1. Our privacy commitment to you
We understand the importance of the Canadian Privacy Principles and are committed to ensuring the privacy of your Personal Information.
2. Why and for what purpose do we collect personal information?
ESY is required to collect certain details of your personal information to legally provide you with telecommunications services and products (including mobile phones and broadband).
We may also use personal information for other reasons, including:
– Processing orders or applications to become a customer
– Carrying out credit checks and credit reporting
– Generating bills, managing your account and carrying out debt-recovery functions
– Dealing with enquiries or complaints and other customer care activities
– Carrying out market analysis and product analysis and development
– Contacting you about our products and services and those offered under other brands that our group owns – which may include marketing these products to you
– Detect, investigate, report, address or prevent fraud and other criminal activity in relation to your accounts or security breach or service disruption.
– Assess, administer, monitor, review, customise or improve services.
– Helping us to run our business. This will include using the information for: training our staff, accounting, risk management and debt collection, record keeping, archiving, systems development and testing, developing new products and services, undertaking planning, research and statistical analysis.
– Any other purpose you would reasonably expect or that we may inform you about when asking for your personal information.
Analytic, session and cookie tools
We use the information to maintain, secure and improve our websites and to enhance your experience when using our products. We use your specific data regarding your travel behaviour to better understand how people use our products and services and to offer location specific products to you. To that end, we may use aggregated, traffic behaviour, along with information from third parties to track usage trends and thereby improve our services. We may also use this aggregated information to develop reports that we may share with third party marketing partners and affiliates. Such usage and traffic information includes:
– The date and time you access and use the services;
– Your internet service provider, mobile carrier, or data services provider;
– Your Internet Protocol (IP) address;
– Your physical address at any time;
– The pages you visit;
– The places you physically visit;
– The links you click;
– The features you use;
– How and when you interact with the services;
– The content, images and advertisements you select; and
– How you arrived at the products and where you go when you leave.
We may use your personal information to offer you products and services we believe may interest you, but we will not do so if you tell us not to. We will not sell your personal information to organisations’ outside the Group. We may use your personal information within the Group so that the Group companies can offer you their products and services. We will only offer you products or services where we reasonably believe that they could be of interest or benefit to you. If you would rather not receive communications about our latest products and services, you can opt out by clicking on the unsubscribe link at the bottom of our emails. You can also contact us over the phone through the details provided at the end of this document. Please be aware that we will still need to send you essential information about your account, and/or changes to your service or plan.
You have no obligation to provide to us your personal information, but if you do not provide us with the information required, we may not be legally allowed to provide you with the products and/or services you want.
3. What personal information do we collect?
Personal Information is information, or an opinion, in any form, and whether true or not, about an individual whose identity is apparent or can reasonably be ascertained from the information or opinion. In this context, “collect” means gather, acquire or obtain by any means, information in circumstances where the individual is identifiable or identified. Personal information also includes “Cookies”.
The amount and type of personal information that we collect and hold about you depends on the dealings you have with us and may include your name, age, date of birth, contact details such as phone, fax, email address and mobile phone number, physical address and delivery address, email address, information relating to payment for products or services including bank account and credit or debit card details your contact person at your bank or financial institution along with transactional information such as the type and quantity of products that you purchase, records of your communications and interactions with us regarding any call or message made or received through the service, behaviour relating to transactions, products, services and activity with our digital services and possibly information about your intended use of our product or service or product or service interests. When we conduct market research, we may also ask you for your opinion about products, services or staff. We treat these opinions as personal information.
We may also request information about your hotel room preferences, and frequent flyer and car rental program information. In the case of businesses, we may ask for information about the company, department or association making the purchase or setting up the account, the company and contact person details and the names of all directors, officers and if applicable senior management and employees.
There are restrictions on collecting sensitive personal information about you (this includes information about your religious views, ethnicity, political opinions, criminal records, or sexual preferences).Generally, we will not collect this sort of information unless needed to provide you with a specific product or service or if you are applying for a job with us and you have provided your consent for us to do so.
