This is the privacy policy of TPG Telecom Limited (“TPG Telecom”) and each of the brands and subsidiaries listed at the end of this policy, including but not limited to Vodafone, TPG, iiNet, AAPT, Pipe Networks, Lebara Mobile, Felix Mobile, Internode, and Kogan Mobile, (referred to as “TPG Group”, “we”, “us”, or “our” in this Privacy Policy).

Privacy Policy

Protecting your privacy is a big deal. At Kogan Mobile we are strict about how we handle personal information.

This privacy policy outlines how we collect, store, use and disclose personal information. It also confirms our obligations under the Privacy Act 1988 and the Telecommunications Act 1997.

What is your personal information?

In this privacy policy, the term ‘personal information’ has the meaning given to it in the Privacy Act. Personal information is information we collect which identifies you or could be used to identify you.

Why do we collect personal information?

We need to collect some personal details from you to provide you with our services and products. Without collecting your identifying information when you join us, we may not be able to provide you with the products and services you want. We may also need to collect additional personal information to manage your account and continue to provide you with our products and services.

What personal information do we collect?

Information about you

The information we collect about you depends on the products and services you use and whether you are a customer, job applicant or a member of the public. It may include:

• Your name, date of birth and contact details
• Your physical address or alternative addresses where we provide our services to you
• Your bank account and credit card details
• Information to prove your identity, for example your driver’s licence or another form of ID
• Information relating to your credit worthiness
• Your employment history, if you apply for a job with us
• If you are a business, company or government entity, the number of employees in your organisation
• Details of products and services we have supplied you or you have asked about
• Details needed to deliver those products and services or answer your questions
• What you tell us about the products, services or lifestyle activities you like or how you like to use our products and services
• Details about your account (including your password and username)
• Information about you that you provide us directly or indirectly when online

Information you provide to us through surveys

We may also need to collect personal information from you about authorised representatives you appoint in relation to your account. If so, you must also tell them about this Privacy Policy and ensure you have the appropriate consents from them to provide their personal information to us.

Some of the information that we collect may be sensitive information, for example, information about your health, race, ethnic origin, religious beliefs or your biometric information (e.g. for facial recognition and verification). If we need this type of information we will ask you for permission, except where otherwise allowed or required by law.

Information about how you use our products and services

We may also collect:

• Phone numbers that you call or send messages to
• Phone numbers that you receive calls and messages from
• The date, time and length of the calls and messages you send or receive with us. Also, your location at the time of these calls and messages
• Information about the level of service you receive. This may include details of network faults or events which may affect our services
• Information about your use of our services, including how you use our network, the operating system you use, our apps or online portals, call centres, webchat services and stores
• Websites you visit and online searches you do. This includes the date, time and length of your internet browsing and your location at the time. For further information, please see the section ‘How we use online identifiers’ below

How do we collect personal information?

We collect your personal information if you:

• Provide information to us in account application forms, order forms or service enquiry forms
• Provide information to us when you buy products or services from our websites
• Subscribe to newsletters, alerts or other services from us
• Take part in a competition, prize draw or survey
• Visit our websites, online stores, Facebook pages and other pages that we own and manage
• Use any of our apps or online portals
• Visit external websites and perform online searches using your device
• Visit external pages through our portals like MyVodafone, TPG MyAccount, Toolbox, My Internode, MyLebara, My Account and Frontier
• Require assistance with service provisioning or fault management
• When you contact us or we contact you. These conversations may be recorded for training, quality and business purposes
• Use your device including when this results in contact between your device and our network. This contact might tell us about you, your device, your use of our services and your location
• Apply for a position to work at any of the companies in the TPG Group

We may also collect personal information about you in accordance with our obligations under the data retention provisions of the Telecommunications (Interception and Access) Act 1979 (Cth).

Information collected from other sources

We may collect personal information from:

• Other companies in the TPG Group. For example, if you have a service with Vodafone, we may share your personal information with our other brands such as TPG or iiNet
• Credit reporting agencies, law enforcement agencies and other government entities
• Entities that provide services to us. This includes entities to which we may disclose your personal information. We explain who these entities are below in the section ‘Who can we provide your information to?’
• Your authorised representatives or legal advisors
• Publicly available sources of information, like market research providers

We may also collect information in other ways and will take all reasonable steps to let you know if we do.

