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About this Privacy Policy

Delacon Pty Ltd understands and appreciates that privacy is a major concern for all our Customers as it is for Delacon.   As part of providing our services, Delacon is committed to:

  • ensuring we comply with the Data Protection Law applying to us; and
  • dealing effectively with your enquiries and complaints concerning our compliance with privacy laws, regulations and codes.

This Privacy Policy describes how we collect, use and handle Personal Data both about our Customers and on behalf of our Customers when providing our services, where those activities come with the GDPR.

Please read this policy carefully to understand how we will treat your Personal Data.  If you have any questions, please contact us using the details provided below.

What information we collect and why

Our Services

Delacon provides call analytics services to Customers, which include small, medium and large businesses. Our services (collectively, “Call Analytic Services”) include:

  • helping Customers track and evaluate the performance of their advertising, by measuring and analysing telephone calls generated by online, mobile and offline ad campaigns;
  • helping Customers drive sales leads and/or other desired outcomes through targeted ad campaigns, and providing related analytics services; and
  • providing Customers with call recording and other data services for their inbound calls.

As part of providing these Call Analytic Services, we collect Personal Data.

Customer Information

The Personal Data we collect about our Customers is called ‘Customer Information.’

We collect Customer Information in the following circumstances:

Opening a customer account: If you wish to become a customer, or if you are acting on behalf of a customer or prospective customer of Delacon, we require your name, residential and email addresses, and telephone number.

We may also ask for:

  • copies of documents confirming your identity, such as your: driver’s licence, passport, birth certificate and/or utility bills; and
  • other information, such as your credit card or bank account details (which may include a photocopy or scanned image of the front and back of your credit card). That information may be used to set up a direct debit, for example.

Enquiries, blogs and on-line interaction: If you send us an enquiry through our Site, we may collect your name, phone number and email address. We may also collect your responses to our correspondence and to any promotions running on the Site.

Our Site may include publicly accessible blogs or community forums. Please note that any information you provide in these public areas may be read, collected, and used by other internet users.

Credit information: Sometimes we provide credit to Customers. To do that, we may collect and hold credit information and credit eligibility information about those Customers. We may combine credit reporting information from a credit reporting body with our own information about your credit worthiness, and we may use that combined information to determine whether to offer credit to you.

Call recordings: Calls to Delacon offices and service centres may be recorded for verification and quality assurance purposes.

Third-party analytics services. We may use automated devices and third-party applications, such as Google Analytics and Marketo, to evaluate the usage of our Site and the effectiveness of our email marketing. We and our third-party providers may also use other analytic technologies (e.g. clear GIFs) to evaluate and improve our Site, its performance and our users’ experience. To perform their services, the third party service providers may use cookies and other tracking technologies. Those third parties may also combine the information that we provide about you with other information that they have collected.

Tracking technologies: Delacon and our partners and suppliers of analytics and other services may use tracking technologies such as web beacons, e-tags, and Javascripts to analyze trends, administer our Site, track users’ movements around our Site, and obtain demographic information about our user base. Reports generated from the use of these technologies may be provided to us, containing data grouped on an individual and/ or an aggregated basis.

We also collect information about suppliers of goods or services to Delacon, including name, position, business and email addresses; and telephone numbers.  This information will be treated as ‘Customer Information.’

Individual Information

The information we receive from our Customers about their current or prospective customers or that we collect on behalf of our Customers, generated by our Call Analytics Services, is called ‘Individual Information.’

We process Individual Information in the following circumstances:

Cookies: We collect information from cookies used to provide our service which may include:

  • your IP address,
  • information on your browser software,
  • page(s) visited (including the time and date of visit), and
  • keyword searches conducted.

Online usage and analytics data: We collect online usage and analytics data from Customer and third-party websites (sometimes using cookies and pixels). We may link that information with other online information we collect from third parties (including cross-device information), as well as information we collect offline.   This information includes:

  • IP address,
  • date and time stamp,
  • device ID,
  • cookie ID,
  • URL and referring URL,
  • browser type,
  • advertising identifiers,
  • header information, and
  • other information about the ad or web page or mobile application the user was viewing.

We also collect data on calls placed to our Customers, such as caller ID information, and may link that information to:

  • the online activity we have collected,
  • information collected from third parties (which may include cross-device information), and
  • information we have collected offline.

We may also record calls placed to our Customers, at the Customer’s election.

We do not collect sensitive information as part of providing Call Analytic Services.

What we use Personal Data for

We collect and use the Personal Data described above in order to provide you with the Services in a reliable and secure manner and in particular:

  • to identify you;
  • to provide our Call Analytic Services, and manage, administer, and control the quality of, those services;
  • to market our products and services to you, and to enable selected third-party partners to market products and services to you;
  • to do research and analysis related to our services, and to develop and improve our services;
  • to assist with your enquiries or complaints;
  • to protect our rights and property and to comply with our legal obligations; and
  • any other purpose required or permitted by law.

Marketing and opting out

With your consent, we may use and disclose your Personal Data for marketing purposes, including to:

  • identify your behaviours, habits and preferences; and
  • enable different members of the Delacon Group and selected third party partners to send you product and service information directly.

You will be able object to or withdraw your consent from future marketing communications from us at any time by:

  • Using the ‘unsubscribe’ link in any email communication; or
  • Contacting us by email at privacy@delaconcorp.com.

