Consumer Protection

Privacy Policy

LIVA Telecom is committed to protecting your personal information in accordance with applicable privacy laws.

LIVA Telecom is a business name of CKS Group Australia Pty Ltd (ABN 32 621 849 518). This Privacy Policy applies to LIVA Telecom and its related entities and businesses that have not adopted a separate privacy policy (LIVA Telecom, we, us or our). This Privacy Policy explains our commitment to collecting, using, disclosing, storing, handling and protecting your personal information in accordance with applicable privacy laws. This Privacy Policy applies to all personal information collected through our interactions with you, including via our websites, applications, platforms, social media channels, telephone communications and email.

LIVA Telecom (ABN 32 621 849 518) provides telecommunications services and IT solutions to residential customers and businesses of all sizes, including wholesale customers. Our services include internet services, VoIP and mobile phone services, business hardware, managed networks, managed security solutions and managed cloud services.

In this Privacy Policy, personal information has the meaning given under applicable privacy laws, including the Privacy Act 1988 (Cth) (as amended or updated from time to time) (Privacy Act). In general, personal information is information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information is true or not and whether it is recorded in a material form or not.

Personal Information

The personal information we collect depends on the purpose for which it is collected, including the products or services you acquire from us, how you use them and the nature of our relationship with you. This may include: • Customers acquiring our services: Information required to verify your identity and establish your account, including your name, date of birth, email address, proof of identity, billing or mailing address, financial information, payment information, (such as credit or debit card details or bank account details), order information and contact numbers. For business, enterprise and government customers, we may also collect individual relationship or account manager contact details. • Customers using the LIVA Telecom app: - Location information, including precise or approximate location data from your mobile device when the MyLiva app is operating in the foreground or background; - Transaction information relating to app usage, including route details such as date and time, start and end locations and distance travelled; - Usage information such as access times, features or pages viewed, browser type, system activity and app crash data; and - Device information including hardware models, IP addresses, unique device identifiers, operating systems and versions, software information, advertising identifiers, device motion data and mobile network data. • Customers using our website: Technical information and analytics relating to your use of our website, systems and applications, including browser type, browsing preferences, internet service provider, referring and exit pages, timestamps, IP address, time zone and geolocation data (where applicable), some of which is collected automatically. • Customers using our services while signed into a Google account: Technical information and analytics as described in the Use of Google Analytics section below. • Customers who choose to receive news and updates about promotions, exclusive offers or event information: Your name, postal or street address, email address and contact telephone number(s). • Customers who contact us: Where you make a complaint, provide feedback, submit an enquiry, request a call-back or request a product replacement, we may collect your name, mailing or street address, email address and telephone number(s). • Prospective employees or contractors: Information contained in applications or CVs, interview records (where permitted by law), background check information and government-issued identifiers where required by law. • Suppliers and business partners: Postal or street addresses and individual or account manager contact details including email addresses and telephone numbers. If you provide us with personal information about another individual (such as an authorised representative or family members), you must obtain their consent and provide them with a copy of this Privacy Policy and Credit Reporting Policy before supplying their information to us.

Telecommunications Information

Telecommunications Data has the meaning given in section 276(1) of the Telecommunications Act 1997 (Cth) (as amended or updated from time to time). Depending on the services you acquire, we may collect Telecommunications Data including: • usage and transaction data relating to LIVA Telecom applications, including route details platforms and services; • device and system information including hardware details, IP addresses, operating systems, identifiers and mobile network data; and • technical and analytical information collected automatically through your interaction with our websites and platforms.

Sensitive Information

We may collect limited sensitive information where necessary, such as criminal history information for fraud prevention, biometric identifiers (including voice recognition or fingerprints) to identify you or if we are required to collect health information required to provide specific products or services. We will obtain your consent before collecting sensitive information unless collection is required or authorised by law.

We collect personal information directly from you and through your use of our services, including when you: • interact with our websites, apps, platforms or customer service teams; • use our network, products or services; • subscribe to receive offers and news, events or promotions; • make inquiries about us or our products or services or otherwise communicate with us by email, in person, by telephone, online, via a website or otherwise; and • apply for employment or contract roles with us. We may also collect personal information from third-party sources, including: • publicly available information including websites, telephone directories, Internet or social media platforms; • if you are an applicant for a role with us, from recruiters or referees; • our suppliers and business partners; • credit reporting agencies; and • by video surveillance if you attend our premises (your image may be captured by CCTV).