Paging and Messaging services

Some entities in the TPG Group (e.g. Vodafone) offer paging and messaging services. If you call or message a customer with a messaging or paging service and you would like to leave or send a message, we will collect from you details like your name, telephone number and any details in your message. We will then send your message and those details to our customer as part of the service. We will not use or disclose your details in other ways. We will hold and manage your details as set out in this policy.

How do we use online identifiers?

We may use cookies and other online identifiers to collect information about you when you interact with our websites, applications, communications, products and services.

How we use online identifiers

• Cookies are small text files stored in your browser and mobile app. Cookies and other online identifiers help us understand how we can make our online products more relevant to you.
• We may use a persistent cookie, which is a cookie that stays linked to your browser. A persistent cookie is used to record your visits so we can recognise you if you visit our website again. It also lets us keep track of products or services you view so that, with your consent, we can send you news about them.
• We also use cookies and other online identifiers to measure traffic patterns, to see which areas of our website have been visited and to measure total transaction patterns. This helps us see how our site is used so that we can improve our online products and services. You can set your browser so your computer stops cookies or lets you know each time a website tries to set a cookie.
• We may also log your IP address. Your IP address is your computer’s electronic Internet address. We may collect your IP address to see trends, run the website, track user movements, and gather broad demographic information.

How do we use your personal information?

We may use your personal information and usage information for the purposes of:

Providing you with products and services

• Providing you with products and services
• Processing orders or applications to become a customer
• Providing you with customer and technical support

Communication and administration

• Contacting you with messages about changes to our products or services
• Verifying your identity
• Generating bills, managing your account, and carrying out debt-recovery
• Carrying out credit checks and credit reporting
• Dealing with questions, complaints and other customer care activities
• Assessing any financial hardship application made by you
• Identifying your location so we can send you emergency alerts

The communications above may be sent from entities within the TPG Group from which you do not currently purchase products and services (e.g. you may receive a bill from TPG Telecom for your iiNet services).

Marketing and communications

• Contacting you with marketing about products and services offered by any of the brands and subsidiaries in the TPG Group. This may include marketing from or related to brands and subsidiaries within the TPG Group that do not currently provide you with products or services. See below for more information about direct marketing communications

Improvement and analytics

• Understanding how you use our products and services, carrying out market analysis and research, and analysing the effectiveness of our marketing campaigns
• Developing our products and services, networks, and business processes
• Understanding how customers use our networks, analysing network use and performance, behavioural data and demographic trends
• Analysing the things that interest you, as well as where you use your device. We may use those details to provide you with services, products and information suited to your needs, interests and location
• Sharing de-identified and anonymised data with select business partners. In these cases, we use techniques such as grouping, combining and anonymising so that we do not reveal your personal information
• Training our staff

Network security and fraud

• Protecting our network and managing the use of our network, including by analysing data use, calling patterns, SMS and other uses of our network. For example, we identify peak periods of use so our network can better handle the volume at those times.
• Conducting internal investigations in relation to crime and fraud prevention, detection, recovery or prosecution.

Compliance

• Complying with. or as required or authorised by, law (including under the Telecommunications (Interception and Access) Act 1979 (Cth) and the Telecommunications Act 1997 (Cth)
• Complying with, or as required by or in accordance with, any mandatory industry code or standard registered under the Telecommunications Act 1997 (Cth)
• Performing identity checks for pre-paid public mobile telecommunications services under the Telecommunications (Service Provider-Identity Checks for Prepaid Mobile Carriage Services) Determination 2013
• Complying with requests for information issued to the TPG Group by agencies and courts that are entitled to obtain the information under Australian law

We may share personal information collected by one TPG Group entity with other entities within the TPG Group and use that information as set out above.

For other purposes, we will ask for your consent to use your personal information.

Direct marketing communications

We may send you direct marketing messages and information about:

• Products, services, discounts, competitions and special promotions offered by entities within the TPG Group that may be of interest to you
• Offers or promotions based on how you use our products and services for example your data, calling and messaging activities, location information and browsing information
• Other companies’ products and services (including offers and discounts we have arranged for our customers) we think may interest you, if you have chosen to receive this information

This marketing material may be sent by various methods, including but not limited to, telephone, post and any form of electronic message (including, but not limited to, email, SMS, MMS, push messages and video messages).

You consent to us sending you marketing material by any of those methods. Unless you opt out, you may continue to receive marketing material from us for up to 13 months from when your agreement with us ends.

At any time you may opt-out of receiving marketing material from us.  For details on the opt out process, please see the section below headed “How can you opt-out of marketing materials?”