At any time, you can advise us that you wish to opt out of future contact by contacting us via phone or via the unsubscribe function in all our email or text marketing communications.
4. How do we collect personal information?
Where practical, we will collect personal information directly from you. We may do this through application forms, over the telephone, the internet, or in person when you visit our offices. When you use our telecommunication products, we will keep a record of your calls, SMS and data usage. This information will only be used to maintain the products and services that we offer to you, such as in cases where we need to troubleshoot a SIM card, phone, or broadband service. We may also collect personal information from other people. Sometimes this may happen without your direct involvement.
We collect Personal Information in a number of ways, including:
– In person;
– Over the telephone including by way of monitoring and recording telephone calls; -
– Through our websites and/or any of our applications;
– On hard copy forms;
– Through written communications including letters, facsimiles and emails;
– From third parties, including:
– Publically available sources (including telephone directories), information service providers, credit reporting agencies or anyone authorized to act on your behalf;
Agents, employees, subcontractors, suppliers and services providers;
Our partners and related entities, market research organizations (such as shoppers’ surveys and telephone polls)
– Your representative (such as a legal adviser) or your appointed point of contact.
– Government agencies and the Document Verification Service.
– Before we can provide any product or service, we may ask to collect and use the information needed. This is done via application forms, administration processes and other ways of collecting information;
– If you do not provide us with all required information, we may not be able to provide you with the product or service as requested;
– There may be times when it is lawful and practical for you to work with us anonymously; however, by doing so, we may not be able to provide you with the product or service as requested;
– If you log into your online account, we will collect information from you to confirm your identity.
– When you ring or email us, we may also monitor and/ or record telephone calls for the purposes of staff training and to verify statements made during the phone call or in the email.
– We may also collect information by other means and will take all reasonable steps to inform you if and when we do.
Each time you visit our websites, anonymous navigation information is collected by our servers. This information includes:
– The type of browser and operating system you are using
– The address of the referring site (i.e. the previous site you had visited) and the website you leave our site to visit
– The date and time of your visit; your server’s IP address (a number which is unique to the machine)
– The address of the pages you accessed.
This provides us with information about how the web site is used and navigated, including the number of hits, the frequency of visits and the duration of visits to each web page on the site. It does not personally identify individual users. In addition, our websites, like many others, uses “cookies”. A cookie is a piece of information that the website sends to your browser and which is stored on your hard disk. A cookie helps to identify your browser to the website when you return to visit the site and identifies the previous requests your browser has made. This allows the site to be tailored to you on your return visits. Cookies cannot identify you personally.
We also collect general statistical information from our website, such as the number of visitors to the website, the number of pages viewed, the date, time and duration of visits and how the visitor came to the website. We may also collect Internet Protocol (IP) addresses and internet browser type. This information will not identify you. For more information, please read the section on cookies above. So that we can continue to offer you great offers and promotion information, we give you the opportunity to say yes to being contacted by us by e-mail or SMS. This is totally your choice and you can opt out of future contact whenever you want by contacting us via phone or via the unsubscribe function in all our email marketing communications to the preference centre.
Location-Based Information and services
We may collect information relating to your general location based on:
– Information you manually provide;
– Information emitted by your telephone;
– Information that you provide to a social media provider regarding your location;
– The IP address of your telephone or computer;
– Global Positioning System (GPS) information sent to us by your GPS-enabled device; and
– The proximity of your computer, tablet, mobile wireless device, personal digital assistant, personal communication system, or other communications device (your “Personal Communication Device”) to the nearest radio tower or cell site.
We may also be able to detect when your Personal Communication Device is activated as well as when and how you are using it. We may collect data to verify the information you provide manually and to provide you with location-based content and advertising. We may associate personally identifiable information with location-based information provided by you or your Personal Communication Device solely for our internal use and to improve your experience with the products.
