using information about your use of our website, including preferences and habits, we are able to make your visit to our website more productive. For example, some cookies remember your language or preferences so that you do not have to repeatedly make these choices.
3.3 Types of cookies
We use the following types of cookies:
3.4 Removal of cookies
Your web browser can choose whether or not to accept cookies. Most web browser software is initially set up to accept them. If you do not want your browser to use cookies, you can manage and control their use through your browser, including removing cookies by deleting them from your "browser history" (cache) when you leave the site. However, if you choose to reject cookies some parts of our website may not work properly.
4.1 Security mechanisms we employ
Generally, we store your Personal Information using secure servers protected from unauthorized access, modification and disclosure. However, like most businesses, we hold some information on our staff’s computers (such as emails from you) and where necessary as hard copy files (such as printed invoices). Our systems are located in Australia and are managed by us and our service providers. Personal Information that we store or transmit is protected by security and access controls, including username and password authentication, multi-factor authentication, and data encryption (both in transit and at rest) where appropriate. In our dealings with third party service providers, we take care to work with subcontractors and service providers who we believe maintain an acceptable standard of data security compliance.
4.2 How long we keep your Personal Information
We retain your Personal Information for as long as is necessary to provide our goods and services to you, as required for our internal business operations, and to comply with our legal obligations. If we hold Personal Information about you, and we do not need that information for any purpose, we will take reasonable steps to destroy or de-identify that information, in accordance with the Australian Privacy Principles (APP) and the European Union General Data Protection Regulation (GDPR), unless we are prevented from doing so by law. Under Australian law, financial records, such as those relating to financial transactions, must be retained for 7 years after the transactions associated with those records are completed. If you no longer want us to use your Personal Information, you can request that we erase it and, where you have an account with us, close your account. Where possible we will do so in accordance with the APPs and GDPR. However, where you request the erasure of your Personal Information we will retain information from deleted accounts as necessary for our legitimate business interests, to comply with the law, prevent fraud, collect fees, resolve disputes, troubleshoot problems, assist with investigations or requests by government, a court of law, or law enforcement authorities, enforce the terms of service and take other actions permitted by law. Any information we retain will be handled in accordance with this Policy.
5.1 Who we share your Personal Information with?
Your Personal Information may be disclosed to:
5.2 Non-disclosure
We will not disclose your Personal Information other than in accordance with this Policy without your consent.
5.3 Offshore transfers
We may disclose your Personal Information to third party contractors, service providers and suppliers with whom we have a business association who operate in the United States and United Kingdom. While we do not otherwise actively disclose your Personal Information to overseas entities, our engagement of service providers, such as those who operate cloud services, may have international data centers and disaster recovery sites. Consequently, these providers may have access to your information offshore. We rely solely on reputable organizations for such cloud services.
6.1 Anonymity
If you contact us with a general enquiry, we may interact with you anonymously or through the use of pseudonyms. However, you are required to provide true and accurate details when requesting the supply of goods or provision of services. You agree you will provide accurate information if we require it.
7.1 Access and corrections
We endeavour to only hold Personal Information that is accurate, complete and up-to-date. You have the right to make a request to access Personal Information which we hold about you and to request corrections of any errors in that data. To make an access or correction request, contact us using the contact details provided at the end of this Policy. If you have an account with us, you can access some of the Personal Information that we collect about you. By logging into your account, you can update or correct certain information. In order to protect your Personal Information, when you contact us, we may require identification from you before releasing the requested information or making the correction.
8.1 Rights
For the purposes of the GDPR, we are a ‘data controller’ of Personal Information. If you’re a citizen or resident of the European Economic Area:
8.2 Required information
Where we require your Personal Information to comply with legal or contractual obligations, then provision of such data is mandatory and if you do not provide it then we will not be able to manage our contractual relationship with you, or to meet obligations placed on us. In those cases, you must provide us with your Personal Information, otherwise the provision of requested Personal Information is optional.
8.3 Right to complain
If you have unresolved concerns, you have the right to complain to data protection authorities. The relevant data protection authority will be the data protection authority in the country:
WHILE YOUR PRIVACY IS IMPORTANT TO US, NOTHING IN THIS PRIVACY POLICY CONSTITUTES A VOLUNTARY OPT-IN TO ANY PRIVACY LAWS, ANYWHERE IN THE WORLD, WHICH WE ARE NOT STATUTORILY BOUND TO COMPLY WITH.
10.1 Changes
We will need to change this Policy from time to time in order to make sure it stays up to date with the latest legal requirements and any changes to our privacy management practices. When we do change the Policy, we’ll make sure to notify you about such changes, where required. A copy of the latest version of this Policy will always be available at https://voipl.co/privacy.html.
Your privacy is important to us. If you have any complaints, concerns or questions about our handling of your Personal Information, we ask that you first contact our privacy officer whose contact details are listed below. We will investigate your complaint and reply to you in writing if you provide us with contact details and request us to do so.
If, after we have conducted our investigations, you are still not satisfied, then we ask you to consult with the Office of the Australian Information Commissioner: