Why do we collect personal information?
CIPL only collects personal information from you if that information is reasonably necessary for or related to, one or more of CIPL's functions and activities. For example, we collect your personal information to enable us to provide you with the capability and services you are seeking to manage your own business.
What personal information do we collect?
If CIPL is providing the Services to your business, the types of personal information that we may collect will include details of your name, date of birth, street address, email address, telephone number that we may direct your calls to and a cell phone number that we can send notification messages to and credit card and bank account details.
CIPL may also collect and store your Client username information & password when you register and subscribe on the Website.
If you contact a business which is using our Services, we may collect your contact details, including your name, telephone number and/or email address on behalf of that business.
When you apply for employment or a contracting opportunity with us, we also collect other details such as your educational and employment history, as well as referee details. If you accept an offer of employment, we will collect your Tax File Number and details of your superannuation fund.
From time to time, you may be able to visit the Website anonymously or deal with us anonymously or by pseudonym. However, as we require certain personal information such as your name, current e-mail address and postcode to be able to provide you with our Services, if you do not provide us with certain personal information, we may not be able to provide you with access to those Services.
How do we collect personal information?
We will only collect personal information which you have voluntarily provided to us, or consented to us collecting.
We collect personal information from you in a variety of ways. For example, when you:
- register for a Client Account on our Website (“Client Account”): we need to collect your name, contact information and, when we ask you to set up a Client Account, we collect your username identification and password;
- order or purchase services on our Website – we need to collect your name, contact information (in particular an email address), your credit or debit card number and the card's expiry date;
- subscribe to our newsletter or mailing list;
- respond to a survey we may conduct, or fill out a form or similar;
- enter into competitions or promotions; or
- contact us – for example, telephone calls may be recorded for training, quality and business purposes and, if so, you will be informed of this at the commencement of the call and given the opportunity not to proceed with the call or not have the call recorded.
We may also collect personal information:
- from our authorised resellers;
- from publicly available sources of information, such as market research providers;
- from third parties such as law enforcement agencies and other government entities; and
- when you visit our website, Facebook page or any other webpages that we own and manage.
We will only collect your personal information from third parties if it is unreasonable or impracticable to collect that personal information from you directly. If and when we do collect personal information from third parties, we will take reasonable steps to inform you.
- site performance identifiers: these give CIPL information about how our Website is used. This helps us provide you with a more user-friendly experience.
- analytics cookies: we may use these to gather statistics about our Website. For example, they help us monitor how many users are on the Website and what sections are most popular.
- advertising cookies: we may use these cookies to improve our understanding of the kind of advertising that may be relevant to you.
You can clear cookies or digital identifiers from your device and also disable future use of them by changing the security settings on your web browser. However, doing this might mean that parts of the Website may not work as intended.
How and what do we use your personal information for?
By submitting your personal information to CIPL and by using the Website, you agree that CIPL may obtain, hold and use your information for the purposes of providing you with products or services and for its internal business purposes.
Any of the personal information we collect may be used in any one or more of the following ways related to providing you with the quality products and services you requested:
- Processing transactions and managing your Client Account – your personal information will allow us to process any orders and transactions you make for products and services and to generate and send you bills, invoices, receipts and otherwise manage your Client Account with CIPL;
- Managing your CIPL Virtual Reception – your personal information will allow our CIPL team to provide you with tailored and relevant services, for example, when answering and receiving calls or messages or making appointments on your behalf;
- Personalising your customer experience – your personal information will help us to better respond to your individual Client needs and requests;
- Managing your concerns and our customer services – we may use your personal information to contact you when responding to your enquiries or complaints and other customer care services or activities and support needs;
- Keeping you informed – we may use your email address to send you information and updates relating to your transactions and your Client Account, as well as to send you occasional company news, updates and related or new product and service information;
- Conducting contests, promotions, surveys and other site features – your personal information will assist us to provide you with opportunities to participate in various promotional activities and other site features to enhance your experience with CIPL; and
- For any other purposes that would be reasonably expected to allow us to comply with our obligations under the law.
