Privacy Policy & Confidentiality

Users

Basics

We abide by the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles (APPs). This policy explains how and why we collect, use, hold and disclose your personal information.  If you are located in an EU or EEA country or in the UK, the GDPR Addendum at the end of this policy also applies to personal information concerning you.

“We“, “us” and “our” and “Your Call” means Your-Call Pty Ltd ACN 168 117 066, trading as Your Call, and any subsidiaries of that company.

“Your Call Service” means the whistleblowing services agreed with a Your Call Client, including access to the Your Call Platform.

“Your Call Client” means an organisation that uses the Your Call Service.

“Your Call Platform” means the Your Call reporting platform, namely Rely, developed and maintained by our related company, Rely Platform Pty Ltd ACN 085 927 377 trading as Rely Platform, and provided for use as part of the Your Call Service, and includes any web-accessible components.

“Your Call Website” means the public-facing website made available at whistleblowing.com.au or any replacement domain from time to time and includes any web-accessible components.

“Your Call Website User” means a person who interacts with our Your Call Website.

“Your Call Platform User” means a person who interacts with the Your Call Platform to submit information as part of the Your Call Service.

“Your Call Service User” means a person who interacts with any components of the Your Call Service to submit information.

What is personal information?

Personal information is any information or an opinion about an identified individual or an individual who can be reasonably identified from the information or opinion. Information or an opinion may be personal information regardless of whether it is true.

Who do we disclose your personal information to, and why?

Generally, we may disclose your personal information to any Your Call Client you are associated with. However, if we tell you that we will preserve your anonymity then we will not share your name (or other information we believe will identify you) with a Your Call Client unless you consent to it, or the law requires us to. (For instance, the law might require us to disclose your name in court proceedings). Similarly, we will not share Google Analytics or other technical data about your interactions with the Your Call Platform or Your Call Website with a Your Call Client unless you consent to it, or the law requires us to. We may, however, provide Your Call Clients with aggregated statistics about use of the service that do not identify you.

We may transfer or disclose your personal information to our related companies.

We may disclose personal information to our external service providers so that they may perform services for us or on our behalf.

We may also disclose your personal information to others where:

(A) we are required or authorised by law to do so;

(B) you have expressly consented to the disclosure, or the consent may be reasonably inferred from the circumstances;

(C) the disclosure appears reasonably necessary to protect or enforce our legal rights or to protect anyone’s safety; or

(D) we are otherwise permitted to disclose the information under the Privacy Act.

If the ownership or control of all or part of our business changes, or we enter a joint venture or similar arrangement, we may transfer your personal information to the new operator (and some information may be provided if potential new operators, investors or lenders investigate our business).

What personal information do we collect and hold?

We may collect information about you and your interactions with us, for example, when you visit the Your Call Website, access the Your Call Platform and any of its web-accessible components, call us, email us, interact with any chatbots we provide, or freely submit information to us as part of the Your Call Service. The information may include, amongst others, your name, gender, contact information and employment information. We may also collect the personal information of others which you share with us as part of your usage of the Your Call Service. We recognise that your usage of the Your Call Service in the submission of information may be performed anonymously and it is not mandatory to share your personal information with us to utilise the Your Call Service.

We may collect technical information about how you access, use and interact with the Your Call Platform and Your Call Website. This information may include:

(A) the location from which you have come to the Your Call Platform or Your Call Website, the pages you have visited and other detail, including page views, bytes transferred, hyperlinks clicked and other actions you take; and

(B) technical data, which may include your IP address, the types of devices you are using to access the Your Call Website or Your Call Platform, device attributes, browser type, language, operating system and inferred location.

We use cookies and other user recognition technologies, such as web beacons (or clear gifs), on the Your Call Website and Your Call Platform. We may use persistent cookies and recognition technologies (which function even after you close your browser) and session cookies and user recognition technologies (which no longer function after you end your browsing session) to help manage the display and presentation of information on the Your Call Website and Your Call Platform. You might be able to block some of these technologies, such as cookies, by configuring your browser, but that is likely to render you unable to use the Your Call Platform and may also inhibit your use of the Your Call Website.

Some of the personal information we collect, and that may be freely submitted to us in the usage of the Your Call Service, may be sensitive in nature, such as racial or ethnic origin, religious beliefs, political opinions, trade union membership, sexual orientation or health conditions. Such information will only be processed in accordance with the primary purpose of collection.

How do we collect your personal information?

We may collect your personal information directly from you whenever you interact with us.

We may also be provided with your personal information by other individual(s) through their usage of the Your Call Service.

How do we store and hold personal information?

Your Call Service User

We store most information about you in computer systems and databases operated by us, our external service providers, or our related companies. The Your Call Platform and Your Call Website and their respective databases are located on servers in Australia.

We implement and maintain processes and security measures aimed at protecting personal information from misuse, interference or loss, and from unauthorised access, modification or disclosure.

These processes and systems include:

(A) the use of identity and access management technologies to control access to systems on which information is processed and stored;

(B) the use of technologies aimed at ensuring that the only Your Call Clients to whom personal information is available are the Your Call Clients you are associated with; and

(C) requiring all employees to comply with internal information security policies and keep information secure.

No process, system or technology is perfect however, and we cannot guarantee that these will always be effective.

Your Call Platform User

We store most information about you and your usage of the Your Call Platform in computer systems and databases made available to us by our related software company, Rely Platform Pty Ltd, located on servers provided by reputable cloud hosting services. Those servers are located in Australia. The Your Call Platform is certified as being compliant with ISO27001:2022.

Your Call Website User

We utilise the Hubspot Platform to store website visitor, contacts and customer details. Our HubSpot data is hosted in HubSpot’s Australian data centre. Some HubSpot support and ancillary functions may be performed from outside Australia by HubSpot and its sub-processors. Hubspot’s commitment to best practice security can be found here https://legal.hubspot.com/security

Your Call has security measures in place to protect the loss, misuse and alteration of information submitted via the Your Call Website and under our control.

For what purpose do we collect and use your personal information?

The primary purpose for which we collect and use your personal information is to provide the Your Call Service. For instance, we collect details of whistleblowing or compliance incidents you might have been involved in and (except to the extent we have agreed to keep certain identifying details confidential) make them available to the organisation that is our Your Call Client. We also collect and use your personal information for ancillary purposes related to your contact with us. For instance, if you are a Your Call Website User we may collect information that identifies your device or network as one that has visited our website, or if you contact us via the website or in any other way, we may keep information related to that contact.

Do we disclose personal information to overseas recipients?

The servers housing the Your Call Platform and Your Call Website are located in Australia, and our HubSpot data is hosted in HubSpot’s Australian data centre. We do not generally disclose personal information to recipients located outside Australia. Limited exceptions may arise where support or ancillary functions of our service providers are performed from outside Australia, where you consent, or where disclosure is required or authorised by law.

Do we use de-identified personal information for other purposes?

Once we have de-identified personal information so that you can no longer reasonably be identified from it, that information is outside the scope of this policy, and the restrictions in this policy don’t apply to it.

Do we use your personal information for marketing?

No, only for the purpose of contacting you in the course of forming a business relationship with you, or responding to or offering services you might be interested in from us or our related company Rely Platform Pty Ltd. (We will treat you as having consented to us sending you electronic messages for that purpose unless you tell us otherwise). We do not use your personal information for marketing of anyone else’s products or services.

Remarketing using third party ad networks

Like many businesses, we may also market our services to Your Call Website Users by using ‘remarketing’ or ‘re-engagement’ services offered by third party ad services. At the time of writing this policy, the third-party service we use for this is Google Ads. In this respect:

• Google Ads (or any similar service we use in the future) are more likely to show ads for our services on other websites and other electronic channels to Your Call Website Users, compared to the general public.
• Google Ads (or any similar service we use in the future) will deploy cookies and possibly other user recognition technologies (such as web beacons (or clear gifs)) on the Your Call Website.
• Those cookies (and possibly other user recognition technologies) will be used by Google Ads (or any similar service we use in the future) to identify you or your device as a prior visitor to the Your Call Website and serve our ads (and perhaps other ads) to you based on that.
• You can opt out of Google Ads’ use of cookies or other recognition technologies by visiting Google’s Ads Settings
• You may also be able to opt out of another service’s cookies or other recognition technologies by visiting http://www.networkadvertising.org/managing/opt_out.asp , and may be able to prevent or limit the use of some cookies and user recognition technologies via settings in your browser or elsewhere on your device.

Who else might collect information about you as you use the YOUR CALL Service or YOUR CALL PLATFORM?

Like most websites and services, the Your Call Website uses third-party technologies such as Google Analytics and the remarketing or re-engagement services mentioned above. Limited entry pages of the Your Call Platform (such as client home pages and reporting form landing pages) also use Google Analytics so that we can produce aggregated statistics about use of the service. These technologies are not used within the disclosure submission process or secure messaging areas of the Your Call Platform. Those third parties might also collect personal information.

Access to and correction of your personal information

You may access or request correction of the personal information that we hold about you by contacting us. Our contact details are set out below. There are some circumstances in which we are not required to give you access to your personal information.

There is no charge for requesting access to your personal information, but we may require you to meet our reasonable costs in providing you with access (such as photocopying costs or costs for time spent on collating large amounts of material).

Feedback/Complaints

If you have feedback or a complaint about the way in which we have handled any privacy issue, including your request for access or correction of your personal information, you should contact us. Our contact details are set out below.

We will consider your feedback or complaint and determine whether it requires further investigation. We will notify you of the outcome of this investigation and any subsequent internal investigation.

If you remain unsatisfied with the way in which we have handled a privacy issue, you may approach an independent adviser or contact the Office of the Australian Information Commissioner (www.oaic.gov.au) for guidance on alternative courses of action which may be available.

Contact details

If you have any questions, comments, requests or concerns, please contact us by email at:

[email protected]

Or by posted mail at:

Privacy Officer, Your Call

Level 2, 400 High Street, Kew, 3101.

Changes to this policy

From time to time, we may change our policy on how we handle personal information or the types of personal information which we hold. Any changes to our policy will be published on our website.

You may obtain a copy of our current policy from our website or by contacting us at the contact details above.