You may withdraw your consent to receiving third party marketing material at any time. Please follow the instructions in the advertising material or on that party’s website, or email: privacy@delaconcorp.com.

Lawful basis for processing

Our lawful basis for processing the Personal Data we collect includes:

  • if you are an existing or prospective Customer to fulfil any contractual agreements between you and us and as part of our “legitimate interest”, and
  • in promoting our services to you, we rely on your consent before contacting you by electronic means for this purpose or require that our Customers obtain such consent.

Cookies and Adwords

Cookies

Delacon and our service providers may use cookies (persistent or single session) and other tracking technologies (described below) to provide Call Analytics Services and to obtain about to the use of our Site.

We do not use cookies to retrieve information that was not originally sent by us to you in a cookie.

You may choose to refuse cookies but, if you do so, some of the functionality of our site and of our Customers’ sites may no longer be available to you.

For more information about cookies, including further details as to what they are and how to refuse them please see our Cookies Policy.

For more general information about cookies, please visit: http://www.aboutcookies.org/

Google Ad settings

To help manage their advertising and websites, our Customers may use our Call Analytics Services together with Google products such as AdWords, Google Analytics, and DoubleClick-branded services. For information about using Google Ads Settings to manage the Google ads you see, and opting out of Google Ads Personalization, please visit: https://www.google.com/policies/technologies/ads/

Third party sites

Our Site may contain links to third-party sites and social media features (for example, Facebook and Twitter buttons and widgets). Social media features are either hosted by a third party or hosted directly on our Site. We have no control over those third-party sites, and we are not responsible or liable for their content or the privacy practices applying to them.

For information about those companies’ privacy practices and how they may use your Personal Data, please visit the company websites.

For information about how to opt out of having your information collected in mobile applications, please visit: https://www.ghostery.com/support/global-opt-out/.

Individual Rights

Individual Information

In supplying our Call Analytic Services we are providing information collection services to our Customers, and do not have a direct relationship with the individuals whose information we process.

If you are an individual (not a Customer) and wish to access or seek correction or deletion of Individual Information processed by us as part of our Call Analytics Services, or otherwise exercise your rights in regard to your Personal Data, you should direct your query to the Customer concerned (who controls the data). In particular, if you are an individual who no longer wishes to be contacted by one of our Customers, please contact that business directly.

We will assist Customers in ensuring the fulfilment of Customers’ obligations to respond to requests for exercising individual rights as laid down in the GDPR, including the right to access, correct and delete Individual Information and the right to object to or restrict processing including automated profilin which leads to decision making.

Customer Information

Quality of information

We will take reasonable steps to ensure the Personal Data we hold about you is accurate, up-to-date and complete.

Please let us know if there is a change to any of the Customer Information you have given to us.

Access to Customer Information

Customers can access the Customer Information Delacon holds about them.

Your Personal Data will usually be available within 30 days of your request (subject to allowable exemptions). We will let you know if additional time (which will not exceed two additional months) is required. We may require evidence of your identity when processing your request for access to your Personal Data.

Rectifying Customer Information

You have a right to ask us to correct any inaccurate Customer Information we hold about you. We will take reasonable steps to correct your Personal Data to ensure it is accurate, up-to-date, complete, relevant and not misleading.

Erasing Customer Information

You have a right to ask us to erase any Customer Information we hold about you.  We will do that without undue delay where one of the grounds specified in Article 17 GDPR applies.

If we made your Customer Information public and are obliged to erase that data, we will, taking into account available technology and the cost of implementation, take reasonable steps, including technical measures, to inform any controllers which are processing the Personal Data that you have requested the erasure.

Right to withdraw consent

If we have collected and process any Personal Data on the basis of your consent, then you can withdraw your consent at any time.  Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Customer Information conducted in reliance on lawful processing grounds other than consent.

Right to object and data portability

You can object to processing of your Customer information, ask us to restrict processing of your Customer Information or request portability of your Customer Information.

Right to object to automated profiling

You can object to decisions being taken based solely on automated means, including profiling, which produce legal effects concerning you or similarly significantly affect you

Exercising Rights

You can exercise any of these rights by contacting us using the contact details provided below.

Data Sharing and International Transfers

We may share your Personal Data with the following recipients:

  • Our contracted service providers which provide services such as IT and system administration and hosting, credit card processing, research and analytics, marketing, customer support and data enrichment;
  • With third–party social networks, advertising networks and websites, which usually act as separate controllers, so that we can market and advertise on third party platforms and websites;
  • Our third party partners who may contact you regarding their products or services;
  • In individual cases, withy professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services;

Any Personal Data or other information you choose to submit in communities, forums, blogs, or chat rooms on our websites may be read, collected, and/or used by others who visit these forums, depending on your account settings.

We may disclose your Personal Data:

  • to regulators and law enforcement agencies and other relevant government authorities and agencies, where legally required; and
  • as otherwise required by law (e.g. in connection with subpoenas, search warrants, court orders or other legal processes).

Sharing within the Delacon Group

Companies in the Delacon Group may share or grant access to Personal Data with other companies in the group (i.e. subsidiary or affiliate companies). This is on a need-to-know basis, and where necessary to fulfil a request you have submitted via our websites, or for customer support, marketing, technical operations and account management purposes.