The legal basis for processing your personal information depends on our relationship with you. Personal information that we collect and use is processed either with your consent, or on the basis that it is necessary to fulfil any contractual obligations we may have when you make purchases from us or that it is necessary for the purpose of our legitimate interest of providing and promoting our products and services and direct marketing.
If CIPL uses your personal information for any other purpose, we will obtain your consent to use that personal information, if and when required.
How do I unsubscribe from marketing materials?
If you would rather not receive communications about our latest products and services, changes to products and services, company information or promotional opportunities, you can opt out. If at any time you would like to unsubscribe from receiving future emails of this kind, you can do so by clicking the "unsubscribe" link at the bottom of each email.
However, please be aware that we will still need your essential personal information to assist in the management of your Client Account, purchases and in providing you the services you require.
Do we disclose any of your personal information?
Your personal information may be disclosed both within and outside Australia to:
- A client of CIPL that you call, to whom we provide, for example, virtual receptionist services on our clients’ behalf, such as taking messages and scheduling meetings;
- Our third party service and content providers, such as payment processors, authorised resellers, agents, contractors and advisors. Further information about some of these third parties is provided below;
- Our professional advisors including lawyers, accountants, tax advisors and auditors;
- Law enforcement bodies to assist in their functions, courts of law or as otherwise required or authorised by law;
- Regulatory or government bodies for the purposes of customer complaints or disputes both internally and externally; and
- Any other person or for any other purpose that would be reasonably expected.
Details of third party service providers CIPL uses routinely are set out below.
eWAY (Web Active Corporation Pty Ltd)
EziDebit (Ezidebit Pty Ltd)
Macquarie Telecom (Macquarie Telecom Group Limited and Macquarie Telecom Pty Ltd)
MailChimp (The Rocket Science Group LLC)
Occasionally, the information you provide to us may be accessed by or given to staff and third parties working outside of Australia, for example employees of our foreign subsidiary entities in order to deliver you with after-hours receptionist services.
Where we do disclose your personal information to overseas recipients, these recipients are most likely to be located in the US or the UK but this list of countries / regions is not exhaustive
What security measures does CIPL use to protect your personal information?
CIPL takes your privacy seriously and takes every reasonable measure and precaution to protect and secure your personal data. We work hard to protect your information from unauthorised access, alteration, disclosure or destruction and have several layers of security measures in place, including:
- Use of a firewall with up-to-date rules to restrict private and public access as well as limiting/eradicating potential threats, such as denial of service attacks;
- Password protected access to all systems providing the level of access required to fulfill a function;
- Constant system patching and software upgrades as well as up-to-date virus definitions to eliminate threats;
- Encryption of highly confidential data; and
- The use of SSL (secure sockets layer) and TLS (transport layer security) where appropriate to maintain a high level of security.
In order to protect your information, we implement a variety of security measures to maintain the safety of your personal information when you make a transaction on the Website, or enter, submit or access your personal information via your Client Account or Message Centre. For example, we use a secure server for online credit card transactions with up to date encryption methods. Information on this secure server is not available to CIPL staff.
However, by its nature, we cannot guarantee that information transmitted on the internet is 100% secure. By providing us with your personal information and continuing to use the Website to make transactions, you agree and acknowledge that CIPL shall not be liable to you or any other person for any of the following:
- Performance, security, reliability and your competence in using the internet, telecommunication companies, and internet service providers in transmitting information;
- The confidentiality of your Subscriber password and the use of the CIPL Messaging by third parties for any reason. You are responsible for your own password security and must ensure that this password is not disclosed to any third party, for whatever reason; and
- Security of any information transmitted on the internet.
How long do we retain your personal information?
We will not keep your personal information for any purpose for longer than is necessary and we retain only the relevant personal information for that purpose.
We determine how long to retain different types of personal information depending on what is necessary for our business operations, taking into account our legal obligations and statutory retention periods.
We retain the personal information that you provide to us for registering an account for as long as your account remains in existence.
We may need to retain personal information, such as financial records of transactions, for as long as required to comply with our legal and financial compliance obligations as well as our contractual obligations with our services providers such as our payment processors.
