Updated: May 19, 2020
Chatti treats the handling of your personal information very seriously. To that end, Chatti has systems and procedures in place to protect your privacy in relation to the handling of your personal information.
Chatti abides by the National Privacy Principles I Australia, which provide a scheme in relation to the collection, disclosure, use and storage of personal information. Chatti's objective is to handle information responsibly and provide you with some control over the way information about you is handled.
Who we are
Chatti is a technology partner of Vonage. Chatti in partnership with its technology partners are a global provider of cloud communications. We offer a complete and fully configured unified communications solution for the delivery of end-to-end communications via voice, video, text, mobile applications, and collaboration tools. Through programmable modules delivered via APIs and SDKs, we enable our customers to incorporate these services into their own applications to serve their own customers.
Collection of Personal Information
Personal information is information or opinion from which an individual's identity may be ascertained. The nature of personal information collected by Chatti generally comprises an individual's name and contact details (including address, phone, fax and e-mail). Such personal information is collected for the purposes of arranging, conducting and promoting Chatti's business activities.
Chatti does not collect personal information unless it is necessary for Chatti to perform one or more of its functions and business activities. On occasion, some of this personal information may be sensitive and Chatti will only collect it with your consent or when required to by law.
Chatti will destroy personal information when it is no longer required for such functions and business activities.
Chatti will generally collect personal information from you directly. For example, Chatti may collect personal information via telephone or letter, or when you attend a function or event, provide a resume or enter an agreement.
Additional information we collect
We collect your information in the following ways:
• , your calls may be recorded and/or monitored for quality assurance and training purposes.
• Information we collect automatically when you visit our websites. We and our third-party partners, such as our advertising and analytics partners, collect information about your visits to our websites and your interactions with our ads or content, together with information such as your IP address, cookies, and other tracking technologies (e.g., web beacons, device identifiers, and pixels). For more information, please see our Cookies and Tracking Notice, which includes information on how to control or opt out of these cookies and tracking technologies.
• Information we get from third parties. Third party sources of information include:
o Third party services and social media. If you create an account or access our services through your account with a third-party service, such as Facebook, Google, LinkedIn, GitHub or Twitter, or use a social media feature through our services, certain personal data from those third-party social media services may be shared with us, such as your interests, “likes,” and friends list. We may use this information, for example, to personalize your Chatti experiences and marketing communications, to enhance our services, and to better serve you. You can control this data sharing via options in your social media accounts. We may also collect information from third party services that are integrated with our services, such as third-party CRMs or other applications that you authorize our services to connect with.
o Credit agencies. We may obtain your credit information from third party reporting agencies in order to control our own credit risk in onboarding new customers.
o Information about our customers’ users. Our customers and other third parties may also provide us with personal information about our customers’ users and others. For example, we may receive personal information and other information from our customers, message senders, mobile network operators, databases with information relevant to mobile telephone numbers submitted to our services, and other third parties. This information may include, without limitation, telephone numbers, telephone numbers’ validity, type (e.g., mobile, landline, etc.), corresponding device status (e.g., whether or not it is currently available for messaging), roaming status, carrier, country of location, and whether or not the number has been ported and is used to help us provide our services.
o Information collected in connection with your use of services delivered via our platform. We and our service providers may collect information in connection with your use of communications services delivered via our platform.
o Communications usage information. This includes information about your communications delivered via our platform such as the time and duration of usage, source and destination identifiers, completion status, location, IP address, and amount of usage.
o Communications content. To enable you to send and receive communications via our platform, we need to be able to handle the content of the messages, calls, and other communications channels used by you. This also includes, for example, voicemails and call recordings recorded via our services.
Use & Disclosure of Personal Information
Personal information provided to Chatti may be shared with related companies within Chatti, where it will be kept strictly confidential and will only be disclosed on a need to know basis.
Chatti will use and disclose your personal information for the purpose for which the personal information was initially collected.