Change in ownership

If the ownership of the Delacon Group or any part of it is transferred (e.g. as the result of a corporate merger, or bankruptcy), or there is a sale of assets, then some or all the Personal Data and non-Personal Data we hold may be transferred to the new owner.

We will notify Customers (for example, via a message to the email associated with your account) of any such transfer or sale and outline your choices in the event,

Data Transfers

Delacon may transfer and process Personal Data to and in other locations around the world where Delacon or its Sub-processors maintain data processing operations as necessary to provide the Services.

Data Transfers from the EEA and Switzerland

Where Personal Data is transferred from the European Economic Area and/or Switzerland to a member of Delacon’s group of companies or Sub-Processor located in a country not recognized by the European Commission or the Swiss Federal Data Protection Authority as providing an adequate level of protection for Personal Data, Delacon will enter into the EU Model Clauses on Customer’s behalf with such Delacon entity based outside of the EEA and Switzerland and involved in the processing of Personal Data.

Delacon will provide a copy of those EU Model Clauses to Customer upon Customer’s written request.

If Delacon adopts Binding Corporate Rules or another alternative data export solution (as recognized under EU Data Protection Law), then the EU Model Clauses will cease to apply with effect from the date that Delacon implements such new data export solution.

Making Complaints

Contact Delacon

If you have a question or concern about how we have handled your Personal Data, please let us know so we can address it, by contacting us using any of the details below.

We will aim to respond to all requests, complaints and other contracts within a reasonable time, usually 30 days. Delacon takes all privacy complaints seriously and our Privacy Officer aims to efficiently resolve any issue arising from a complaint.

Data Protection Officer

Delacon has also appointed an external Data Protection Officer (DPO) to help ensure that we meet our obligations under the GDPR.

If you have any queries, questions, concerns or wish to make a complaint regarding how we deal with your Personal Data please contact either us or our DPO, using the following details:

Delacon: The Privacy Officer

Delacon

Suite 703, Level 7,

35-43 Grafton Street,

Bondi Junction, NSW 2022, Australia

Telephone: +61 2 8019 0200

email: privacy@delaconcorp.com

Delacon Data Protection Officer:  We have appointed Thomas McNamara as our Data Protection Officer to oversee our data protection efforts. Thomas brings a wealth of knowledge and experience in international law, regulatory compliance and data protection.

Email: privacy@delaconcorp.com

 

EU Representative

Because we are based in Australia and do not have an office in the EU, we have appointed Spider Guard  as our Data Protection Representative in the EU.

Spider Guard will primarily deal with any communications with EU data protection authorities.

You may also wish to contact Spider Guard if you have any queries, questions, concerns or wish to make a complaint regarding how we deal with your Personal Data and would prefer to deal with a local organisation.

To raise a question or otherwise exercise your rights in respect of your Personal Data through Spider Guard, you may do so by using any of the following details:

 

EU Representative Kimura Limited t/ Spider Guard, 1st Floor, Iveagh Court WeWork, Block D, Charlemont St. D02 VH94, Dublin, Ireland

Email: privacy@delaconcorp.com

 

Complaint to the Data Protection Authority

The GDPR also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred.

If you are in the EU,  please follow this link to locate the data protection authority most relevant to you: http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm.

Data retention and deletion

Delacon will not retain any Personal Data longer than necessary to fulfil the purposes for which it is processed, including the security of our processing, complying with legal terms and regulatory obligations (e.g. audit, accounting and statutory retention terms), handling disputes and for the establishment, exercise or defence of legal claims.

Where Delacon:

  • no longer needs to use or disclose your Personal Data for any authorised purpose; and
  • is not legally required to retain that information,

then we will take reasonable steps to destroy the Personal Data or have it de-identified.

Deletion of Customer Information

To request removal of any Customer Information held by Delacon, including from a Delacon blog or community forum, contact us at privacy@delaconcorp.com.

We may not be able to remove Personal Data in every case – if we cannot comply with your request we will let you know and explain why.

Security

Security measures by Delacon

Delacon will implement and maintain appropriate technical and organizational security measures to protect against Personal Data Breaches and to preserve the security and confidentiality of Personal Data processed by Delacon on behalf of Customer in the provision of the Call Analytic Services. Delacon may update or modify the Security Measures from time to time provided that such updates and modifications do not result in the degradation of the overall security of the Services purchased by the Customer.

Security Measures by Customer

Customer is responsible for using and configuring the Services in a manner which enables Customer to comply with Data Protection Laws, including implementing appropriate technical and organizational measures.

Notification of Personal Data Breach

In accordance with its obligations under the GDPR, Delacon will inform the competent Supervisory Authority and the Data Subject in the event of a Personal Data Breach affecting Customer Information.

Upon becoming aware of a Data Breach affecting Individual Information, Delacon will notify Customer without undue delay and will provide all information relating to the Data Breach as reasonably requested by Customer.

Delacon will use reasonable endeavours to assist Customer in mitigating the adverse effects of any Personal Data Breach.

Other provisions

Scope

This Privacy Policy applies to Delacon Pty Limited (ABN 42 074 596 553) and its subsidiary and affiliate companies (collectively “Delacon”, “we”, “us”, “our” and “Delacon Group”).