Personal information will be de-identified or destroyed when no longer required by us.
How do we maintain the accuracy of the personal information we hold about you?
CIPL aims to take all steps as are reasonable in the circumstances to ensure that the personal information we collect, hold, use and disclose about you is accurate, up to date and complete.
However, the accuracy of your personal information is largely reliant on the quality of the information you provide to us. To ensure that we always have your most current and accurate personal information, please update your details as soon as possible when your information changes via your online Client Account or contact CIPL by the methods below or on the Contact page of our Website.
Can you access and/or correct personal information we hold about you?
You have the right to access any personal information that CIPL processes about you. If you believe that we hold any incomplete or inaccurate data about you, you have the right to ask us to correct and/or complete the information.
You can make a request for access or correction by contacting CIPL by the methods below or on the Contact page of our Website. We may ask you to verify your identity before processing your request to ensure that your personal information is protected and kept secure.
We will endeavour to respond to your request for access and/or correction within thirty days after your request is made. We may charge reasonable costs for responding to the request, however, we will not charge you for making a request.
If we refuse to provide you with access, or to correct the information, we will generally provide you with written reasons for our refusal and how you may complain about the refusal. If we refuse your correction request, we will include a statement with your personal information about the requested correction.
How can you report a breach of your privacy?
If you have any concerns that your privacy has been compromised or have any other privacy related complaint, please contact CIPL immediately by a method below or on the Contact page of our Website.
We will first consider your complaint to determine whether there are simple or immediate steps which can be taken to resolve the complaint. We will endeavour to complete our investigation into your complaint promptly. We may ask you to provide further information about your complaint and the outcome you are seeking. We will then typically gather relevant facts, locate and review relevant documents and speak with individuals involved.We will first consider your complaint to determine whether there are simple or immediate steps which can be taken to resolve the complaint. We will endeavour to complete our investigation into your complaint promptly. We may ask you to provide further information about your complaint and the outcome you are seeking. We will then typically gather relevant facts, locate and review relevant documents and speak with individuals involved.
In most cases, we will investigate and provide a written response to a complaint within 30 days of receipt of the complaint. If the matter is more complex or our investigation may take longer, we will let you know.
If you are not satisfied with our response to your complaint, a complaint may be made to the Office of the Australian Information Commissioner (“OAIC”). The OAIC can be contacted by telephone on 1300 363 992 or by using the contact details on the website www.oaic.gov.au.
General Data Protection Regulation (relevant to individuals located in the EU)
Capitalised terms and phrases used in this section but not otherwise defined shall have the same meanings given to them in the GDPR. CIPL gather and process your personal information in accordance the GDPR (as amended or updated from time to time). CIPL act as the Data Processor when Processing your Personal Data.
For the purposes of the GDPR, CIPL’s designated EU representative is ReceptionHQ LLP (a limited liability partnership registered in England and Wales with offices at Bunnian Place, Basingstoke, Hampshire RG21 7JE, United Kingdom) OC358482. ReceptionHQ LLP is registered on the Information Commissioner’s Office Register; registration number ZA385794
If you are in the EU, in addition to the rights identified above, you also have the right to request erasure of your personal data or to restrict processing (where applicable) in accordance with the data protection laws; as well as to object to any direct marketing from us. Where applicable, you have the right to data portability of your information and the right to be informed about any automated decision-making we may use. If we receive a request from you to exercise any of these rights, we may ask you to verify your identity before processing the request to ensure that your data is protected and kept secure.
If you are in the EU, you may also request information about:
- What personal data we hold about you;
- The purposes of the processing;
- The categories of personal data concerned;
- The recipients to whom the personal data has/will be disclosed;
- How long we intend to store your personal data for; and
- If we did not collect the data directly from you, information about the source.
The Information Commissioners Office
Water Lane, Wycliffe House
Wilmslow – Cheshire SK9 5AF
Phone: +44 1625 545 745
Cloud International Pty Ltd
Level 14, 275 Alfred Street
North Sydney NSW 2060
Last Updated: 16 November 2020