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    Privacy Policy

    General
    Fonality Pty Ltd takes your privacy seriously. This Privacy Policy describes how Fonality Pty Ltd ABN 32 112 795 276 (Fonality, we or us) will treat the personal information that we collect about you. This Privacy Policy uses the definition of "personal information" which is provided in the Privacy Act 1988 (Cth) (Act). Through your use of our website www.fonality.com.au (Website), social media websites and pages and other communications with us, we may collect personal information about you. We like to keep your personal information safe and want to explain to you how we collect, use, disclose or transfer it and how you can access and correct your personal information and what to do if you have a complaint. This Privacy Policy explains how we do all this and it complies with the requirements of applicable laws in Australia.

    Collection of personal information

    What kinds of personal information do we collect and hold?
    The kinds of personal information that we collect includes names, driver licence details, contact details and other information that is relevant to our functions and activities, including the products and services we provide.

    How do we collect personal information?
    We usually collect personal information directly from you. From time to time, we may collect personal information from third parties if you are a sole trader or partnership. We may collect your personal information when you communicate with us, such as when you:

    a)     make inquiries about our products and services or contact us for any other reason so that we can process, deal with and respond to your queries or other issues including any complaints;

    b)     subscribe to any of our products or services;

    c)     use our Website or any other websites operated by Fonality;

    d)     contact us for technical support; or

    e)     fill out a form or survey via our website.

    We will notify you by email or through the contact details provided if personal information is being collected.

    The Fonality service
    Fonality provides a service which includes the capability for customers to upload and store their system configuration information and call statistics data on Fonality servers and equipment. Customers can disable uploading of call statistics data, which will cause all call data to be stored locally on the customer’s server. Disabling uploading of call statistics also disables graphical reporting capabilities.

    In addition, Fonality software gives customers, at their discretion, the ability to record and save voicemails, phones calls and chats. All communications content is stored locally on the customer’s server(s), and unless provided for under separate terms and conditions, Fonality does not store any voicemail, call recordings, chats or other communications.

    Maintenance of optional secure connection to Fonality
    In order to monitor the performance of your system, Fonality may provide you with technical support, product enhancements, and updates, and Fonality by default maintains a secure electronic connection to your server(s). Fonality implements certain security techniques to ensure the safety of customer data and system access and to minimise the risk of network intrusion.

    Customers can, at their discretion, elect to sever this connection. Severing the connection will disable administration of your server(s) and other important features, including graphical reporting, technical support or software updates, until the connection is re-established.

    What happens if you do not provide your personal information to us?
    If you do not provide the personal information that we request in connection with our activities, we may not be able to provide our products or services to you (e.g. technical support).

    Sensitive information
    We generally do not collect sensitive information; however, we will always obtain your consent if we need to collect sensitive information.

    Use and disclosure of information

    Why do we collect, use, hold and disclose your personal information?
    We collect, use, hold and disclose your personal information as necessary for purposes directly related to our functions and activities, including:

    a)     providing our products and services to you and all related information and services;

    b)     to record information regarding products purchased from us and to provide further services to you;

    c)     direct marketing including promotions, newsletters and competitions;

    d)     to contract with individuals;

    e)     for the purposes of monitoring or improving the use and satisfaction of the website or of the Fonality application; and

    f)      for credit reporting and monitoring purposes.

    Fonality does not review, edit, disseminate or use individual customer information, data or communications in any way, except to investigate a technical support request initiated by a customer, to investigate a suspected terms of use violation or as may be required by law or permitted under this Privacy Policy. We may use aggregated, non-identifiable usage statistics to assess system performance and scale. We do not monitor customer communications without your consent or otherwise in accordance with applicable laws. 

    Where is personal information stored?
    Your personal information is stored on our premises and in cloud based systems located in the United States.

    How do we treat children's personal information?
    We do not want to obtain personal information from children who are using our Website unsupervised. Fonality does not sell products or services for purchase by children. Fonality does not knowingly solicit or collect customer identifiable information from children or persons under the age of eighteen.  If you are under 18 years of age, you must obtain the consent of your parent or guardian before providing us with any personal information. If you believe that a minor has disclosed personal information to Fonality, please contact our Privacy Officer.

    Marketing
    From time to time, Fonality may communicate with you regarding new products, product updates and important Fonality news and information. You have the option to exclude yourself from our marketing communications. Normally, there is an "UNSUBSCRIBE" link in our marketing communications. In any event, if you would like to cease receiving such communications from Fonality, please send a request http://cp.fonality.com/support/ with the subject line “UNSUBSCRIBE”.

    Do we use cookies or other web tracking systems?
    Cookies
    We track traffic patterns throughout our Website and other websites such as www.trixbox.com or www.trixbox.org, and any other website operated by Fonality.

    We use "cookies" on our Website. A "cookie" is a small amount of information which is transferred to the hard drive of your computer and which can identify your web browser but not you. A cookie can collect and store information, but cannot interfere with your computer. Most cookies that we use are "session cookies" that delete themselves at the end of your session.

