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Privacy statement

In this Statement, "Hotkey", "us" or "we" means Hotkey Internet Services Pty Ltd and Hotkey franchisees. The reference to 'you' means the Hotkey account holder and users of that account.

Hotkey' commitment to Privacy

We are committed to the protection of customer personal information. We are subject to the requirements of the Telecommunications Act 1997, the Privacy Act 1988, the Telecommunication Industry Ombudsman Scheme and the ACIF Code of Practice. This includes our Privacy Policy, which has been designed to ensure that customer personal information is protected.

As a private sector company, we are bound by the Privacy Act. Under the Act, we can choose to develop and be bound by a Privacy Code or choose to comply with the National Privacy Principles in the Privacy Act. We have chosen to be bound by the National Privacy Principles.

Personal information held by Hotkey

We only collect personal information from you that is necessary to provide our services to you or is necessary by law. The personal information we collect about you depends on the services you request from us and the use you make of those services. Personal information held by us may include:

  •   your name, address and contact details;
  •  your date of birth;
  •  drivers licence;
  •  password;
  •  credit card details;
  •  records of communications between you and Hotkey relating
  •  to services provided by Hotkey to you;
  •  Records of e-mails sent to us by you or from you to us;
  •  billing statements;
  •  Connection logs;
  •  Call connection records;
  •  Information in relation to joining or cancelling you account with us.

Use of your personal information

We recognise that any personal information is very important to you, and that you should have a right to control the use and dissemination of that information. The primary purpose for which we use your personal information is to provide you with Internet and related services. Other purposes for which your personal information also might be used include:

  •  providing you with customer service, including investigating and resolving of complaints in relation to your services;
  •  contacting you with information concerning your service, technical issues or marketing information;
  •  connecting your services;
  •  network routing;
  •  billing;
  •  debt collection.

We may also use some of your personal information to inform you about other products and services or bundled offerings, provided by our associated entities or us. We will however provide you with a choice to opt out of our marketing activities, and will respect your request to decline to receive further direct marketing communications.

How we collect personal information

We collect your personal information in various ways, such as over the phone, over the Internet if you transact with us on-line, or when you complete an application form for one of the products or services that we offer or promote. We collect personal information directly from you at the time when you apply for Internet services. We may also collect personal information from third parties such as:

  •  Other entities that supply services to us related to the provision of Internet services provided to you.
  •  Agents who refer customers to us.

Exchange of telephone numbers between carriers and disclosure to internet and other carriage service providers

The exchange of telephone numbers between carriers is integral to the operation of telecommunications networks, to enable calls to be connected efficiently and billed to the right customer. Carriers also disclose telephone numbers to internet and other carriage service providers for lawful use to prevent fraud, for billing, better call management and to provide secure credit control. These may include unlisted telephone numbers and numbers for which a customer or other person has blocked calling line display.  Hotkey may disclose and receive such information for these purposes related to the supply of services, subject to any legal prohibitions.

Contracting out services and disclosures

The information we collect from you is strictly confidential. We will not reveal, disclose, sell, rent or pass that information on to any third parties unless they are contracted to us to keep the information confidential or are required to comply with all relevant laws including the Privacy Act 1988. Services that we contract out include service provisioning, mailing of bills and other communications to customers, debt collection, and I.T. services. We impose security and confidentiality requirements on how contractors are to use your personal information.

We may disclose personal information for the purpose specified to you at the time of collection or for another purpose if:

  •  you would reasonably expect us to disclose it for that purpose; and
  •  that purpose is related to the purpose specified to you at the time of collection.

If we should wish to disclose any of the personal information other than as set out above, we will not do so unless we have your express consent.

Exceptions to this include:

  •  where there are reasonable grounds to believe that disclosure is necessary to prevent a threat to life or health; or
  •  where we suspect that unlawful activity is or has been engaged in and uses the personal information to investigate the suspected unlawful activity; or
  •  the use or disclosure is authorised or required by law or reasonably necessary to enforce the law.

Security

We will take reasonable steps to ensure that all information we collect, use or disclose is accurate, complete, up-to-date and stored in a secure environment accessed only by authorised persons.

Access and correction of personal information

You have the right to access the personal information we hold about you. We will generally not charge you with a fee for access to your personal information, unless requests are considered unnecessarily numerous, extensive or otherwise vexatious. Also if you wish to have a copy of the personal information, charges that cover the administrative costs of providing the information to you might apply. To request access to your personal information, please contact Customer Service on 1300 655 366 or e-mail your local franchisee.

If for any reason we refuse to give you access to your personal information, we will provide you with the reasons for our decision. The circumstances in which access to personal information may be limited or denied include where giving you access:

  •  would pose a serious threat to life or health of any individual or pose an unreasonable impact on the privacy of an individual;
  •  would prejudice any negotiations or legal proceedings between you and us;
  •  would prejudice the detection and investigation of unlawful activity; or
  •  would prejudice enforcement of laws.

If you believe that we hold personal information that you consider to be inaccurate, incomplete or not up-to-date, please contact our Customer Service on 1300 366 655. In most cases we will amend any inaccurate, incomplete or not up to date information. In the event of an unresolved disagreement, either you or us may append an explanatory note to the data in question.

Privacy Complaints and Organisational Details

You can complain about breaches of your Privacy to your local Hotkey franchisee or alternatively in writing (e-mail, fax or letter) to:

Hotkey Customer Service
PO Box 631
Melbourne
Victoria 3000
Fax: 03 9923 6055
E-mail address: accounts@service.hotkey.net.au


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