By purchasing or requesting us to provide you with telecommunications services through the Interanational SIM, you allow us to use your mobile device’s location. We may use your location in the event of an emergency and as required by laws applicable to us. You understand that this service enables your Personal Communication Device’s location to be determined through cellular-based mobile networks and through Global Positioning Systems (GPS). Our location-based services allow us to contact you (for example in the event of an emergency) using metadata collected by us. You may be contacted via email, SMS, App notifications and USSD Messages.
We also provide Location-Based services in the form of Geo-Location Marketing. This service uses your Personal Communication Device’s location through cellular-based mobile networks and Global Positioning Systems (GPS). If you have agreed to marketing and promotions through geo-marketing, you allow us to use your location to market offers to you. You may choose to withdraw your consent at any time by opting out of geo-location marketing in your ‘My Account’ settings.
5. When do we disclose personal information to third parties?
We may share your personal information with other companies within the Group. Your information is stored in Australia and in the United Kingdom but is also accessible to staff of companies in our Group that are located in Malaysia, New Zealand and Canada.
Sometimes we provide personal information about our customers to third parties outside our Group for the purposes set out in this policy. These may be located in Australia or overseas. The countries in which these companies are located include the United Kingdom, Italy, India, Malaysia, Canada, Hong Kong, Latvia and countries you are travelling to with your International SIM.
Generally, these are local or overseas third parties that resell, assist, support or facilitate our products or services or the operation of our business.
These may include:
– Professional advisors including your authorized representatives or professional advisors or our professional advisors, including lawyers, accountants, tax advisors and auditors.
– Your Suppliers including but not limited to hotels, airlines, car rental, and activity providers, who fulfil your travel reservations or provide to you other services you requested. Please note that these suppliers also may contact you as necessary to obtain additional information about you, facilitate your travel reservation or other requested service, or respond to a review you may submit.
– Our service providers who provide services or functions on our behalf or to us, including credit card processing, credit reporting, debt collection and recovery, business analytics and consulting, data analysis, customer service, marketing, distribution of surveys or sweepstakes programs, logistics and delivery, data processing, hosting, storage, information broking, online computing, printing, contact centre, legal, accounting, research, auditing, archival, back up, security, investigation, mailing services, analysis, fraud detection and prevention. We may also authorize our service providers to collect information on our behalf, including as necessary to operate features of our website or to facilitate the delivery of online advertising tailored to your interests.
– Suppliers and Telecommunication Services providers including upstream telecommunication and sim services providers, mainly in the United Kingdom and Italy, our system developers in India and Latvia, local network providers in the countries you are traveling to, our service and content providers, dealers and agents, contractors and advisers, mobile phone manufacturers and repairers. and other telecommunications services providers including in relation to unwelcome calls and mobile number portability issues.
– Business partners, resellers and service providers are those whom we may jointly offer products or services, or whose products or services may be offered on our website or may be facilitated by us, or who sell, market or distribute our products or services Please note that we do not control the privacy practices of these third-party business partners or resellers. Therefore, we encourage you to review their privacy policies.
– Referring websites If you were referred to this website from another site (for example, through a link you clicked on another site that directed you to this one), we may share some information about you with that referring website. We have not placed limitations on the referring websites’ use of your personal information and we encourage you to review the privacy policies of any website that referred you here.
– Government, Regulatory and Law Enforcement Agencies We may be required to disclose your personal information to law enforcement agencies, governments or regulatory bodies around the world if required by them, authorised by law, to assist with their functions or investigations or to resolve complaints or disputes, or for security, customs and immigration purposes. For example, under U.S. Law, the U.S. Department of Homeland Security Bureau of Customs and Border Protection requires that certain travel and reservation information relating to people travelling to or via the U.S.A, known as Passenger Name Record or PNR data, be provided to it prior to arrival in, or departure from, the U.S.A.
We are required by law to disclose certain personal information about you (including your name, address, telephone number and address) to the operator of the Integrated Public Number Database (IPND). Personal information in the IPND is used to assist emergency services and safeguard national security. If you consent, information from the IPND may also be published in public directories or used by directory assistance.
