Privacy Policy

GRLmobile PRIVACY POLICY

Our Privacy Promise

Aggregato Direct Pty Ltd (ACN 141 627 152), trading as GRLmobile, is committed to protecting your privacy.

We are bound by the National Privacy Principles in the Privacy Act 1988 (Cth) (the Privacy Act) as well as other applicable laws protecting privacy, such as the privacy provisions of the Telecommunications Act 1997 (Cth). Where appropriate we will handle personal information relying on the employer exemption relating to employee records and the related bodies corporate exemption in the Privacy Act.

If we change our privacy policy we will update this Privacy Policy. We encourage you to check GRLmobile.com/privacy (the GRLmobile website) periodically to ensure that you are aware of our current Privacy Policy.

What personal information do we collect and why?

GRLmobile collects the personal information it needs to provide enhanced services and information to its customers and for its business operations. If you choose not to provide certain personal information to us, we may not be able to provide you with the services you require.

To provide services and products

If you apply for our services or products, we will collect information about you to help us to identify you, assess your application, provide you with the services and products you have requested, administer your account with us, and for related purposes. The information we collect will include your name and contact details and may also include other details such as your date of birth, driver's licence number and residential address and (if necessary for payment purposes) your credit card or direct debiting details. We may also obtain credit information about you from a credit reporting agency or from a credit provider. To provide you with our services and products and to administer your account with us, we will generate and process information about how you use our services and products (such as the type, time, location and duration of phone calls or other communications, the numbers you call and how much you spend).

You may sometimes also need to provide personal information to us about other individuals (for example, another user of your account with us). If you do so, please inform those individuals that you are providing us with their personal information and refer them to this Privacy Policy and any privacy statement that we give you.

When you apply for one of our services or products, we will usually tell you that we will contact you towards the end of contract period with us to let you know the further options that are available to you. We will usually also ask you if you would like to be contacted by us from time to time to keep you up to date with information about the products and services offered by GRLmobile and its affiliates and business partners and, if so, how you would like to be kept updated.

When you use the GRLmobile website and WAP Portal

When you use the GRLmobile website or our WAP Portal (at GRLmobile.mobi), we will collect personal information about you, such as your name, address, phone number or email address if you provide it. Circumstances in which you may choose to provide these details to us include when you enter our competitions or games, agree or ask to receive information about products and services offered by us and our affiliates and business partners, download software from the GRLmobile website or WAP Portal, register your details so you may gain access to a particular section of the GRLmobile website or WAP Portal, or send us a query about our products or services.

However please note that when you post information to the WAP Portal (or parts of the GRLmobile website that other visitors are able to access, such as on a 'bulletin board' or during an interactive 'chat') you must assume (unless we notify you otherwise in any particular case) that the information you post becomes generally available to the public and we have no ability to control or limit its use by any persons. If you use the WAP Portal, you must read carefully its Terms of Use, particularly relating to Confidentiality and Security.

To assist with your queries

When you call the GRLmobile Concierge Desk on 1300 475 475, we may collect your personal information to help us answer your query and, if you agree or ask, to keep you updated with information about products and services offered by us and our affiliates and business partners.

As part of our general business operations
We also collect personal information about individuals who are, or are employed by, our suppliers (including service and content providers), contractors, dealers, related companies, agents and corporate customers. Generally, if appropriate, we will tell you why we are collecting personal information when we collect it and how we plan to use it or these things will be obvious when we collect the information.

How do we collect personal information?

We collect most of our information about you directly from you but sometimes we may also collect your personal information indirectly, such as from credit reporting agencies, your authorised representative, publicly available sources of information, our own records about how you use your services or our related companies.

How do we use and disclose personal information?

We generally use and disclose your personal information for the purpose it was collected and for related purposes that would be reasonably expected by you.

Providing you with services and products and for operating our business For example, when you apply for our services and products, we may use your personal information to assess your application, provide you with those services and products (including billing you and administering your account) and collect overdue payments. When you provide your personal information to us (including through our WAP Portal and the GRLmobile website) to enter a competition or game, download software from the GRLmobile website or WAP Portal, register your details or send us a query, we will use your personal information for the purpose you provided it.

Keeping you informed about services and products

Where you have agreed or asked, we may also use your personal information to keep you up to date with information about the products and services offered by GRLmobile and its affiliates and business partners. If you do not want us to use your personal information in this way, you can always let us know by calling the GRLmobile Concierge Desk on 1300 475 475 or by emailing us at privacy@GRLmobile.com.
Improving services and products and conducting our business
When we collect your personal information, we may also use it to help us to carry out market and product analysis and to assist us with marketing products and services and so that we can continue to deliver enhanced services and products. As part of conducting our business, personal information may also be used to maintain and develop our business systems, including testing and upgrading them.

Resolving complaints or legal proceedings

It may also be necessary for us to use your personal information to help investigate and resolve queries or complaints or in connection with disputes or legal proceedings.

Disclosing personal information

For the purposes we have described, we may also disclose your personal information:

to our suppliers (including service and content providers), contractors, dealers, related companies and agents;
to government agencies or individuals appointed by a government responsible for the investigation and resolution of disputes or complaints concerning your use of our services and products;
to anyone to whom our assets or business (or any part of it) is transferred; or
where you have otherwise consented.
We will take reasonable steps to ensure that the persons and organisations to whom we disclose personal information are bound to protect the privacy of that personal information.