    If you want, you can disable your web browser from accepting cookies. If you do so, you can still access our websites, but it is possible that some areas of our sites will not function as effectively, and you may be unable to log into our web based administration tools, preventing the administration of your system.

    Web Analytics

    We may use a third party to provide statistical analysis regarding our web users and may set cookies in order to gather the information needed to perform statistical analysis. The information collected by the third party cookies does not contain any personal information and cannot be linked back to any individual user.

    Fonality may collect information from visitors to the Website, trixbox.com and trixbox.org websites, or any other websites operated by Fonality. We may collect the internet addresses of Fonality website visitors. We use the information that we log from such websites to both improve our services and help troubleshoot possible website problems. We may also analyse non-identifying statistics that we collect from website visitor usage and provide this data to third parties.

    Additionally, Fonality web properties may contain content from third-party content providers, but these content providers neither receive nor distribute Fonality user or customer information, nor do they receive user or customer information from Fonality.

    We use and collect IP addresses to analyse trends, administer our websites, and to track users’ movement across our websites, and may provide this data to qualified third parties to help us improve the websites and our service.

    Will we disclose personal information to anyone else?
    We may disclose personal information to third parties, for purposes such as:

    a)     to service providers, agents and contractors of Fonality to sub-contract certain services, such as billing;

    b)     to credit reporting, debt collecting and monitoring agencies such as AMPAC, Ezi Debit and CreditorWatch; or

    c)     with the consent of the individual.

    We may also provide your information to others, if required or permitted to do so by law.

    GOVERNMENT RELATED IDENTIFIERS
    While we may need to collect certain government related identifiers, such as Driver Licence numbers in order to provide our products and services, we do not use any government related identifiers as our own identifiers.

    OVERSEAS DISCLOSURE OF PERSONAL INFORMATION
    We may disclose your personal information to an entity located outside Australia in accordance with the terms of this Privacy Policy.  You consent to us disclosing your personal information to our related bodies corporate located in the United States and Philippines in accordance with this Privacy Policy. We will not disclose personal information to overseas recipients other than in accordance with applicable laws and this Privacy Policy.

    SECURITY
    We have implemented certain procedures and equipment to safeguard the security of your information. Your information is encrypted and authenticated, using Secure Socket Layer (SSL) technology. The SSL systems provide data security for you and your users, and the authentication ensures that your valuable content is available only to registered users, and is not accessible to unwanted parties. Each registered user in your organisation is provided with a unique username and password. Each time a user logs onto your Fonality application, they can only be authenticated and allowed access using the correct username and password that has been assigned. A session is issued for the purpose of capturing encrypted authentication data for the length of the session. Neither the username nor the password is included in the session. Security protocols put into operation by Fonality are determined by encrypted session IDs and dynamic data. We ensure that only authorised staff have access to areas where information is stored electronically. Once personal information is no longer required by us for the purposes for which it was collected or held or otherwise in accordance with applicable laws, we will take all reasonable steps to ensure that it is either destroyed or de-identified.

    Fonality complies with the U.S.-EU Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries.  Fonality has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement.  To learn more about the Safe Harbor program, and to view Fonality’s certification, please visit http://www.export.gov/safeharbor/.

    DEALING WITH US ANONYMOUSLY OR USING A PSEUDONYM
    You may deal with us on an anonymous basis or using a pseudonym when making general inquiries through our Website or social media pages. However, we may need certain contact details from you to respond to inquiries.

    Access, Correction and Removal of your Personal Information
    We take such steps as are reasonable in the circumstances to ensure that personal information that we collect is accurate, up to date and complete. We also take reasonable steps to ensure that personal information that we use or disclose is accurate, up to date, complete and relevant, having regard to the purpose of the use or disclosure. You may seek to access or correct your personal information at any time by contacting the Privacy Officer by email at accounts@fonality.com.au or by mail to the "Privacy Officer, Suite 2, Level 9, 56 Berry Street, North Sydney, NSW 2060". If we do not agree to provide you with access to your personal information or to amend or annotate the information we hold about you, you may seek a review of our decision. If we do not agree to make the requested changes to your personal information, you may make a statement about the requested changes and we will attach it to your record.

    Complaints
    You can send written complaints about a breach of this Privacy Policy in relation to your personal information by email to escalations@fonality.com or by mail to the "Privacy Officer, Suite 2, Level 9, 56 Berry Street, North Sydney, NSW 2060". Complaints will be reviewed by our Privacy Officer and a response will usually be provided within 30 days of receipt of the complaint by us.

    Amendments
    We may amend this Privacy Policy at any time. Amendments to this Privacy Policy will be posted on our Website and will be effective when posted. Please check our Privacy Policy regularly for updates and amendments.

    Linking to other websites
    Our Website may contain links to other sites. This Privacy Policy does not apply to your use of another website accessed through a link from our Website. In such cases, the privacy policy of the linked website will apply.

    This Privacy Policy was last updated 7 July 2015.