Privacy Policy

This Privacy Policy describes how we collect, use and handle Personal Information both about our Customers and on behalf of our Customers when providing our services. Delacon understands and appreciates that privacy is a major concern for all our Customers, as it is for Delacon. As part of providing our services, Delacon is committed to:

• ensuring we comply with the Data Protection Law applying to us; and
• dealing effectively with your enquiries and complaints concerning our compliance with privacy laws, regulations and codes.

This Policy does not apply to any activities that come with the operation of the EU General Data Protection Regulation. Customers and other individuals who are in the EU, should refer to our EU Privacy Policy.
Please read this policy carefully to understand how we will treat your Personal Information.  If you have any questions, please contact us using the details provided below.

What information we collect and why

Our Services

Delacon provides call analytics services to Customers, which include small, medium and large businesses. Our services (collectively, “Call Analytic Services”) include:

• helping Customers track and evaluate the performance of their advertising, by measuring and analysing telephone calls generated by online, mobile and offline ad campaigns;
• helping Customers drive sales leads and/or other desired outcomes through targeted ad campaigns, and providing related analytics services; and
• providing Customers with call recording and other data services for their inbound calls.

As part of providing these Call Analytic Services, we collect Personal Information.

Customer Information

The Personal Information we collect about our Customers is called ‘Customer Information.’

We collect Customer Information in the following circumstances:

Opening a customer account: If you wish to become a customer, or if you are acting on behalf of a customer or prospective customer of Delacon, we require your name, residential and email addresses, and telephone number.

We may also ask for:

• copies of documents confirming your identity, such as your: driver’s licence, passport, birth certificate and/or utility bills; and
• other information, such as your credit card or bank account details (which may include a photocopy or scanned image of the front and back of your credit card). That information may be used to set up a direct debit, for example.

Enquiries, blogs and on-line interaction: If you send us an enquiry through our Site, we may collect your name, phone number and email address. We may also collect your responses to our correspondence and to any promotions running on the Site.

Our Site may include publicly accessible blogs or community forums. Please note that any information you provide in these public areas may be read, collected, and used by other internet users.

Credit information: Sometimes we provide credit to Customers. To do that, we may collect and hold credit information and credit eligibility information about those Customers. We may combine credit reporting information from a credit reporting body with our own information about your credit worthiness, and we may use that combined information to determine whether to offer credit to you.

Call recordings: Calls to Delacon offices and service centres may be recorded for verification and quality assurance purposes.

Third-party analytics services. We may use automated devices and third-party applications, such as Google Analytics and Marketo, to evaluate the usage of our Site and the effectiveness of our email marketing. We and our third-party providers may also use other analytic technologies (e.g. clear GIFs) to evaluate and improve our Site, its performance and our users’ experience. To perform their services, the third party service providers may use cookies and other tracking technologies. Those third parties may also combine the information that we provide about you with other information that they have collected.

Tracking technologies: Delacon and our partners and suppliers of analytics and other services may use tracking technologies such as web beacons, e-tags, and Javascripts to analyze trends, administer our Site, track users’ movements around our Site, and obtain demographic information about our user base. Reports generated from the use of these technologies may be provided to us, containing data grouped on an individual and/ or an aggregated basis.

We also collect information about suppliers of goods or services to Delacon, including name, position, business and email addresses; and telephone numbers.  This information will be treated as ‘Customer Information.’

Individual Information

The information we receive from our Customers about their current or prospective customers or that we collect on behalf of our Customers, generated by our Call Analytics Services, is called ‘Individual Information.’

We process Individual Information in the following circumstances:

Cookies: We collect information from cookies used to provide our service which may include:

• your IP address,
• information on your browser software,
• page(s) visited (including the time and date of visit), and
• keyword searches conducted.

Online usage and analytics data: We collect online usage and analytics data from Customer and third-party websites (sometimes using cookies and pixels). We may link that information with other online information we collect from third parties (including cross-device information), as well as information we collect offline.   This information includes:

• IP address,
• date and time stamp,
• device ID,
• cookie ID,
• URL and referring URL,
• browser type,
• advertising identifiers,
• header information, and
• other information about the ad or web page or mobile application the user was viewing.

We also collect data on calls placed to our Customers, such as caller ID information, and may link that information to:

• the online activity we have collected,
• information collected from third parties (which may include cross-device information), and
• information we have collected offline.

We may also record calls placed to our Customers, at the Customer’s election.

We do not collect sensitive information as part of providing Call Analytic Services.