We may use cookies, log files, web beacons, tags and pixels, which are electronic files used to collect technical information and usage analytics about how users interact with our websites and LIVA Telecom applications. You can disable cookies via your browser settings. If you do so, you can still access our website, but some functionality or user experience may be affected. For more information about cookies, and how to disable cookies, visit www.allaboutcookies.org

We use web analytics tools such as Google Analytics (and, where enabled, Google Signals) to help us understand how visitors engage with our websites and online services. These tools may use cookies or similar technologies to collect technical and usage information about your interactions with our websites. In addition to LIVA Telecom's own cookies, third parties may also place cookies on your device when you use our websites. For example, cookies may be delivered by third-party advertisers, content providers or when you click on links to third-party websites. If you consent to ads personalisation, those third parties may collect and use information in accordance with their own privacy policies. These third-party cookies and analytics services are not controlled by LIVA Telecom and are not covered by this Privacy Policy. We recommend that you review the privacy policies of any third-party websites or services before providing them with your personal information or enabling personalised advertising.

LIVA Telecom may use tracking pixels and similar technologies provided by third-party advertising platforms. This may result in targeted advertising being shown to you on those platforms based on your interactions with our websites or services. You can opt-out of receiving targeted advertising from many major platforms by adjusting your advertising preferences with those providers. For example, you may review or change your advertising settings with providers such as Google, Facebook, LinkedIn and other digital advertising platforms that you use. You may also choose to opt-out of interest-based advertising from a range of participating companies by visiting the Digital Advertising Alliance's opt-out portal (www.aboutads.info/choices).

You may choose not to identify yourself, or to use a pseudonym, when you contact us to make a general enquiry about LIVA Telecom or our services. However, if you choose not to provide certain personal information, or you ask to deal with us anonymously or under a pseudonym, we may not be able to provide you with the products, services or information you require. For example, we will not be able to send you requested information without a valid email address or telephone number, and we cannot supply services without relevant billing and payment details.

Managing our business and providing our products and services to you, including to:

• supply you with the products and services that you request; • confirm and verify your identity; and • issue invoices and process payment for our products and services.

Improving our services, including to:

• ensure the proper operation and functionality of our services; • monitor network usage, quality and performance, and to operate, maintain, develop, test and upgrade our products, systems and infrastructure; and • use analytics and intelligence tools to gain high-level insights into usage and location patterns or trends, network performance, demographic trends and other behavioural data, as further described in this Privacy Policy and Credit Reporting Policy, where applicable.

Compliance with laws, including:

• complying with the laws that apply to us, such as telecommunications legislation and related industry codes and standards; • enabling access to emergency services where the law allows; and • supporting law enforcement authorities and emergency services when required.

Network, Security and Fraud Protection, including to:

• identify, prevent and investigate suspicious, fraudulent, criminal or otherwise harmful activity (including scams) that may impact you, us or others, including in relation to our services; • protect the security of our networks and systems, and notify you where there are network security or data breach concerns; and • carry out audits or assess your creditworthiness.

Direct Marketing, including to:

• send you newsletters or direct marketing messages as described in the 'Direct Marketing' section below, unless you have chosen not to receive them; and • undertake general market research and analysis. (Please refer to the 'Direct Marketing' section below for more details, including how to opt out of direct marketing.)

Communication, including to:

• contact you in relation to any of the above matters, using SMS, email, post, telephone or any other lawful method; and • if you apply for a job with us, contact you about your application or other suitable opportunities.

We may also use your personal information to create aggregated or de-identified information so that we can better understand how our customers use our products and services, improve and personalise your experience, and enhance the services we provide. We also use technical information and data analytics to assess visitor traffic and usage trends, to deliver personalised content when you use our websites, and to help us improve our services.

We may send you marketing communications via mail, SMS, email or third-party platforms to inform you about offers, promotions or changes relating to our products and services. You may opt out of marketing communications at any time using the opt-out mechanisms provided or by contacting us directly. You cannot opt out of essential operational communications such as invoices, outage notifications or emergency alerts. We may send you direct marketing communications through various channels, including post, SMS, email or via third-party marketing platforms. We do this to market, promote or keep you informed about offers, promotions or changes relating to products and services that you obtain from us, or about other products and services that we, our subsidiaries or our business partners believe may be of interest to you. We may use your personal information for these purposes for up to 12 months after you stop acquiring products or services from us. We will not send you direct marketing communications where you have told us that you do not wish to receive them. You may opt out of receiving some or all direct marketing communications from us at any time, either by contacting us using the details set out below, or by using the opt-out facility included in the relevant communication. Where available, you may also manage your marketing preferences through your online account settings. You cannot opt out of receiving operational or service-related communications (such as notices about network outages, invoices or urgent service updates). You can opt out by: • phoning us on 1300 345 148; • emailing us with the subject line 'Opt-out of direct marketing' at marketing@livatelecom.com.au