We may also disclose your personal information to others outside United Networks Limited where:
– We are (in limited circumstances) allowed or required by law to do so or where we have a public duty to do so.
– You have expressly consented to your personal information being supplied to others, in writing or verbally.
– It can be reasonably inferred from the circumstances that you consent to your personal information being disclosed to them (implied consent). For example, your consent will be implied for us to use and disclose your information to inform you of products and services that we believe may interest you. Your implied consent can be withdrawn at any time by telling us.
– If permitted by law, we may disclose information collected about you as an asset of the company in conjunction with the purchase and potential purchase of our company or a portion of our assets. Any personal information that is disclosed to such a third party will remain subject to the protections in the Australian Privacy Principles.
6. How can you access the personal information we hold about you?
To request your personal information, please contact us using the contact details provided at the end of this document. If you think your personal information may be inaccurate, incomplete or out of date, you can request it to be updated. We may not always be able to give you access to all the personal information we have about you. For instance, we may not be able to give you access to information that
would reveal personal information about another person or would reveal a commercially sensitive decision-making process, that we are prevented by law from providing to you or that relates to existing or anticipated legal proceeding.
We will notify you in writing if we can not give you access to the information and why. We aim to respond to most requests for access within 30 days subject to some exceptions permitted by law. We may charge a fee to cover our reasonable costs of processing your request, locating the information and providing it to you.
7. How do we keep your personal information accurate and up-to-date?
We take all reasonable measures to ensure that the personal information we hold is accurate, complete and up-to-date. However, the accuracy of your information is largely dependent on what you provide us. To ensure that we have your most current and accurate personal information, please contact us when your information changes (e.g. if you change your name or move house).
If you ask us to correct personal information that we hold about you, or if we are satisfied that the personal information we hold is inaccurate, out of date, incomplete, irrelevant or misleading, we will take reasonable steps to correct that information to ensure that, having regard to the purpose for which it is held, the information is accurate, up-to-date, complete, relevant and not misleading. If we correct personal information about you, and we have previously disclosed that information to another agency or organisation, you may ask us to notify that other entity. If so, we will take reasonable steps to do so, unless this would be impracticable or unlawful. Where we decide not to make a requested correction and you disagree, you may ask us to make a note of your requested correction with the information.
In most cases, we expect that requests to correct information will be addressed within 30 days of receipt of the request. We will notify you in writing if we can not correct the information and why.
8. How do we secure your personal information?
We will use up-to-date techniques and processes, which meet current industry standards, to protect your personal information from misuse, loss and unauthorised access, modification or disclosure.
Access to your personal information will usually be limited to our Group’s employees and service providers who need your personal information to do their jobs.
Paper documents are protected from unauthorised access or use through various security systems that we have over our physical premises. We also maintain up-do-date computer and network security systems with appropriate firewalls, encryption technology and passwords to protect electronic copies of personal information.
We also require you to help us by complying with the security measures designed to protect your personal identification numbers and passwords. These are set out in the terms and conditions of your account. You may be able to limit your liability for unauthorised use of your account if you observe these requirements. Anyone who knows your account details, such as your account number, SIM phone number, username and password, etc. can access your account. You must keep your account details secure and only share these details with people you authorise to access and manage your account. We accept no responsibility for information disclosed to parties who know or use your username or password.
9. What if you have a concern or complaint?
The privacy of your personal information is important to us and we are committed to protecting it. We have put in place a way of dealing with issues you might raise quickly and fairly. Please talk to us first. We aim to resolve your complaints within 48 hours. Please raise your complaints with any of our Customer Service Representatives. If the matter is more complex and our investigation may take longer, we will contact you and tell you when we expect to provide our response.
€$¥ International SIM partnered with United Global SIM, a local and international mobile network provider. For this reason, you should also be aware of the United Global SIM PrivacyPolicy (https://unitedglobalsim.com/