Chatti may also use that personal information for a purpose related to the initial purpose of collection if that other purpose would be within your reasonable expectations. Related purposes might include internal auditing and administration, adding your name to a contact list, guest list or invitation list or helping us to identify production and broadcast business activities or investment opportunities which may be of benefit or interest to you.
Chatti will not use or disclose your personal information for any other purposes without first obtaining your express or implied consent. Chatti may however be required to disclose your personal information without your consent if the disclosure is:
· required or authorised by law;
· required in order to investigate an unlawful activity;
· required by an enforcement body for investigative activities; or
· necessary to prevent a serious and imminent threat to a person's life, health or safety, or to public health or safety.
Generally, Chatti will retain your personal information within Australia and not use or disclose it overseas. However, on some occasions the information may need to be transferred overseas in order to perform one of Chatti's functions or activities. In these circumstances, Chatti will either obtain your express or implied consent or will use its best endeavours to ensure that your personal information will receive protection similar to that which it would have if the information were in Australia.
As like most business organisations, Chatti relies on third party suppliers who are contracted to conduct specialised activities such as insurance broking, supply of equipment, business services, security services and travel and hospitality services. While personal information may be provided to these suppliers in order to enable them to perform the agreed tasks, Chatti will make every effort to ensure that the supplier handles the personal information in accordance with the National Privacy Principles and confidentiality principles. Chatti will require all such suppliers to provide privacy undertakings and enter confidentiality agreements.
Why we collect your information and how we use it
How we use the information we collect depends on which of our services you use, how you use them, and specific preferences you may have communicated to us. We list below the specific purposes for which we collect your information.
• To deliver our services. We use your information because it is necessary to perform our obligations in delivering our services to our customers. This includes delivering your communications to the intended end user, processing transactions with you (such as billing), authenticating you when you log into our platform, providing customer support, and operating and maintaining our services. We also need your information to communicate with you about the services, including registration confirmations, purchase confirmations, expiration or renewal reminders, responding to your requests, and sending you notices, updates, security alerts, administrative messages, and other communications necessary to usage of the services.
• To carry out core activities relating to our services. To effectively deliver our services to you, we use your information to engage in important supporting activities such as:
o billing and collections, including maintenance of records in the event of a subsequent billing dispute;
o preventing fraud, violations of our acceptable use policies, and unlawful activities;
o troubleshooting, quality control, and analytics; and
o monitoring the performance of our systems and platform.
• To comply with legal requirements. Applicable laws or regulations may require our processing of your data, such as laws mandating retention of communications data.
• To protect our legitimate business interests and legal rights. Where we believe it is necessary to protect our legal rights, interests and the interests of others, we use information about you in connection with legal claims, compliance, regulatory, and audit functions, and disclosures in connection with the acquisition, merger or sale of a business.
• According to your explicit consent. If we wish to use your information for certain purposes which require consent under applicable law, we will first seek out and obtain your consent. This may include, for example, testimonials or case studies that identify you in your individual capacity.
From time to time Chatti may use your personal information to identify business activities or investment opportunities which may be of interest to you.
If you do not wish to receive direct marketing information, please let Chatti know. Chatti will take immediate steps to ensure that you do not receive any direct marketing information in future.
Personal Information Quality
Chatti's objective is to ensure that all personal information collected by us is accurate, complete and up-to-date. To assist Chatti in achieving its objective, please contact us if any of your details change. Further, if you believe that the information Chatti holds is not accurate, complete or up-to-date, please contact us in order to have the information corrected.
Personal Information Security
Chatti is committed to keeping your personal information secure, and we will take all reasonable precautions to protect your personal information from unauthorised access, loss, misuse or alteration.
Your personal information may be stored in hard copy documents, or electronically on Chatti's software or systems.
Chatti maintains physical security over its paper and electronic data stores, such as locks and security systems. Chatti also maintains computer and network security using passwords to control and restrict access to authorised staff for approved purposes. Where information is particularly sensitive, the information is overwritten and then manually deleted.
