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 that provides the user interface, application logic and cloud hosting

through which the Client operates its own telephony service.

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. Bring-Your-Own-SIM

Seglo Phone operates on a Bring-Your-Own-SIM basis. The underlying carriage of calls,

SMS and MMS is provided by the Client's own third-party telecommunications carrier. That

carrier collects and handles information under its own privacy policy, over which Seglo

has no control.

3. Information we collect

•Account information: name, business name, email, phone number, login credentials.

•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:

•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 [email protected]. 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

SEGLO PTY LTD (ABN 65 694 776 488) — [email protected]

Seglo Phone Privacy Policy