We may give your personal information to other organisations that assist us in providing you with direct marketing. These organisations are limited to our suppliers or third parties working with or directly on behalf of the TPG Group. You can separately opt-in to receiving third-party marketing through a specific promotion.

How can you opt-out of marketing materials?

If you would rather not receive our marketing material, you may opt-out by using any of the opt-out methods noted in the marketing material. You may also contact us in the following ways:

Consumer and small business customers:

• TPG Telecom, AAPT and Pipe Networks customers: By completing this form
• Vodafone customers: Check out our support article to find out how. Or, you may contact 1555 from your mobile or call 1300 650 410 from any phone
• iiNet customers: You can opt-out of certain communications directly through Toolbox or by calling 13 22 58
• Westnet customers: You can opt-out of certain communications directly through MyAccount or by calling 1300 786 068
• Internode customers: You can opt-out of certain communications directly through My Internode, by contacting us at support@internode.com.au or by calling 13 66 33
• TPG, Adam Internet, Chariot and Soul Communications customers: You may send an email with your full name and customer ID to nomarketing@tpg.com.au. If you have more than one Customer ID, you must list each ID to ensure that the opt-out is effective for all of them
• Felix customers: Simply opt out of marketing within your felix app or email marketing@felixmobile.com.au
• Kogan mobile customers: Call 12612 from your Kogan Mobile phone or call 1300 056 426 from any other phone
• Lebara customers: Call 126122 from your Lebara phone or call 1300 126 122 from any other phone

Enterprise, government and wholesale customers: by completing this form.

Just a heads up that if you have multiple services with TPG Group, opting out of receiving direct marketing material for any one of the TPG Group brands will not withdraw your consent to receive direct marketing material from other TPG Group brands that you have a service with. If you wish to opt out of receiving direct marketing from all TPG Group brands that provide you a service, you will need to follow the opt out process for each relevant brand. 

Please be aware that even if you have opted out of receiving marketing material, we will still need to send you essential information about your account, your service or plan and other information required by law.

Who can we provide your personal information to?

We might disclose your personal information both within and outside Australia to the relevant entities below.

We take reasonable steps to make sure recipients of your personal information handle that information in accordance with the obligations set out in the Australian Privacy Act. The relevant entities are:

• Credit providers or credit reporting agencies for the purposes permitted under the Privacy Act and credit reporting legislation
• Our service providers, including the providers of network and IT services, content providers, insurance products and mailing services
• Our dealers, agents, suppliers, contractors and advisers
• Our device manufacturers and repairers
• Our providers of marketing, research, call centre and telemarketing services
• Companies in the TPG Group
• Your authorised representatives or legal advisors
• Our professional advisors including lawyers, accountants, tax advisors and auditors
• Debt collection agencies and other parties that assist with debt-recovery functions
• Law enforcement bodies to assist in their functions, courts of law or as otherwise required or authorised by law
• Emergency services (if you make an emergency call) or other service providers assisting in emergency situations
• Regulatory or government bodies to resolve customer complaints or disputes both internally and externally or to comply with any investigation by one of those bodies
• Other telco companies for the purposes of dealing with unwelcome calls and number portability issues
• To third parties for the purpose of preventing or investigating actual or suspected fraud, unlawful activity, or misconduct relating to your accounts or our services. For example, your financial institution may use a third party service to verify your location or to verify that the location where your mobile service is being used is near the place of a recent or pending financial transaction and/or to check whether or not your mobile service’s SIM has recently been swapped

We are required by law to disclose personal information about you to the operator of the Integrated Public Number Database (IPND). Information we may be required to disclose includes, your name, residential address, telephone number and email address. 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. IPND information may also be used for research with approval by the ACMA.

Do we disclose your personal information outside Australia?

We may disclose personal information to third party suppliers and service providers located overseas for some of the purposes listed above.

We may store or sometimes disclose personal information to entities outside Australia. Some of these entities are:

• Companies within the Vodafone Group Plc group of companies located in the UK, Germany, Italy, Egypt and India
• TPG Group’s data hosting and other service providers located in Fiji, Canada, countries within the European Union, United Kingdom, India, Japan, New Zealand, the Philippines, Singapore, Malaysia, South Africa, Indonesia, and the USA

How do we hold and protect your personal information?

The security of your personal information is important to us. We take all reasonable steps to securely store your personal information in a way that is protected from unauthorised use, access, modification or disclosure. This includes both physical and electronic security measures.