Access to Personal Information
You may request access to the personal information Chatti holds about you.
The procedure for gaining access is as follows:
· All requests for access to your personal information must be made in writing and addressed to the Privacy Officer.
· You must provide as much detail as possible regarding the business entity, department or person to whom you believe your personal information has been provided, and when. This will allow Chatti to process your request faster.
· Chatti will acknowledge your request within 14 days, and access will usually be granted within 14 days, or if it is more complicated, 30 days. Chatti will inform you if this timeframe is not achievable.
· You will be asked to verify your identity.
· A fee may apply to such access in the event that a request for access is onerous or time consuming. Such a fee will cover staff costs involved in locating and collating information, and reproduction costs.
· Depending on the circumstances, you may be forwarded the information by mail or email, or you may be required to personally inspect your records at the appropriate place.
· You will be given the opportunity to correct any personal information which is no longer accurate.
In some circumstances, Chatti may not be in a position to provide access. Such circumstances include where:
· access would create a serious threat to safety;
· providing access will have an unreasonable impact upon the privacy of other individuals;
· denying access is required or authorised by law;
· the request is frivolous;
· legal proceedings are underway;
· negotiations may be prejudiced by such access; or
· access would reveal a commercially sensitive decision making process.
Chatti denies access to your personal information, it will provide you with
reasons in writing.
European Economic Area users and our “lawful bases” for using their data
European data protection law requires organizations like us to provide a lawful basis to collect and use your information. Our lawful basis to collect and use information from our EEA users include when:
• We need it in order to provide you with the services and to carry out the core activities related to our provision of the services.
• We need to comply with a legal obligation.
• We have a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to market and promote the services and to protect our legal rights and interests.
• You give us your consent to do so for a specific purpose.
Who we share your information with and why
We may share your information as detailed below:
• Third-party service providers that help us to deliver the services and allow us to operate our businesses.
• Communications providers. As the provider of a communications platform, we share the data we collect from you with communications providers (including traditional PSTN telecommunications companies and over-the-top communications service providers) as necessary in order to provide you with the services. These are the telecommunications companies, for instance, who we need to ensure your calls, messages and other communications reach the people you want to contact.
• Business operations vendors. We work with third-party service providers to provide website and application development, hosting, maintenance, backup, storage, virtual infrastructure, payment processing, analysis and other services for us, which may require them to access or use information about you. We only work with carefully selected vendors, and we require any vendors with whom we share personal data to protect the confidentiality of such information and use it solely for the purposes for which it was shared.
• Partners. In the event that you purchase services offered by Chatti or a partner through a special marketing arrangement (for example, through a co-branded advertisement or offer, or an arrangement where we and a partner market or offer the other’s products or services), we may share your information with these third parties in connection with their services, such as to assist with billing and collections, to provide localised support, and to provide customizations. We may also share information with these third parties where you have agreed to that sharing.
• Compliance with law enforcement requests and applicable laws; enforcement of our rights. We may disclose personal data as required by applicable law, regulation, legal process or government request; to protect Chatti, our services, our customers or the public from harm or illegal activities; and to enforce our agreements, policies and service terms.
• With your explicit consent. We share information about you with third parties when you give us consent to do so. For example, we often display use cases or testimonials of satisfied customers on our public websites and require your consent to identify you in your individual capacity. If you are a business customer, and have requested this, your business name and phone number may be included in public directories.
• Sharing with senders and recipients of communications. The name on your account, or a portion thereof, and/or your phone number may be displayed to people that you make calls to and to other users of the services so that they may contact you. Depending on the service you’re using, you may be able to control what’s displayed by adjusting your settings within the mobile app or your customer account, or by contacting customer care at the address provided when you signed up for the services.
• Chatti affiliates; business transactions. We share your information with and among our corporate affiliates in order to operate and improve the services we provide to you; and we may share your information in connection with a sale, merger, liquidation, or reorganization of our business or assets.
