Personal Information Management Policy

Upwire (“we”, “our” or “us”) recognises the importance of protecting the privacy and the rights of individuals in relation to their personal information. This includes existing and prospective
customers of our clients, potential and existing employees and contractors whom Upwire collects personal information from or is provided with such information from our clients. We at Upwire, know you care about how your personal information is used and shared, and we take your
privacy seriously.

This document is our privacy policy and it tells you how we collect and manage your personal information. We manage personal information as an organisation under the Australian Privacy Principles. This document has been written to accommodate changes to the Privacy Act 1988
(Privacy Act) introduced via the Privacy Amendment (Enhancing Privacy Protection) Act 2012 and we comply with all of the requirements of the Privacy Act in respect of the collection, use, management, disclosure, quality, security, access and correction of your personal information.

In this policy, personal information means information or an opinion (including information or an opinion forming part of a database), whether true or not, and whether recorded in a material form or not, about an individual whose identity is apparent, or can reasonably be ascertained,
from the information or opinion (source: Privacy Act 1988). http://www.oaic.gov.au/privacy/privacy-act/the-privacy-act

How we collect your information

Our approach to collecting personal information is, wherever reasonably possible, to collect information directly from you. Where practical, the purpose for which we collect personal information and the consequences of not providing it, where practical, will be made clear at the
time of collection.

We receive and store any information that you provide to us. For example, through the registration process and/or through your account settings, making calls, requests for support and otherwise using the services, we may collect personal information such as your name,
email address, location, phone number and payment information. Certain information may be required to register with us or to take advantage of some of our features.

In connection with your use of the services, we may also collect information created or provided by you, or that we otherwise receive, in connection therewith. For example, if you enable users to send SMS messages through the services, we will collect and maintain the call
data (e.g. receipts, phone numbers, size, time of transmission, confirmations, etc.) and other message transmission and conversion data, which may include personal information.

Use or disclosure of personal information

Upwire does not collect or compile personally identifying information for dissemination or sale to outside parties for consumer marketing purposes, or host mailings on behalf of third parties. Upwire will not use or disclose your personal information without your consent, except:

  • where required or authorised by law;
  • to implement the terms of any agreement we have with you;
  • to assist the lawful investigation of a law enforcement authority;
  • to protect the rights, property or personal safety of another Upwire customer, any member of the public or Upwire;
  • where the assets and operations of the business are transferred to another party as a going concern; or
  • as otherwise described in this Privacy Policy.

We may exchange your personal information with our related bodies corporate, your representatives and with our service providers that assist us with archival, auditing, accounting, customer contact, legal, business consulting, banking, payment, delivery, data
processing, data analysis, information broking, research, investigation, website or technology services.

In certain situations, businesses that are involved with the services may provide products or services to you through or in connection with the services (either alone or jointly with us). For example, in sending or receiving messages and other information through the services, we
may route your in-bound and outbound communications and related information through third party mobile networks and aggregators, and they may transmit data to their respective service providers in the transmission channels. We will share your communications and related
information (which may include Personal Information) with such business only to the extent that it is related to such transaction or service.

Security of personal information

Upwire has implemented generally accepted standards of technology and operational security in order to protect personally identifiable information from loss, misuse, alteration or destruction. All Upwire employees follow a network-wide security policy. Only authorised Upwire personnel are provided access to personally identifiable information and these employees have agreed to ensure confidentiality of this information.

Users of our messaging platform must realise that although Upwire employs high levels of security, no data transmission over the internet can be 100% safe. Furthermore, users must be aware that sending messages with Upwire will have a similar level of security and reliability as
that of Mobile Phone Networks.

Contacting us

If you have any questions about this privacy policy, any concerns or a complaint regarding the treatment of your privacy or a possible breach of your privacy, please contact our Privacy Officer using the details set out below.

We will treat your requests or complaints confidentially. Our representative will contact you within a reasonable time after receipt of your complaint to discuss your concerns and outline options regarding how they may be resolved.

Please contact our Privacy Officer at:
Attn: Privacy Officer
Upwire
Suite 101, 6-8 Clarke Street
Crows Nest NSW 2065
Australia
Phone: 1300 797 670