Where laws require or permit other use or disclosure

There may also be other circumstances where we may be permitted or required by applicable laws to use or disclose personal information about you, including your name, address, service number and other details. For example, these may include:

• disclosures to the operator of the Integrated Public Number Database for the purposes of inclusion in that database to facilitate the management and verification of telephone numbers, assistance to emergency services and law enforcement agencies and other approved purposes (this obligation is mandatory, and includes the details of persons who are unlisted, are registered on the Do Not Call Register or have their mobile phone numbers permanently barred);
• disclosures to law enforcement agencies for purposes relating to the enforcement of criminal and other laws;
• uses or disclosures to assist in the recovery of lost or stolen equipment;
• uses or disclosures in accordance with orders made by a court or if required or otherwise authorised by law;
• uses or disclosures to lessen or prevent serious threats to an individual's life, health or safety, or to public health or safety; or
• uses or disclosures to assist in our internal investigations into suspected fraud or other unlawful activities.

Credit checks

If you apply for one of our services or products, we may perform credit checks on you.

To do this, we may give personal information about you to a credit reporting agency in order to obtain a consumer credit report about you and to allow the credit reporting agency to create or maintain a credit information file about you. Such information may include your identity particulars, the fact that you have applied for our services and products and the credit terms (if any) of those services and products, GRLmobile provision of those services and products to You, information relating to your account with GRLmobile (including payments which become overdue for more than 60 days and for which collection action has been commenced, that cheques drawn by you for $100 or more have been dishonoured more than once or that payments are no longer overdue), that court judgments or bankruptcy orders have been made against you, or that, in specified circumstances, in the opinion of GRLmobile, you have committed a serious credit infringement.

We may also obtain a consumer or commercial credit report containing information about you or about your commercial activities and credit-worthiness from a credit reporting agency or a business which provides information about the commercial credit worthiness of persons, in order to assess your credit-worthiness for the services and products you apply for, to provide and administer them to you and to collect overdue payments relating to any commercial credit owed by you.

We may also exchange information about you (including any information about credit worthiness, credit standing, credit history or credit capacity that credit providers are allowed to exchange under the Privacy Act 1988) with other credit providers to assess your credit-worthiness for the services and products you apply for, to provide and administer them to you, to notify other credit providers of a default by you, or exchange information with other credit providers as to the status of any amounts owing by you where you are in default with other credit providers.

Employees

When you apply for a job with us we may collect certain information from you, from any recruitment consultant and from your previous employers and others who may be able to provide information to us to assist us in our decision on whether or not to make you an offer of employment.

This Privacy Policy does not apply to acts and practices in relation to employee records of our current and former employees which are exempt from the Privacy Act.

Cookies

When you log onto our WAP Portal or the GRLmobile website we may store some information (called a 'cookie') about the date and time when you entered the Portal or website. We use this type of information to track the patterns of visitors and to examine trends and demographics. This may include identifying which areas on the WAP Portal and the GRLmobile website are popular.

Cookies may be used to personalise your visit to our Portal and the GRLmobile website and to customise our service to your needs. They contain information about your preferences. Cookies are alphanumeric identifiers that your web browser transmits to your hard drive or mobile handset to enable our system to recognise your browser. This means that we are able to know information about you when you next visit our site, such as your IP address.

Cookies do not reveal your personal identity and are not personal information, but if you don't want cookies to be collected by us the Help option of your browser's tool bar will tell you how to prevent cookies or disable cookies entirely. You can still use our WAP Portal and the GRLmobile website even if you choose to disable cookies.

How secure is your personal information?

We regard the security of your personal information as a priority and implement a number of physical and electronic measures to protect it. We remind you, however, that if you send information to our WAP Portal or the GRLmobile website, the internet is not a secure environment and although all care is taken, we cannot guarantee the security of information you provide to us via electronic means.

In particular, we also remind you that when you post information to the WAP Portal we do not warrant that the use of the Portal will be confidential, that information transmitted to or from you in connection with the use of the Portal may be intercepted by third parties and that such information may include information identifying you. If you use the WAP Portal, please read carefully its Terms of Use, particularly relating to Confidentiality and Security.

How secure is your credit card information?

When you provide us with credit card information, we take reasonable steps to ensure that it is kept secure by adopting the following practices:

• where collected through our website, ensuring that encryption standards and protocols are included within the on-line web page, databases and other supporting programs which are reasonably appropriate for the purpose of keeping the information secure;
• where collected through our website or by any other electronic means (including via our call centre), refraining from storing any permanent record of that information, but instead transmitting that information to our payment gateway service provider on the basis that it be stored in accordance with applicable security standards (in which case it is stored and used by that service provider to process payments made by you to us).
• where collected through a manual form, providing a copy of the form to our bank on a confidential basis to allow payments made by you to us to be processed, and storing a copy of the form securely for a period of up to 7 years (at the conclusion of which that copy is destroyed) and limiting access to that copy to appropriate staff only.
• We do not otherwise disclose your credit card information to third parties.

 

Access and correction

We will provide you with access to most personal Information that we have about you, but sometimes that will not be possible, in which case we will tell You why. If you want to find out what information we have about you can contact the GRLmobile Concierge Desk on 1300 475 475 or by emailing us at privacy@GRLmobile.com. When you request access, we may need to take measures to verify your identity, such as by requiring your account and/or password details or other information, or by requiring your request to be in writing.


If you think that any personal Information we hold about you is not accurate, complete and up-to-date, you may request us to correct that information. We will take reasonable steps to correct such personal information unless we disagree with you about whether the information is accurate, complete and up-to-date.

More information?

If you:

• have any queries or would like further information about our privacy policies or practices, or
• wish to make a complaint about the way we have collected, used, held or disclosed your personal information; or
• would like to tell us that you do not want us to use your personal information to contact you with information about products or services, please contact the GRLmobile Concierge Desk on 1300 475 475 or by emailing us at privacy@GRLmobile.com.

Version: 100323 Privacy Policy