It applies to the activities of Delacon to the extent they fall within the operation of the GDPR.

Definitions

In this policy:

Controller means an entity that determines the purposes and means of the processing of Personal Data.

Customer includes all users of any of our services, any prospective customers, suppliers and other third parties who we may deal with, individuals who may contact us by phone or email and other visitors to our Site.

Customer Suppliers means an entity the Customer has engaged, selected or nominated as an integration partner.

Data Protection Law means the GDPR.

Data Subject as the meaning given to it in the GDPR.

GDPR means Regulation 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data (General Data Protection Regulation).

Personal Data means any information relating to an identified or identifiable natural person as defined in the GDPR.

Personal Data Breach means an event affecting Delacon leading to the accidental or unlawful loss or unauthorized disclosure of or access to Personal Data.

Processing has the meaning given to it in the GDPR.

Processor means an entity that processes Personal Data on behalf of a Controller.

Representative has the meaning given to it in the GDPR.

Sensitive Data has the meaning given to it in the GDPR.

Site means our website www.delaconcorp.com and our other websites.

Sub-processor has the meaning given to it in the GDPR to the extent that the relevant Processor is engaged by Delacon to processes Personal Data for Call Analytics Services but does not include Processors when acting in their capacity as Customer Suppliers.

Access to Policy

Our Privacy Policy is available on our websites, or you can request a copy in a different format (e.g. a hard copy or email attachment) by emailing privacy@delaconcorp.com or telephoning +61 2 8019 0200.

If you have any queries about Delacon’s privacy practices, please contact our Privacy Officer by emailing privacy@delaconcorp.com or telephoning +61 2 8019 0200.

For information about those companies’ privacy practices and how they may use your Personal Data, please visit the company websites.

Changes to our Privacy Policy

We will review this Privacy Policy from time to time, and we reserve the right to modify or update it at any time.

You acknowledge that we may make changes to this Privacy Policy. Changes to this Privacy Policy will come into effect immediately when uploaded to our Site or Delacon’s iOS or Android apps. If you continue using our products or services after changes to this Privacy Policy are uploaded, you will be taken to have accepted those changes.

Policy last updated: July 2018

http://www.delacon.com.au/privacy-policy/

About this Privacy Policy

This Privacy Policy describes how we collect, use and handle Personal Information both about our Customers and on behalf of our Customers when providing our services.

Delacon understands and appreciates that privacy is a major concern for all our Customers, as it is for Delacon.   As part of providing our services, Delacon is committed to:

·         ensuring we comply with the Data Protection Law applying to us; and

·         dealing effectively with your enquiries and complaints concerning our compliance with privacy laws, regulations and codes.

This Policy does not apply to any activities that come with the operation of the EU General Data Protection Regulation. Customers and other individuals who are in the EU, should refer to our EU Privacy Policy.


Please read this policy carefully to understand how we will treat your Personal Information.  If you have any questions, please contact us using the details provided below.

What information we collect and why

Our Services

Delacon provides call analytics services to Customers, which include small, medium and large businesses. Our services (collectively, “Call Analytic Services”) include:

  • helping Customers track and evaluate the performance of their advertising, by measuring and analysing telephone calls generated by online, mobile and offline ad campaigns;
  • helping Customers drive sales leads and/or other desired outcomes through targeted ad campaigns, and providing related analytics services; and
  • providing Customers with call recording and other data services for their inbound calls.

As part of providing these Call Analytic Services, we collect Personal Information.

Customer Information

The Personal Information we collect about our Customers is called ‘Customer Information.’

We collect Customer Information in the following circumstances:

Opening a customer account: If you wish to become a customer, or if you are acting on behalf of a customer or prospective customer of Delacon, we require your name, residential and email addresses, and telephone number.

We may also ask for:

  • copies of documents confirming your identity, such as your: driver’s licence, passport, birth certificate and/or utility bills; and
  • other information, such as your credit card or bank account details (which may include a photocopy or scanned image of the front and back of your credit card). That information may be used to set up a direct debit, for example.

Enquiries, blogs and on-line interaction: If you send us an enquiry through our Site, we may collect your name, phone number and email address. We may also collect your responses to our correspondence and to any promotions running on the Site.

Our Site may include publicly accessible blogs or community forums. Please note that any information you provide in these public areas may be read, collected, and used by other internet users.

Credit information: Sometimes we provide credit to Customers. To do that, we may collect and hold credit information and credit eligibility information about those Customers. We may combine credit reporting information from a credit reporting body with our own information about your credit worthiness, and we may use that combined information to determine whether to offer credit to you.

Call recordings: Calls to Delacon offices and service centres may be recorded for verification and quality assurance purposes.

Third-party analytics services. We may use automated devices and third-party applications, such as Google Analytics and Marketo, to evaluate the usage of our Site and the effectiveness of our email marketing. We and our third-party providers may also use other analytic technologies (e.g. clear GIFs) to evaluate and improve our Site, its performance and our users’ experience. To perform their services, the third party service providers may use cookies and other tracking technologies. Those third parties may also combine the information that we provide about you with other information that they have collected.