• Credit control. We conduct credit checks on new customers in order to control the risk of non-payment. In the event of non- or late payment, we may disclose your name, address and other details to credit bureaus and agencies. They may use that information to assess your credit rating and provide that rating to other companies.
How we protect your information
Chatti has implemented administrative, physical, and technical safeguards to help protect the personal data that we transmit and maintain. However, no system or service can provide a 100% guarantee of security, especially a service that relies upon the public internet. Therefore, you acknowledge the risk that third parties may gain unauthorized access to your information. Keep your account password secret and please let us know immediately if you think your password was compromised. Remember, you are responsible for any activity under your account using your account password or other credentials.
Where we store your information and international transfers
Personal information held by Chatti is stored on and processed on computers situated in the Australia, United Kingdom, the EEA, the United States, and in other jurisdictions. We and/or our service providers also process data in some other countries for customer care, account management and service provisioning.
If you are an EEA resident, your personal data held by Chatti may be transferred to, and stored at, destinations outside the EEA that may not be subject to equivalent data protection laws, including the United States. When you sign up for service with Chatti or inquire about our services, we transfer your information to the United States and other countries as necessary to perform our agreement with you or to respond to an inquiry you make. It may also be processed by staff situated outside the EEA who work for us or for one of our suppliers.
• International transfers within Chatti and its corporate affiliates. To facilitate our global operations, we transfer information among our corporate affiliates in countries whose privacy and data protection laws may not be as robust as the laws of the countries where our customers and users are based. We utilize standard contractual clauses approved by the European Commission and rely on the European Commission’s adequacy decisions about certain countries, as applicable, for data transfers from the EEA to the United States and other countries.
How long we store your information
We store your information until it is no longer necessary to provide the services or otherwise relevant for the purposes for which it was collected. This time period may vary depending on the type of information and the services used, as detailed below. After such time, we will either delete or anonymize your information or, if this is not possible (for example, because the information has been stored in backup archives), then we will securely store your information and isolate it from any further use until deletion is possible. We may also retain aggregate information beyond this time for research purposes and to help us develop and improve our services. You cannot be identified from anonymized information retained or used for these purposes:
• Customer account information. We store your account information for as long as your account is active and a reasonable period thereafter in case you decide to re-activate the services. We also retain some of your information as necessary to comply with our legal obligations, to resolve disputes, to enforce our agreements, to support business operations, and to continue to develop and improve our services.
• Communications usage information. While you’re an active customer, we retain the communications usage information generated by your use of the services until the information is no longer necessary to provide our services, and for a reasonable time thereafter as necessary to comply with our legal obligations, to resolve disputes, to enforce our agreements, to support business operations, and to continue to develop and improve our services.
• Marketing information, cookies and web beacons. If you have elected to receive marketing e-mails from us, we retain information about your marketing preferences for a reasonable period of time from the date you last expressed interest in our services, such as when you last opened an e-mail from us or visited our websites. We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created.
How to access and control your information
• Opt out of communications. You may opt out of receiving promotional communications from us by using some or all of the following methods: the unsubscribe link within each e-mail, updating your e-mail preferences within your service account settings menu, or by contacting us as provided below to have your contact information removed from our promotional e-mail list or registration database. Even after you opt out from receiving promotional messages from us, you will continue to receive transactional messages from us regarding our services. Depending on your type of account with Chatti, you may be able to opt out of some notification messages in your account settings.
• Your rights as an EEA resident. If you are from the EEA, you may have broader or additional rights, including:
o to be provided with a copy of your personal data held by us;
o to request the rectification or erasure of your personal data held by us;
o to request that we restrict the processing of your personal data (while we verify or investigate your concerns with this information, for example);
o to object to the further processing of your personal data, including the right to object to marketing and profiling; and
o to request that your provided personal data be moved to a third party.
Where the processing of your personal data by us is based on consent, you have the right to withdraw that consent without detriment at any time by contacting us. If you do not want your personal data used by Chatti for any direct marketing purposes, or shared with third parties for their own marketing use, then you may opt out of such use or sharing by contacting us, even if you have previously consented to such use.