We sometimes use service providers to process, manage and store personal information. Where we do, we require those service providers to comply with strict requirements about the use and protection of your details.

We also ensure that your personal information can only be seen and used by staff who need it to do their jobs. Our staff securely destroy any printed documents containing your details.

We run checks of our systems, service providers and staff to make sure that your personal information is held and used properly. We give our staff special training about privacy and the proper use of your details.

How can you protect your account from unauthorised access?

Anyone who knows your account security information (such as PIN or online username and password) can access your account. You must keep this information secure. You may choose to nominate authorised persons to manage your account, and they will need to provide their own personal and security information. We accept no responsibility for information we disclose to parties who know your account security information.

How accurate is the personal information we hold about you?

We take all reasonable measures to make sure 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 make sure we have your most current and accurate details, please let us know when your information changes (e.g. if you change your name or address).

Can you access and correct the personal information we hold about you?

Yes, but there may be times where we cannot grant you access to the personal information we hold. For example, we may not grant access to information if it could interfere with the privacy of others or if it would result in a breach of confidentiality. If that happens, we will give you written reasons for any refusal.

You can access and correct some of the personal information (such as contact details) that we hold about you by securely logging in to your account with us. To request your personal information complete this form and return it to the address provided in the form. We may charge reasonable administrative costs for responding to privacy information requests, however we will not charge you for simply making the request or for making any corrections to your personal information.

If you think your personal information is not current or may not be accurate or complete, you should ask for it to be updated. If we do not agree that there are grounds to change it, we will add a note to the personal information stating that you disagree.

How can you report a breach of your privacy?

If you believe your privacy has been compromised, please fill in this Privacy Breach form and return it to the address provided. A member of our Privacy team will get in touch within 5 business days.

If you believe that we have not dealt with your concerns you may lodge a complaint with the Australian Privacy Commissioner or the Telecommunications Industry Ombudsman.

Australian Privacy Commissioner: GPO Box 5218 Sydney NSW 2001. Telephone: 1300 363 992. Email: enquiries@oaic.gov.au (preferred)

Telecommunications Industry Ombudsman: PO Box 276, Collins Street West, VIC 8007. Telephone: 1800 062 058. Website: https://www.tio.com.au/making-a-complaint

Contact us

If you have any questions about your privacy, or if you would like a printed copy of this privacy policy (free of charge), please contact us by:

• emailing us at privacy@tpgtelecom.com.au
• sending us a letter to TPG Telecom Customer Care, PO Box 1113, North Sydney NSW 2060
• if you are an enterprise, government or wholesale customer, by contacting your designated account manager, if you have one
• calling Customer Care:

TPG Telecom Limited Privacy Policy (effective 1 May 2023)

This Privacy Policy applies to the TPG Group, including but not limited to the following entities:

TPG Telecom Limited (formerly Vodafone Hutchison Australia Pty Limited) ABN 76 096 304 620.

Vodafone Australia Pty Limited ABN 86 056 161 043

Vodafone Pty Limited ABN 76 062 954 554

Vodafone Network Pty Limited ABN 31 081 918 461

iiNet Limited ABN 48 068 628 937

Chime Communications Pty Ltd ABN 90 073 119 285

Agile Pty Ltd ABN 36 080 855 321

TransACT Victoria Communications Pty Ltd ACN 063 024 475

Adam Internet Pty Ltd ABN 22 055 495 853

TransACT Capital Communications Pty Limited ABN 23 093 966 888

Westnet Pty Ltd ABN 50 086 416 908

AAPT Limited ACN 052 082 416

Internode Pty Ltd ABN 82 052 008 581

Pipe Networks Pty Limited ABN 21 099 104 122

TPG Corporation Limited ABN 46 093 058 069

TPG Internet Pty Ltd ABN 15 068 383 737

TPG Network Pty Ltd ABN 85 003 064 328

Chariot Pty Ltd ABN 31 088 377 860

SPTCom Pty Ltd ABN 75 111 578 897

Soul Communications ABN 99 085 089 970

PowerTel Limited ACN 001 760 103

Request Broadband Pty Ltd ABN 89 091 530 586

Connect Internet Solutions Pty Ltd ABN 61 054 112 435

Soul Pattison Telecommunications Pty Ltd ABN 79 001 726 192

Soul Communications Pty Ltd ABN 99 085 089 970

Orchid Cybertech Services Inc (in the Philippines)

Registered address: Level 1, 177 Pacific Highway, North Sydney NSW 2060