Tracking technologies: Delacon and our partners and suppliers of analytics and other services may use tracking technologies such as web beacons, e-tags, and Javascripts to analyze trends, administer our Site, track users’ movements around our Site, and obtain demographic information about our user base. Reports generated from the use of these technologies may be provided to us, containing data grouped on an individual and/ or an aggregated basis.

We also collect information about suppliers of goods or services to Delacon, including name, position, business and email addresses; and telephone numbers.  This information will be treated as ‘Customer Information.’

Individual Information

The information we receive from our Customers about their current or prospective customers or that we collect on behalf of our Customers, generated by our Call Analytics Services, is called ‘Individual Information.’

We process Individual Information in the following circumstances:

Cookies: We collect information from cookies used to provide our service which may include:

  • your IP address,
  • information on your browser software,
  • page(s) visited (including the time and date of visit), and
  • keyword searches conducted.

Online usage and analytics data: We collect online usage and analytics data from Customer and third-party websites (sometimes using cookies and pixels). We may link that information with other online information we collect from third parties (including cross-device information), as well as information we collect offline.   This information includes:

  • IP address,
  • date and time stamp,
  • device ID,
  • cookie ID,
  • URL and referring URL,
  • browser type,
  • advertising identifiers,
  • header information, and
  • other information about the ad or web page or mobile application the user was viewing.

We also collect data on calls placed to our Customers, such as caller ID information, and may link that information to:

  • the online activity we have collected,
  • information collected from third parties (which may include cross-device information), and
  • information we have collected offline.

We may also record calls placed to our Customers, at the Customer’s election.

We do not collect sensitive information as part of providing Call Analytic Services.

What we use Personal Information for

We collect and use the Personal Information described above in order to provide you with the Services in a reliable and secure manner and in particular:

  • to identify you;
  • to provide our Call Analytic Services, and manage, administer, and control the quality of, those services;
  • to market our products and services to you, and to enable selected third-party partners to market products and services to you;
  • to do research and analysis related to our services, and to develop and improve our services;
  • to assist with your enquiries or complaints;
  • to protect our rights and property and to comply with our legal obligations; and
  • any other purpose required or permitted by law.

Marketing and opting out

We may use and disclose your Personal Information for marketing purposes, including to:

  • identify your behaviours, habits and preferences; and
  • enable different members of the Delacon Group and selected third party partners to send you product and service information directly.

You can object to or withdraw your consent from future marketing communications from us at any time by:

  • Using the ‘unsubscribe’ link in any email communication; or
  • Contacting us by email at privacy@delaconcorp.com.

You may withdraw your consent to receiving third party marketing material at any time. Please follow the instructions in the advertising material or on that party’s website, or email: privacy@delaconcorp.com.

Cookies and Adwords

Cookies

Delacon and our service providers may use cookies (persistent or single session) and other tracking technologies (described below) to provide Call Analytics Services and to obtain about to the use of our Site.

We do not use cookies to retrieve information that was not originally sent by us to you in a cookie.

You may choose to refuse cookies but, if you do so, some of the functionality of our site and of our Customers’ sites may no longer be available to you.

For more information about cookies, including further details as to what they are and how to refuse them please see our Cookies Policy.

For more general information about cookies, please visit: http://www.aboutcookies.org/

Google Ad settings

To help manage their advertising and websites, our Customers may use our Call Analytics Services together with Google products such as AdWords, Google Analytics, and DoubleClick-branded services. For information about using Google Ads Settings to manage the Google ads you see, and opting out of Google Ads Personalization, please visit: https://www.google.com/policies/technologies/ads/

Third party sites

Our Site may contain links to third-party sites and social media features (for example, Facebook and Twitter buttons and widgets). Social media features are either hosted by a third party or hosted directly on our Site. We have no control over those third-party sites, and we are not responsible or liable for their content or the privacy practices applying to them.

For information about those companies’ privacy practices and how they may use your Personal Information, please visit the company websites.

For information about how to opt out of having your information collected in mobile applications, please visit: https://www.ghostery.com/support/global-opt-out/.

Access and correction

Individual Information

In supplying our Call Analytic Services, we are providing information collection services to our Customers, and do not have a direct relationship with the individuals whose information we process.

If you are an individual (not a Customer) and wish to access or seek correction or deletion of Individual Information processed by us, or otherwise exercise your rights in regard to your Personal Information, you should direct your query to the Customer concerned (who controls the data). In particular, if you are an individual who no longer wishes to be contacted by one of our Customers, please contact that business directly.

We will assist Customers in ensuring the fulfilment of Customers’ obligations to respond to requests for exercising individual rights, including the right to access or correct Individual Information.

Customer Information

Quality of information

We will take reasonable steps to ensure the Personal Information we hold about you is accurate, up-to-date and complete.

Please let us know if there is a change to any of the Customer Information you have given to us.

Access to Customer Information

Customers can access the Customer Information Delacon holds about them.

Your Personal Information will usually be available within 30 days of your request (subject to allowable exemptions). We will let you know if additional time is required.

Rectifying Customer Information

You have a right to ask us to correct any inaccurate Customer Information we hold about you. We will take reasonable steps to correct your Personal Information to ensure it is accurate, up-to-date, complete, relevant and not misleading.

Exercising Rights

You can exercise any of these rights by contacting us using the contact details provided below. We may require evidence of your identity when processing your request for access to or to rectify your Personal Information.

