Seglo Phone Privacy Policy

1. Who we are

SEGLO PTY LTD (ABN 65 694 776 488) is an Australian company. In this Privacy Policy, "Seglo", "we", "us" and "our" refers to Seglo in its operation of Seglo Phone, a software platform through which we provide the user interface, application logic and cloud hosting, together with a telephony service we acquire from a licensed Australian carriage service provider and resupply to the Client.

This Privacy Policy applies to the Seglo Phone product only. Seglo's appointment and business-management platform is covered by a separate privacy policy.

We comply with the Privacy Act 1988 (Cth) and the Australian Privacy Principles ("APPs").

2. Our carrier, and what we share with them

The underlying carriage of calls, SMS and MMS is supplied to us by Crazytel (CRAZY TELECOMMUNICATIONS PTY LTD, ABN 66 629 066 771) (the "Carrier"), and resupplied by us to the Client. The Carrier collects and handles information under its own privacy policy, over which Seglo has no control.

To provision and operate a service we disclose to the Carrier the information necessary to do so, including the Client's business name, the name of the person responsible for the service, the service address, and the telephone numbers allocated. Call and message traffic necessarily transits the Carrier's network.

We may change carriers. If we do, we will update this Policy under clause 13.

2A. The Integrated Public Number Database (IPND)

Where we allocate a telephone number to a Client, Australian law requires the Client's name and service address to be recorded in the Integrated Public Number Database (IPND) and kept up to date. The IPND is a national database operated under the Telecommunications Act 1997 (Cth). We provide this information through the Carrier.

Information in the IPND is available to emergency service organisations, law enforcement and national security agencies, approved research and public-safety users, and — for listed numbers only — directory and directory-assistance operators.

A Client may choose whether its number is listed or unlisted in public directories. Unless a Client tells us otherwise, we record its number as unlisted. An unlisted number is still recorded in the IPND and is still available to emergency and law-enforcement users; the unlisted election affects public directory listing only.

Providing a service address is a condition of being allocated a number. If a Client does not wish its address recorded in the IPND, we cannot supply it with a number.

3. Information we collect

• Account information: name, business name, email, phone number, login credentials.
• Service address information: the physical address at which the service is used and the name of the person responsible for it, collected to meet our IPND obligations (clause 2A).
• Device and technical data: device identifiers, operating system, app version, IP address, push notification tokens, diagnostic and crash logs.
• Communications metadata: numbers dialled or messaged, direction, timestamps, duration, and volume/frequency of communications.
• Communications content: the content of SMS, MMS and messages, and — where the Client enables it — call recordings and voicemail, processed to transmit, deliver and store the Client's communications (not analysed for monitoring — see clause 5).
• Usage data: how the Client and its Authorised Users interact with the Platform.

4. How we use information

• To provide, operate and maintain the Platform.
• For security, fraud prevention, and abuse detection.
• To monitor and enforce our Fair Use Policy through metadata and traffic analysis (message volume, frequency, velocity and usage patterns) — see clause 5.
• To provide support and respond to enquiries.
• To comply with our legal obligations and lawful requests.
• To improve the reliability and performance of the Platform.

5. Encryption, and monitoring by metadata only

Communications data is encrypted in transit and encrypted at rest.

We do not monitor, read or intercept the content of communications. Our automated compliance systems operate on metadata and traffic data only — usage patterns, message velocity, volume, frequency and similar signals — solely for network security, platform stability, and enforcing our Fair Use Policy (including spam and abuse prevention). Message content is processed only to the extent technically necessary to transmit, deliver and store communications, or where strictly necessary to provide support or comply with a lawful request.

6. Disclosure to third parties

We disclose personal information to:

• The Carrier (clause 2), to provision, operate, fault-find and bill the telephony service, and to meet regulatory obligations including the IPND.
• The Integrated Public Number Database (clause 2A), and through it to the users described in that clause.
• Infrastructure and hosting providers who host and operate the Platform on our behalf.
• Professional advisers, and regulatory or law-enforcement bodies, where required or authorised by law.

We do not sell personal information. We require our service providers to protect personal information consistently with this Policy and the APPs.

7. Overseas disclosure

Our primary infrastructure is hosted in Australia (AWS ap-southeast-2). Some service providers may store or process data outside Australia — likely locations include Singapore and the United States. Where we disclose personal information overseas, we take reasonable steps under APP 8 to ensure the recipient handles it consistently with the APPs, including contractual safeguards.

8. Data retention

We retain personal information only for as long as necessary to provide the Platform, meet our legal, tax and regulatory obligations, resolve disputes and enforce our agreements. Where the Client controls Client Content, retention is also subject to the Client's instructions and the applicable Terms of Service.

9. Roles and responsibilities

As between Seglo and the Client, the Client is responsible for the lawful collection, use and disclosure of the communications data it routes through the Platform, including obtaining any consents required from its own customers and message recipients.

10. Access, correction and complaints

You may request access to, or correction of, the personal information we hold about you, and you may make a privacy complaint, by contacting us at support@seglo.ai. Complaints that are not about privacy are handled under our Complaints Handling Policy. We will respond within a reasonable period. If you are not satisfied with our response, you may contact the Office of the Australian Information Commissioner (OAIC) at oaic.gov.au.

11. Security

We take reasonable technical and organisational measures to protect personal information from misuse, interference, loss, and unauthorised access, modification or disclosure. No system is completely secure, and we cannot guarantee absolute security.

If we become aware of an eligible data breach that is likely to result in serious harm, we will assess, contain and notify affected individuals and the Office of the Australian Information Commissioner (OAIC) as required by Part IIIC of the Privacy Act 1988 (Cth) (the Notifiable Data Breaches scheme), and will notify the Client without undue delay of any breach affecting Client Content so the Client can meet its own obligations.

12. Children

Seglo Phone is a business tool and is not directed at children under 16. We do not knowingly collect personal information from children under 16.

13. Changes to this Policy

We may update this Privacy Policy from time to time. The current version is always available within the Platform and at our published URL, with the effective date shown above.

14. Contact

Email	support@seglo.ai
Post	SEGLO PTY LTD (ABN 65 694 776 488), Level 1, 63-73 Ann Street, Surry Hills NSW 2010