We may disclose your personal information to third parties where this is reasonably necessary to achieve the purposes outlined in this Privacy and Credit Reporting Policy. This may include sharing your personal information with the following categories of third parties: • our employees, contractors, and third-party service providers; • organisations engaged by us to carry out promotional, research, and/or marketing activities, including managing opt-outs or exclusions from targeted or direct marketing communications; • if you are an applicant for a role with us, third parties you have authorised us to contact or provide information to (such as referees); • We may, in accordance with applicable law, approach a credit reporting body regarding your credit information. • We may also engage a licensed third-party debt recovery agency to recover any outstanding amounts. • our related bodies corporate, subsidiaries, and affiliated businesses, for the purposes set out in this Privacy Policy including to provide you with a seamless and personalised experience when interacting with those entities; • any prospective purchaser of, or investor in, our business or assets, and their professional advisers; and • any other person or organisation where disclosure is required or permitted by law. We may also disclose your personal information to third parties where: • you have consented to the disclosure; • the disclosure is required or authorised by law, or is reasonably necessary for law enforcement purposes or public safety; or • the disclosure is necessary to prevent or lessen a serious and imminent threat to the life, health, or safety of any person.

We may disclose your personal information to organisations located outside Australia, including suppliers and service providers who assist us in delivering products or services connected with our business operations. Our overseas service providers may be located in the United States, Singapore, Malaysia and India. Each of these jurisdictions has laws that regulate the handling and protection of personal information. We take reasonable steps to ensure that any overseas recipient of your personal information handles that information in a manner consistent with the requirements of applicable Australian privacy laws. If you would like further information about a specific overseas disclosure of your personal information, please contact us using the details set out in the How to contact us section below.

We store your personal information using electronic record-keeping systems and secure databases. From time to time, we may combine or link the personal information we hold about you with other personal information obtained from third-party sources. We use this information internally, including for data analytics purposes, to identify trends, insights, and opportunities and to improve our services.

We take reasonable steps to protect personal information from misuse, loss, theft and unauthorised access, modification or disclosure. These measures include security, access controls, network security systems and industry-standard safeguards. Please notify us immediately if you believe your personal information has been compromised or subject to unauthorised access.

Overview

LIVA Telecom may collect personal information about you from, and disclose your personal information to, organisations whose business involves handling personal information for the purpose of providing information about an individual's credit worthiness (Credit Reporting Bodies). This may occur in connection with your application for services, the provision of services, or other dealings you have with us. Where a serious credit infringement occurs in relation to credit provided for our services, we may be entitled to disclose that information to a Credit Reporting Body. We store and manage credit information and credit eligibility information in the same way as we manage other personal information, in accordance with applicable privacy laws.

Types of credit information we may collect, use or disclose

The categories of credit and credit eligibility information that we may collect, hold, use or disclose include: • identifying information relating to you; • information requests to credit reporting bodies; • details of credit applications and credit arrangements; • information relating to defaults, overdue payments or serious credit infringements, including any subsequent payments or arrangements; • bankruptcy information, credit-related court proceedings and other publicly available credit information; and • credit scores, risk assessments and assessments of credit worthiness.

Accessing and correcting your personal information

You may request access to personal information, including credit-related information, that we hold about you at any time by contacting us using the details set out below. Access will be provided in accordance with the Privacy Act 1988 (Cth), subject to any applicable exemptions. In limited circumstances, an administration fee may apply, and we will notify you in advance if this is the case. If you believe that any personal information we hold about you is inaccurate, incomplete or out of date, you may request that we correct it. Where we agree that a correction is required, we will update the information accordingly. If we do not agree, you may ask us to record your correction request with the relevant information. You may also request that we notify any third parties to whom incorrect information was previously disclosed. Where practicable, we will assist with this request, or advise you if we are unable to do so. Where available, you may also be able to view and update certain personal information directly through your LIVA Telecom online account portal.

Complaints handling

If you wish to make a complaint about our handling of credit-related information or privacy matters, you may contact us using the details above. We will acknowledge receipt of your complaint promptly and within 7 days where it relates to credit reporting and aim to investigate and respond within 30 days, or sooner if required by law. If additional time is needed, we will explain the reason for the delay and provide an updated timeframe. If we are unable to resolve your complaint to your satisfaction, you may contact the Office of the Australian Information Commissioner (OAIC): Office of the Australian Information Commissioner GPO Box 5218 Sydney NSW 2001 Phone: 1300 363 992 Website: www.oaic.gov.au Email: enquiries@oaic.gov.au For complaints relating to telecommunications services or telecommunications data handling, you may also contact the Telecommunications Industry Ombudsman (TIO).

Changes to this policy

We may update this Credit Reporting Policy from time to time to reflect changes in legal requirements or our business practices. The most current version will always be available on our website. We encourage you to review this policy periodically. Where changes are significant, we will take reasonable steps to notify you, including by website notice or email.

Questions or complaints?

LIVA Telecom | Level 49, 8 Parramatta Square, Parramatta NSW 2150 | ABN: 32 621 849 518