Data Sharing and International Transfers

We may share your Personal Information with the following recipients:

  • Our contracted service providers which provide services such as IT and system administration and hosting, credit card processing, research and analytics, marketing, customer support and data enrichment;
  • With third–party social networks, advertising networks and websites, which usually act as separate controllers, so that we can market and advertise on third party platforms and websites;
  • Our third party partners who may contact you regarding their products or services;
  • In individual cases, withy professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services;

Any Personal Information or other information you choose to submit in communities, forums, blogs, or chat rooms on our websites may be read, collected, and/or used by others who visit these forums, depending on your account settings.

We may also disclose your Personal Information:

  • to regulators and law enforcement agencies and other relevant government authorities and agencies, where legally required; and
  • as otherwise required by law (e.g. in connection with subpoenas, search warrants, court orders or other legal processes).

Sharing within the Delacon Group

Companies in the Delacon Group may share or grant access to Personal Information with other companies in the group (i.e. subsidiary or affiliate companies). This is on a need-to-know basis, and where necessary to fulfil a request you have submitted via our websites, or for customer support, marketing, technical operations and account management purposes.

Change in ownership

If the ownership of the Delacon Group or any part of it is transferred (e.g. as the result of a corporate merger, or bankruptcy), or there is a sale of assets, then some or all the Personal Information and non-Personal Information we hold may be transferred to the new owner.

We will notify Customers (for example, via a message to the email associated with your account) of any such transfer or sale and outline your choices in the event,

Cross Border Disclosures

Delacon may disclose Personal Information to a member of the Delacon Group or Sub-processors in other locations around the world, as necessary to provide the Services. The countries to which we may transfer Personal Information include the United States, the United Kingdom, New Zealand, Singapore, Japan, India, Hong Kong and Malaysia.

Making Complaints

If you have a question or concern about how we have handled your Personal Information, please let us know so we can address it, by contacting us using any of the details below.

Delacon: The Privacy Officer

Delacon

Suite 703, Level 7,

35-43 Grafton Street,

Bondi Junction, NSW 2022, Australia

Telephone: +61 2 8019 0200

email: privacy@delaconcorp.com

We will aim to respond to all requests, complaints and other contracts within a reasonable time, usually 30 days. Delacon takes all privacy complaints seriously and our Privacy Officer aims to efficiently resolve any issue arising from a complaint.

Security

Security measures by Delacon

Delacon will implement and maintain appropriate technical and organizational security measures to protect against Personal Information Breaches and to preserve the security and confidentiality of Personal Information processed by Delacon. Delacon may update or modify the Security Measures from time to time provided that such updates and modifications do not result in the degradation of the overall security of the Services purchased by the Customer.

Notification of Data Breach

In accordance with its obligations under Data Protection Laws, Delacon will inform the competent regulatory authority and the Data Subject(s) in the event of a Personal Information Data Breach affecting Customer Information.

Upon becoming aware of a Personal Information Data Breach affecting Individual Information, Delacon will notify Customer without undue delay and will provide all information relating to the Data Breach as reasonably requested by Customer.

Delacon will use reasonable endeavours to assist Customer in mitigating the adverse effects of any Personal Information Data Breach.

Other provisions

Scope

This Privacy Policy applies to Delacon Pty Limited (ABN 42 074 596 553) and its subsidiary and affiliate companies (collectively “Delacon”, “we”, “us”, “our” and “Delacon Group”).

It applies to the activities of Delacon to the extent they fall outside the operation of the GDPR.

Definitions

In this policy:

Customer includes all users of any of our services, any prospective customers, suppliers and other third parties who we may deal with, individuals who may contact us by phone or email and other visitors to our Site.

Customer Suppliers means an entity the Customer has engaged, selected or nominated as an integration partner.

Data Protection Law means the Privacy Act 1988 (Cth).

GDPR means Regulation 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data (General Data Protection Regulation).

Personal Information has the same meaning as defined in the Data Protection Law.

Personal Information Data Breach has the same meaning as ‘eligible data breach’ in the Data Protection Law.

Sensitive Data has the meaning given to it in the Data Protection Law.

Site means our website www.delaconcorp.com and our other websites.

Sub-processor means any third party entity engaged by Delacon to processes Personal Information for Call Analytics Services but does not include Processors when acting in their capacity as Customer Suppliers.

Access to Policy

Our Privacy Policy is available on our websites, or you can request a copy in a different format (e.g. a hard copy or email attachment) by emailing privacy@delaconcorp.com or telephoning +61 2 8019 0200.

If you have any queries about Delacon’s privacy practices, please contact our Privacy Officer by emailing privacy@delaconcorp.com or telephoning +61 2 8019 0200.

Changes to our Privacy Policy

We will review this Privacy Policy from time to time, and we reserve the right to modify or update it at any time.

You acknowledge that we may make changes to this Privacy Policy. Changes to this Privacy Policy will come into effect immediately when uploaded to our Site or Delacon’s iOS or Android apps. If you continue using our products or services after changes to this Privacy Policy are uploaded, you will be taken to have accepted those changes.

Policy last updated: July 2018

About this Cookie Policy

We use common tracking tools to collect information, including personal information, about visitors to our site and as part of providing Services. These tools include browser cookies, use web beacons, flash cookies, and similar technologies. Our vendors may also use these tools.

