Privacy and Collection Statement

Ethan Group Telco / CR Voice & Data

Introduction

This Statement Includes

> our collection statement, explaining aspects of our collection and use of personal information
> our privacy policy, further explaining how we manage personal information.

Collection Statement

Who We Are

Ethan Group Pty Ltd ACN 099 503 456

Our Contact Details

> Phone: 1300 0 ETHAN (38 426)
> Email: crvoiceanddata@ethangroup.com.au
> Web site: https://www.ethangroup.com.au

Collection from third party sources

We may collect personal information from someone other than you, and you may not be aware of the collection, when it is not reasonable or practicable to collect it from you, and it is available from:

> publicly available sources like phone books
> other companies in our group that you may have dealt with
> third parties like our business partners, your authorised representative/s and wholesalers
> information brokers
> other telecommunication and information service providers that interact with us in providing products to you (eg overseas when you use a roaming mobile service)
> fraud checking agencies
> our dealers, contractors and other representatives that you may deal with
> our websites and how you use them
> various parties listed under Disclosing personal information in our Privacy Policy.

Collection under law

We may be required to collect personal information under the Telecommunications Act 1997 and laws made under it (eg if we supply a pre-paid public mobile telecommunications service, we are required by law to carry out an identity check.)

Why we collect and hold personal information

We collect and hold personal information because:
> we may need to use it to operate our business
> we may need to provide it to other parties in connection with our business.

Unavailability of personal information

If we cannot collect the information we need about you, we may not be able to supply the products or service you want.

Disclosing Personal Information

We may disclose personal information as reasonably required to contractors and suppliers who goods and services that we use to operate our business and provide products and support to you, and to other parties detailed in our Privacy Policy.
Some of these parties may be based overseas including countries where you use roaming services while travelling.

Access and correction

Our privacy policy contains information about how the you can access and seek correction of the personal information about you that we hold.

Complaints

Our privacy policy explains how you can complain about a breach of the Australian Privacy Principles, and how we will deal with such a complaint.

Privacy Policy

Collecting personal information

Unless it is not reasonable or practicable to do so, and in other cases allowed by law, we will collect personal information about you directly from you (eg when you contact us by phone or online, or at our
premises, or fill in an application form).
In other cases, we may collect personal information about you from:

> publicly available sources like phone books
> other companies in our group that you may have dealt with
> third parties like our business partners, your authorised representative/s and wholesalers
> information brokers
> other telecommunication and information service providers that interact with us in providing products to you (eg overseas when you use a roaming mobile service)
> fraud checking agencies
> our dealers, contractors and other representatives that you may deal with
> our websites and how you use them
> various parties listed under Disclosing personal information below.

Holding personal information

We hold personal information in hard and/or soft copy at our offices and in other facilities that we own or license from third parties, like data centres. We take reasonable steps to keep it secure and to protect it from unauthorised access, use or alteration.

Why we collect and hold personal information

We collect and hold personal information because:

> we may need to use it to operate our business
> we may need to provide it to other parties in connection with our business.

The uses and disclosures we may make of personal information are detailed in our Privacy Policy.

Using personal information

We may use personal information:
> to identify you
> for credit checks
> to prevent fraud
> to supply products (including goods and/or services) to you
> to give you information about us and our products, and product offers
> for direct marketing – see Direct marketing for details
> to improve our products, our marketing and our website
> to answer your enquiries
> to give you customer support and service
> to better understand your needs and respond to them
> to manage and plan our products and business
> to charge and bill you for products you use
> to collect payment from you
> to monitor, manage, test and improve our network and facilities
> to comply with various laws that apply to us, including the Telecommunications Act 1997 and our obligations under any
carrier licence that we hold
> for other purposes related to the operation of our business.

Disclosing personal information

We may disclose personal information as reasonably required:
> to contractors and suppliers who supply or support us in:
• market research, sales and marketing
• direct marketing – see Direct marketing for details
• identity and fraud checking
• credit management
• service provisioning
• installation, maintenance and repairs
• helpdesk and enquiries
• support and complaint management
• communications and mailing
• billing, debt recovery and credit management
• network and product design and maintenance
• corporate strategy
• legal and regulatory advice and compliance
• accounting and financial planning
• risk management
• otherwise providing goods and services that we use to operate our business and provide products and support to you
> to your authorised representative/s
> if you ask us to do so
> to our agents, dealers and members of our corporate group
> to our business partners and wholesale suppliers
> to other telecommunication and information service providers that interact with us in providing products to you (eg overseas when you use a roaming mobile service)
> to the manager of the Integrated Public Number Database, the Australian Communications and Media Authority, police, law enforcement and national security agencies and other authorities when and as required by law
> to organisations that provide credit or finance to us
> to persons who invest in or acquire all or part of our business or company, or are considering doing so.
Some of these parties may be based overseas eg [name countries if practicable] and countries where you use roaming services while travelling.

Direct marketing

We may use and disclose personal information to direct market to you products offered by us, our agents, dealers and members of our corporate group, and our business partners, where we think the offers will be of interest to you, using:
> post
> email
> electronic messaging
> social media
> targeted web content
> other direct marketing channels.
Direct marketing may continue until you opt-out by calling the number in Contacting us even if you are no longer our customer.

Accessing and correcting personal information

Please contact us for these purposes using the details in Contacting us below. We shall process and respond to your request in accordance with Australian Privacy Principle 12. There is no charge for making a request but a reasonable administrative charge, on a cost recovery basis, may be payable before we agree to provide access.

Complaints

If you wish to complain about a breach of the Australian Privacy Principles, please contact us using the details in Contacting us below. We shall:
> acknowledge your complaint within a reasonable time
> give you an estimated first response time
> allocate your complaint to a suitably senior staff member
> process and respond to your complaint as soon as we reasonably can.

Contacting us

Questions, requests and complaints regarding our Privacy Statement or our compliance with privacy laws should be directed to us by telephone on 1300 0 ETHAN (38 426) or email to crvoiceanddata@ethangroup.com.au