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Focus Talk is committed to the privacy of its customer records and for your information we have documented our information handling practices below. Please contact Focus Talk on 1300 784 673 if you wish to discuss any aspect of our information handling practices.

Is Focus Talk bound by the National Privacy Principles or an approved Privacy Code?
As a private sector company, Focus Talk is bound by the Privacy Act 1988. Under the Act, Focus Talk, or the telecommunications industry, can choose to develop and be bound by a Privacy Code or choose to comply with the National Privacy Principles in the Privacy Act 1988. Focus Talk has chosen to be bound by the National Privacy Principles.

The kinds of personal information held by Focus Talk and how it is collected
Focus Talk only collects personal information from you that is necessary for it to perform its functions. The kinds of personal information Focus Talk holds about you will depend on the services you request from Focus Talk and the use that you make of those services. However, the information may include:

• Your name, address and contact details;
• Your date of birth;
• account name and account number held by financial institutions from which payments for services provided by Focus Talk are made and information obtained as a result of credit checks which you authorise us to carry out;
• Records of communications between you and Focus Talk relating to services provided by Focus Talk to you;
• Records of use made by you of services provided by Focus Talk to you;
• Billing statements.

In most cases, we collect your personal information directly from you when you provide it to us. In some cases, for example where we carry out credit checks or collect information from organisations to whom we outsource functions, your personal information will be collected indirectly.

Use of your personal information
Focus Talk respects your privacy. As a result, Focus Talk does not trade, rent or sell your personal information.

The primary purpose for which we use your personal information is to provide you with telecommunications services. In the course of providing telecommunications services to you we may also use your personal information for related purposes which include the following:

• Provisioning or connecting your service;
• Network routing;
• Providing you with customer service;
• Credit checking;
• Billing you for that service;
• Investigating complaints in relation to your service;
• Investigating and fixing faults in relation to your service;
• Following up any payments that you may owe us;
• To administer contractual agreements or arrangements necessary to provide services to you;

Sending you product or services information. We may also use your information to tell you about our other products and services or bundled offerings, provided by us in conjunction with either or related bodies corporate or our business partners and associates.

How Focus Talk collects personal information
For corporate customers, Focus Talk collects some personal information from company employees, principals or directors of Focus Talk in order to provide services to Focus Talk.

For corporate customers, Focus Talk collects some personal information from list rental companies.

For individual customers, Focus Talk collects personal information directly from you when you supply it to us in connection with a request for services. Focus Talk may also collect personal information from third parties such as:

• Resellers of telecommunication services;
• Credit providers or credit reporting agencies contacted by us (or by external service providers on our behalf) in the course of carrying out a credit check;
• Other entities that provide services to us which are related to the provision of telecommunication services provided to you;
• Government agencies which administer laws regulating telecommunication service providers, or complaint resolution processes established under those laws;
• Independent sales organisations; and,
• List rental companies.

Contracting out services and disclosures
Focus Talk contracts out some services such as mailing, credit checking, provisioning, billing, printing, verification of sales and fault fixing to external service providers. Focus Talk may disclose your personal information to these organisations but only so that they can provide you with the services that Focus Talk has contracted out.

Focus Talk may disclose your personal information to other telecommunications services and equipment providers, 2easy Telecom's related bodies corporate, resellers, credit providers, credit reporting agencies, organisations to whom Focus Talk outsource services (such as mailhouses), and our business partners and associates. At your request, Focus Talk may disclose your information to directory providers so that your information can appear in telephone directories.

Personal information shared with related bodies corporate may include your name, address, and service history.

Focus Talk may disclose some of your personal information such as your name and address to organisations located outside Australia in countries which do not have the same or substantially similar privacy laws but only to the extent necessary to provide you with telecommunications services requested by you.

At all times, parties to which we contract services or disclose your personal information are either covered by contracts which protect your personal information or are subject to obligations which are substantially similar to the National Privacy Principles.

Access to Personal Information
Generally, you have the right to see or obtain a copy of personal information about you that we may hold.

Focus Talk will handle requests for access to personal information in accordance with the National Privacy Principles.

To request access to your personal information, please contact our Call Centre on 1300 784 673.

As long as we can verify your identity, the person you speak to may be able to provide you with the information you require over the telephone. If you wish to have a copy of any information, we will ask that you put your request in writing and either post or fax that request to us. Again, this is to ensure that we can verify your identity.

In some cases, we may need time to consider and respond to your request for access. If we need time to consider your request, we will acknowledge your request within 14 days and respond within a maximum of 30 days.

If for any reason we refuse to give you access to your information we will let you know why.

The circumstances in which we may refuse to give you access to personal information we hold about you include where giving you access:

• Would have an unreasonable impact on other people's privacy;
• Would prejudice any negotiations we are having with you;
• Would prejudice an investigation of unlawful activity;
• Would prejudice activities carried out by, or for, a law enforcement body.

If you believe that we hold personal information about you that you consider to be inaccurate, incomplete or out of date you should tell us by calling 1300 784 673. In most cases, we will amend any inaccurate, incomplete or out of date information. In some cases it is necessary for us to keep a record of what we know or understand to be correct at a particular time. However, in those circumstances, if you request, we will take reasonable steps to associate with the relevant record of your personal information a statement to the effect that you claim the information is inaccurate, incomplete or up-to-date. We would ask that you discuss your request with us by calling 1300 784 673.

Security of your personal information
Focus Talk is committed to protecting your privacy and recognises its obligations to take all reasonable steps to protect your personal information from misuse and loss and from unauthorised access, modifications or disclosure both under the Privacy Act 1988 and the Telecommunications Act 1997.

Security of your information while on line:
Our web server is capable of up to 128bit SSL encryption. Note however, that our web server can only choose the highest common level with your browser. If you use older browsers, you may find that it only supports 40bit or 56bit encryption.

Cookies are small text files that our web server may ask your web browser to store on your machine. The cookie cannot tell who you are, or determine your personal details, and is not used to actually track your access, apart from making sure you are the same person over a given "session" online. Although you could turn off cookies and not normally have any problems accessing many parts of our sites, there are other parts of our web server that rely on cookies. For instance we may use a cookie to store information temporarily between various pages in a lengthy multi-part order form, or to store screen preferences.

We do not make use of 3rd party cookies, 'web beacons', or other tracking mechanisms on our website.

Security of Stored Information
We take physical and electronic measures to secure your information. We store your personal information in password-protected servers that are in a restricted and monitored area. Access to this information is limited.

You also have a role in security of your personal information in some cases. For example, if you have been given access to our "Your Account", where you may pay your bill, look up call information and so on, it is your responsibility to protect your own personal access password.

Other Websites
Some of our websites contain links to other, external websites. The Focus Talk group of companies is not responsible for content or privacy policies websites that we do not operate.

Website Access Logs
All accesses to pages on our websites are "logged". The sort of information contained in these logs cannot easily identify you personally, but instead contains such things as a list of all of the pages accessed, and the sort of browser used.

This information is used to check for attempts at "hacking", or other fraudulent activity, to indicate missing pages or other web server problems. It is periodically summarised to provide general statistics such as the number of people viewing particular parts of the site.

Changes to this Privacy Awareness Policy
From time to time, it may be necessary for us to review our Privacy Awareness Policy. We reserve the right to amend our Privacy Awareness Policy at any time and to notify you by posting an updated version on the Focus Talk website.

You can raise any privacy related concern or complain about breaches of your Privacy in writing or by phone to:

The Manager
Focus Talk
PO Box 2206
Ballarat Mail Centre VIC 3354

Phone: 1300 784 673
Fax: 1300 790 868

E mail Address:

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