This policy describes in more detail:

  • The types of cookies, 3rd Party Cookie and similar technologies we use; and
  • How you can manage, block or delete those tracking technologies.

For more information on how we handle Personal Data generally, please refer to our Privacy Policy.

We Use Common Tracking Technologies

We use different tracking technologies to collect personal information about users when you use this site or our Service. We also have third parties that collect personal information this way.

The Tracking Technologies we use include the following:

Cookies

We use cookies. Cookies are small files that download when you access certain websites.

We use JavaScript to collect certain information from you, including:

  • your IP address;
    • information on your browser software
    • page(s) you visited (including the time and date of visit);
    • keyword searches you conduct.

Our tracking JavaScript collects this information and uses cookie to link this information:

Third parties also use cookies on our sites.

We do not use cookies to retrieve information that was not originally sent by us to you in a cookie.

For more general information about cookies, please visit: http://www.aboutcookies.org/

The cookies we employ are confined to those on our website and tracking cookies as part of the services we provide to our Customers.

For our website, both session and permanent cookie are used to store users’ preferences and previous selections.

For tracking, only session cookies are used to link the captured Customer website information and the telephone number assigned to that information and which telephone number is used by end users of our Customers services and websites to contact our Customers in response to an advertising campaign.  The Delacon cookies reside in the cookies of our Customers and we consider them to be first party cookies as the cookie is between our Customer’s website and the end user’s browser, not between Delacon and the end user’s browser.

Tracking Tools

Delacon and our partners and suppliers of analytics and other services may use tracking technologies such as web beacons, e-tags, and Javascripts. Reports generated from the use of these technologies may be provided to us, containing data grouped on an individual and/ or an aggregated basis.

The Specific Tracking Technologies We Use

Here is more information about the cookies and tracking technologies we use and how you can manage them.

Types of cookie Who serves these cookies How to refuse
Essential website cookies: These cookies are strictly necessary to provide you with services available through our Website and to use some of its features, such as access to secure areas. Delacon Because these cookies are strictly necessary to deliver the Websites to you, you cannot refuse them.

However, you can block or delete them by turning JavaScript off in your browser. See instructions below on how to do this:

Turning off JavaScript in your browser please see below link:

https://www.computerhope.com/issues/ch000891.htm

Analytics and customization cookies: These cookies collect information that is used either in aggregate form to help us understand how our Websites are being used or to help us customize our Websites for you. Google Analytics (analytics.google.com)

Marketo (www.marketo.com)

To refuse these cookies follow the instructions below under the heading “How can I control tracking technologies?”

Alternatively, please click on the relevant opt-out link below:

https://tools.google.com/dlpage/gaoptout

For Marketo, see instructions below under the heading “How can I control tracking technologies?”

Advertising cookies: These cookies are used to make advertising messages more relevant to you. They perform functions like preventing the same ad from continuously reappearing, ensuring that ads are properly displayed for advertisers, and in some cases selecting advertisements that are based on your interests. Google Ads (www.google.com), To refuse these cookies follow the instructions below under the heading “How can I control tracking technologies?”

Alternatively, please click on the relevant opt-out link below:

https://www.google.com/settings/u/0/ads/authenticated

We Use Tracking Technologies for a Variety of Reasons

We use tracking technologies:

  • To recognize new visitors to our web sites.
  • To improve our website and better understand your visits on our platforms.
  • To integrate with third party social media websites.
  • To serve you with interest-based or targeted advertising (see below for more on interest-based advertising).
  • To observe your behaviour and browsing activities over time across multiple websites or other platforms.
  • To better understand the interests of our customers and our website visitors.

We also use tracking technologies to provide our Call Analytics Services.  These cookies reside in the cookies of our Customers and our Customers must obtain the consent of end users to the use of these cookies and afford them the opportunity to revoke consent.  This can only be achieved by contacting our Customers.

We Engage in Interest-Based Advertising

We and our partners display interest-based advertising using information gathered about you over time across multiple websites or other platforms. This might include apps.

Interest-based advertising or “online behavioural advertising” includes ads served to you after you leave our website, encouraging you to return. They also include ads we think are relevant based on your browsing habits or online activities. These ads might be served on websites or on apps. They might also be served in emails. We might serve these ads, or third parties may serve ads. They might be about our products or other companies’ products.

Where required, we get consent to engage in interest-based advertising.

How Do We Gather Relevant Information About You for Interest-Based Advertising?

To decide what is relevant to you, we use information you make available to us when you interact with us, our affiliates, and other third parties. We gather this information using the tracking tools described above. For example, we or our partners might look at your purchases or browsing behaviours. We might look at these activities on our platforms or the platforms of others. We work with third parties who help gather this information.

How can I control tracking technologies?

Cookies

You have the right to decide whether to accept or reject cookies. You can exercise your cookie preferences by clicking on the appropriate opt-out links provided in the cookie table above.

You can also set or amend your web browser controls to accept or refuse cookies. Usually a web browser will automatically accept cookies, but you can set your web browser to reject new cookies, or notify you when a cookie is sent, or disable cookies altogether (use the “Help” function on your browser to get more information). If you block or disable our cookies, you may still use our Site, but you may not have access to certain areas and some features may not function.

