Privacy Policy

Introduction

We take our responsibility to protect your privacy very seriously. We apply strict controls to the way we handle your Personal Information.

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“We”, “us” and “our” means CloudWave Pty Ltd (ABN 27 162 189 790) (CloudWave) of Level 11, 22 Market Street, Sydney, NSW, 2000.

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Privacy Law

We are bound by the Privacy Act 1988(Cth) (Privacy Act) and the Australian Privacy Principles (APPs).This policy explains how and why we collect, use, hold and disclose yourpersonal information.

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This Privacy Policy does not apply to Personal Information collected, processed, stored, or hosted by ourcustomers using CloudWave services.

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What Is Personal Information?

Personal information is any information oran opinion about an identified individual or an individual who can bereasonably identified from the information or opinion. Information or anopinion may be personal information regardless of whether it is true.

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Personal Information We Collect

We collect Personal Information in the following ways:

• Information you give us: we collect any information you provide us in relation to subscribing to CloudWave services (for example when you purchase any of our products or services,  when you call us, when you download resources from our website, and when you sign up to our online newsletter).
• Automatic Information: we automatically collect certain types of information when you interact with CloudWave services (examples of information we automatically collect include: authentication and security credential information, location of your computer or device, network and connection information, email addresses and phone numbers used to contact us etc).
• Information from other sources: We might collect information about you from other sources, including service     providers, partners, and publicly available sources.

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Cookies and Third‑Party Analytics

We use cookies and similar technologies on our website to support core functionality, analytics, and business development activities. Cookies may collect information such as IP address, device identifiers, browser type, pages visited, and interaction data.

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We also use third‑party services, including business intelligence and data enrichment providers such as ZoomInfo, to helpus understand website usage, identify potential business interest, and improveour marketing and sales outreach. These providers may use cookies or similartechnologies and may collect or receive information about your interactionswith our website in accordance with their own privacy practices.

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You can control or disable cookies through your browser settings. Disabling cookies may limit certain website functionality.

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Why Do We Collect, Hold and Use YourPersonal Information?

We collect, hold and use your Personal Information so that we can:

(a) provide you with products and services, and manage our relationship with you;
(b) contact you, for example, to respond to your queries or complaints, or ifwe need to tell you something important;
(c) comply with our legal obligations and assist government and law enforcementagencies or regulators; or
(d) identify and tell you about other products or services that we think may beof interest to you.

If you do not provide us with your Personal Information, we may not be able to provide you with our services, communicate with you or respond to your enquiries.

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How Do We Store and Hold Personal Information?

We store most information about you incomputer systems and databases operated by either us or our external service providers.

We implement and maintain processes andsecurity measures to protect personal information which we hold from misuse, interference, or loss, and from unauthorised access, modification, ordisclosure.
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These processes and systems include, but are not limited to:

(a) the use of identity and access management technologies to control access to systems on which information isprocessed and stored;
(b) requiring all employees to comply with internal information securitypolicies and keep information secure;
(c) requiring all employees to complete training about information security; and
(d) monitoring and regularly reviewing our practice against our own policies and against industry best practice.
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We will also take reasonable steps to destroy or de-identify personal information once we no longer require it for the purposes for which it was collected or for any secondary purpose permitted under the APPs.

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Who Do We Disclose Your Personal Information To, and Why?

We may transfer or disclose your Personal Information to our related companies.

We may also disclose your PersonalInformation to others outside our company where:

(a) we are required or authorised by law todo so;
(b) you may have expressly consented to the disclosure, or the consent may bereasonably inferred from the circumstances;
(c) we need to share it with our external providers and data processors to operate our business and for our customers to provide products and services to you;
(d) to external service providers so that they may perform services for us oron our behalf;
(e) you consent to us disclosing your personal information for marketingpurposes;
(f) we are otherwise permitted to disclose the information under the PrivacyAct; or
(g) we share it with prospective sellers or buyers of our business or assetsand if the ownership or control of all or part of our business changes, we maytransfer your personal information to the new owner.

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Do We Disclose Personal Information to Overseas Recipients?

We disclose your Personal Information toour employees located outside Australia. They require access to your personal information to serve you. These employees are in New Zealand, India, and Philippines.

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Location of Personal Information

CloudWave is in Australia, but our partnerproviders are located in multiple countries. Depending on the scope of yourinteractions with us your Personal Information (and the Personal Information ofyour customers) may be stored in (and possibly accessed from) other countries,including the United States. Whenever we transfer Personal Information toanother jurisdiction, we will ensure the information is transferred inaccordance with this Privacy Policy and is permitted by the Australian Privacy Act.

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Do We Use Your Personal Information forMarketing?

We will use your Personal Information tooffer you products and services we believe may interest you, but we will not doso if you tell us not to. These products and services may be offered by us, ourrelated companies, our other business partners, or our service providers.

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Where you receive electronic marketing communications from us, you may opt out of receiving further marketing communications by following the opt-out instructions provided in the communication.

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Access to and Correction of Your Personal Information

You may access or request correction of the Personal Information that we hold about you by contacting us. Our contactdetails are set out below. There are some circumstances in which we are not required to give you access to your Personal Information.

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There is no charge for requesting access to your Personal Information, but we may require you to meet our reasonable costs in providing you with access (such as photocopying costs or costs for time spent on collating large amounts of material).

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We will respond to your requests to accessor correct Personal Information in a reasonable time and will take all reasonable steps to ensure that the Personal Information we hold about you remains accurate and up to date.

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Your Rights Under the EU GDPR

Under the European Union (EU) General Data Protection Regulation (GDPR), as a data subject you have the right to:

(a) access your data;
(b) have your data deleted or corrected where it is inaccurate;
(c) object to your data being processed and to restrict processing;
(d) withdraw consent to having your data processed;
(e) have your data provided in a standard format so that it can be transferredelsewhere; and
(f) not be subject to a decision based solely on automated processing.

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Data Subject Rights

We have processes in place to deal with Data Subject Rights (data rights of citizens and residents of the EU based inthe EU). Our actions and responsibilities will depend on whether we are the controller or processor of the personal data at issue. Depending on our role aseither a controller or processor, the process for enabling Data Subject Rights may differ, and are always subject to applicable law.

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Please refer to the Contact Details section of this policy if you would like to make a Data Subject Rights request or have a specific need for assistance with a Data Subject Rights request.

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Complaints

If you have a complaint about the way inwhich we have handled any privacy issue, including your request for access orcorrection of your personal information, you should contact us. Our contactdetails are set out below.

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We will consider your complaint and determine whether it requires further investigation. We will notify you of the outcome of this investigation and any subsequent internal investigation.

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If you remain unsatisfied with the way in which we have handled a privacy issue, you may approach an independent advisoror contact the Office of the Australian Information Commissioner (OAIC) (http://www.oaic.gov.au) for guidance on alternative courses of action which may be available.

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Contact Details

If you have any questions, comments, requests, or concerns, please contact us at:

Privacy Officer

Email: privacy@cloudwave.com.au
Ph: +61 1800 941 117

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Changes to This Policy

From time to time, we may change our policy on how we handle personal information or the types of personal information which we hold. Any changes to our policy will be published on our website.

You may obtain a copy of our current policy from our website or by contacting us at the contact details above.

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