If you have any concerns or complaints regarding the treatment of your personal information by us, or you believe we have breached any privacy law in relation to your personal information, please contact us. We will treat any concerns or complaints confidentially. We will promptly investigate any concern or complaint that you raise with us.
You can exercise the rights listed above at any time by contacting us and if you feel that your request or concern has not been satisfactorily resolved, or if our response was not provided within a reasonable time, you may approach your local data protection authority (links here for residents of the EEA or Australia). The Information Commissioner is the supervisory authority in the United Kingdom and can provide further information about your rights and our obligations in relation to your personal data, as well as deal with any complaints that you have about our processing of your personal data.
Other important information
• Information from children. Chatti does not sell products or services for purchase by children and we do not knowingly solicit or collect personal data from children or teenagers under the age of eighteen. If you believe that a minor has disclosed personal data to Chatti, please contact us.
• Note for Chatti Integration Suite users. Chatti's use of information received from Gmail APIs will adhere to Google's Limited Use Requirements.
How to contact us
You can use the “Exercise Your Rights” button located on this page to submit a request to the Chatti Privacy Team.
5/34 Commercial Road,
Newstead, QLD, 4006
E-mail: [email protected]
Cookies and Tracking Notice
They also help us track users, conduct research, allow you to back click to earlier registration pages viewed by you and improve our content and services. For instance, we may use web beacons on our websites to access and set cookies and otherwise help us to better understand how users are moving through our websites. Information provided by the web beacon includes the computer’s IP address, the type of browser being used and the time that the web beacon was viewed. We may also use web beacons in e-mails and newsletters so that we know when such communications have been opened and to otherwise help us tailor our communications to individual users.
• When it’s strictly necessary. These cookies and other technologies enable us to recognize you when you return to our service and to maintain your web session so you can more easily navigate the subscription process or your viewing of your call details. They are also essential for you to access secure areas of our sites, for example, to use shopping baskets or make payments.
Google Tag Manager is a third-party service provider that allows us to manage website tags via an interface. Tags are small elements of code that are used, for example, to measure traffic and visitor behavior, to understand the effect of online advertising and social channels, to set up remarketing and orientation towards target groups, and to test and optimize websites. Google Tag Manager only implements tags. This means that no cookies are used and, as a result, no personal data is recorded. We list it here for completeness and to be transparent about the tools we use. If deactivation has been performed at a domain, page, event or 3rd party script level, this remains in place for all tracking tags if these are implemented with Google Tag Manager.
• To enable functionality. These cookies and similar technologies can tell us which language you prefer and what your communications preferences are. They can help you fill out forms on our sites more easily. They also enable customization of the layout and/or content of the pages on our sites.
• Social media cookies and widgets. We use social media platforms to advertise to you online and to monitor the success of our advertising (for instance by receiving reports when you click on our ads on Facebook, LinkedIn and others). We summarize the main advertising and social media partners who drop cookies below:
• DoubleClick: Google's Doubleclick re-targeting cookie lets us serve personalized advertising to you when you're browsing other websites and social media platforms. You can control advertising personalization on Google and partner websites here.
• Facebook Custom Audience: This service from Facebook enables us to display personalized ads to people on our e-mail lists when they visit Facebook. We provide personal information such as your e-mail address and phone number in encrypted form to Facebook (so they cannot be seen by anyone at Facebook) to enable Facebook to determine if you are a registered account holder with Facebook.
• Twitter advertising and remarketing: We advertise on Twitter and our advertising content will be tailored to your interests on the basis of your browsing behaviour and the pages you have consulted on this and other websites. In order to improve the relevance of our marketing content, the cookie may therefore transmit such data to Twitter, who will use it to understand your interests better including to benefit their other advertising customers. If you decide that you do not wish your browsing data to be collected, you can find comprehensive information on Twitter’s advertising policy and the steps you can take to protect your privacy here.
How to control cookies