As the means by which you can refuse cookies through your web browser controls vary from browser-to-browser, you should visit your browser’s help menu for more information.

To find out more about how to enable, disable, or delete cookies from your web browser, please visit here and here.

To reject Delacon tracking cookies you must reject the cookies of our Customers who use our services.

Flash Cookies: To control flash cookies, which we may use on certain websites from time to time, you can go here. Why? Because flash cookies cannot be controlled through your browser settings.

Do not Track

Some browsers have a “Do Not Track” feature that allows you to tell a web site not to track you. These features are not all uniform. We do not currently respond to those signals. If you block cookies, certain functionality on our sites may not work.

If you block or reject cookies, not all of the tracking described here will stop. Certain options you select are browser and device specific.

Online Behavioural Advertising

The Self-Regulatory Program for Online Behavioural Advertising provides consumers with the ability to opt-out of having their online behaviour recorded and used for advertising purposes. To opt out of having your online behaviour collected for advertising purposes, visit www.aboutads.info/choices.

Some of the tracking technologies we may use do not participate in the Self-Regulatory Program for Online Behavioral Advertising. This means you will not be opted out by following the instructions above. Instead, click on the following link to get more information about how to opt-out of that tracker’s cookies: Twitter.  Certain choices you make are both browser and device-specific.

Network Advertising

It’s possible to opt out of many website third-party ad networks, including those run by members of the Network Advertising Initiative (“NAI”) and Digital Advertising Alliance (“DAA”). For more information visit: www.networkadvertising.org/optout_nonppii.asp (NAI) and www.aboutads.info/choices (DAA). If you are in the European Union, you can opt out of many ad networks via http://www.youronlinechoices.eu.

Please note: if you opt out of one or more NAI member or DAA member networks, it just means those network(s) will no longer be used deliver targeted content or ads to you. It does not mean you will stop receiving all customised content or ads on our Site or other websites. Also, if your browsers are set to reject cookies when you visit an opt-out page or you later delete all your cookies, use a different computer or change web browsers, your opt out may stop being effective.

Other provisions

Scope

This Cookie Policy applies to Delacon Pty Limited (ABN 42 074 596 553) and its subsidiary and affiliate companies (collectively “Delacon”, “we”, “us”, “our” and “Delacon Group”).

Definitions

In this policy:

Customer includes all users of any of our services, any prospective customers, suppliers and other third parties who we may deal with, individuals who may contact us by phone or email and other visitors to our Site.

Personal Data means any information relating to an identified or identifiable natural person as defined in the GDPR.

Services and Call Analytic Services have the same meaning as in the Delacon Privacy Policy.

Site means our website www.delaconcorp.com and our other websites.

Access to Policy

Our Cookie Policy is available on our websites, or you can request a copy in a different format (e.g. a hard copy or email attachment) by emailing privacy@delaconcorp.com or telephoning +61 2 8019 0200.

If you have any queries about Delacon’s cookie policy or privacy practices, please contact our Privacy Officer by emailing privacy@delaconcorp.com or telephoning +61 2 8019 0200.

Changes to our Cookie Policy

We will review this Cookie Policy from time to time, and we reserve the right to modify or update it at any time.

You acknowledge that we may make changes to this Cookie Policy. Changes to this Cookie Policy will come into effect immediately when uploaded to our Site or Delacon’s iOS or Android apps. If you continue using our products or services after changes to this Cookie Policy are uploaded, you will be taken to have accepted those changes.

Policy last updated: June 2018

http://www.delacon.com.au/privacy-policy/

Sub-processor Website Country where data is processed
Google www.google.com Google says that your information may be processed on servers located outside of the country where you live and that they comply with certain legal frameworks relating to the transfer of data, such as the EU-US and Swiss-US Privacy Shield Frameworks”.

Delacon has signed a Data Protection Addendum with Google

 Google Says that:

“We maintain servers around the world and your information may be processed on servers located outside of the country where you live. Data protection laws vary among countries, with some providing more protection than others. Regardless of where your information is processed, we apply the same protections described in this policy. We also comply with certain legal frameworks relating to the transfer of data, such as the EU-US and Swiss-US Privacy Shield Frameworks”.

https://policies.google.com/privacy#infodelete

Marketo www.marketo.com Marketo says that your personal data may be stored and processed in any country where they have facilities and that they have put in place a solution to ensure that Personal Data transferred outside of the EEA is subject to adequate protection, namely the European Commission Standard Contractual Clauses.”
Delacon has signed a Data Protection Addendum with Marketo.Marketo Says that:“Your Personal Data may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Sites or disclosing information to us you consent to the transfer of information to countries outside of your country of residence, including the United States, Australia, Germany, Ireland, Israel, Japan, and the UK, which could have different data protection rules than those of your country or the country in which you were located when you initially provided the information. Where required, we put in place a solution to ensure that Personal Data transferred outside of the EEA is subject to adequate protection, namely the European Commission Standard Contractual Clauses.”

https://documents.marketo.com/legal/privacy/

Salesforce www.salesforce.com Japan and The United States
Freshworks www.freshworks.com EU, EUC, US and AU

https://www.freshworks.com/privacy/data-hosting/

Atlassian www.atlassian.com United States and Ireland
Microsoft www.microsoft.com Australia