What we use Personal Information for

We collect and use the Personal Information described above in order to provide you with the Services in a reliable and secure manner and in particular:

• to identify you;
• to provide our Call Analytic Services, and manage, administer, and control the quality of, those services;
• to market our products and services to you, and to enable selected third-party partners to market products and services to you;
• to do research and analysis related to our services, and to develop and improve our services;
• to assist with your enquiries or complaints;
• to protect our rights and property and to comply with our legal obligations; and
• any other purpose required or permitted by law.

Marketing and opting out

We may use and disclose your Personal Information for marketing purposes, including to:

• identify your behaviours, habits and preferences; and
• enable different members of the Delacon Group and selected third party partners to send you product and service information directly.

You can object to or withdraw your consent from future marketing communications from us at any time by:

• Using the ‘unsubscribe’ link in any email communication; or
• Contacting us by email at privacy@delacon.io.

You may withdraw your consent to receiving third party marketing material at any time. Please follow the instructions in the advertising material or on that party’s website, or email: privacy@delacon.io.

Cookies and Adwords

Cookies

Delacon and our service providers may use cookies (persistent or single session) and other tracking technologies (described below) to provide Call Analytics Services and to obtain about to the use of our Site.

We do not use cookies to retrieve information that was not originally sent by us to you in a cookie.

You may choose to refuse cookies but, if you do so, some of the functionality of our site and of our Customers’ sites may no longer be available to you.

For more information about cookies, including further details as to what they are and how to refuse them please see our Cookies Policy.

For more general information about cookies, please visit: http://www.aboutcookies.org/

Google Ads settings

To help manage their advertising and websites, our Customers may use our Call Analytics Services together with Google products such as AdWords, Google Analytics, and DoubleClick-branded services. For information about using Google Ads Settings to manage the Google ads you see, and opting out of Google Ads Personalization, please visit: https://www.google.com/policies/technologies/ads/

Third party sites

Our Site may contain links to third-party sites and social media features (for example, Facebook and Twitter buttons and widgets). Social media features are either hosted by a third party or hosted directly on our Site. We have no control over those third-party sites, and we are not responsible or liable for their content or the privacy practices applying to them.

For information about those companies’ privacy practices and how they may use your Personal Information, please visit the company websites.

For information about how to opt out of having your information collected in mobile applications, please visit: https://www.ghostery.com/support/global-opt-out/.

Access and correction

Individual Information

In supplying our Call Analytic Services, we are providing information collection services to our Customers, and do not have a direct relationship with the individuals whose information we process.

If you are an individual (not a Customer) and wish to access or seek correction or deletion of Individual Information processed by us, or otherwise exercise your rights in regard to your Personal Information, you should direct your query to the Customer concerned (who controls the data). In particular, if you are an individual who no longer wishes to be contacted by one of our Customers, please contact that business directly.

We will assist Customers in ensuring the fulfilment of Customers’ obligations to respond to requests for exercising individual rights, including the right to access or correct Individual Information.

Customer Information

Quality of information

We will take reasonable steps to ensure the Personal Information we hold about you is accurate, up-to-date and complete.

Please let us know if there is a change to any of the Customer Information you have given to us.

Access to Customer Information

Customers can access the Customer Information Delacon holds about them.

Your Personal Information will usually be available within 30 days of your request (subject to allowable exemptions). We will let you know if additional time is required.

Rectifying Customer Information

You have a right to ask us to correct any inaccurate Customer Information we hold about you. We will take reasonable steps to correct your Personal Information to ensure it is accurate, up-to-date, complete, relevant and not misleading.

Exercising Rights

You can exercise any of these rights by contacting us using the contact details provided below. We may require evidence of your identity when processing your request for access to or to rectify your Personal Information.

Data Sharing and International Transfers

We may share your Personal Information with the following recipients:

• Our contracted service providers which provide services such as IT and system administration and hosting, credit card processing, research and analytics, marketing, customer support and data enrichment;
• With third–party social networks, advertising networks and websites, which usually act as separate controllers, so that we can market and advertise on third party platforms and websites;
• Our third party partners who may contact you regarding their products or services;
• In individual cases, withy professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services;

Any Personal Information or other information you choose to submit in communities, forums, blogs, or chat rooms on our websites may be read, collected, and/or used by others who visit these forums, depending on your account settings.

We may also disclose your Personal Information:

• to regulators and law enforcement agencies and other relevant government authorities and agencies, where legally required; and
• as otherwise required by law (e.g. in connection with subpoenas, search warrants, court orders or other legal processes).

Sharing within the Delacon Group

Companies in the Delacon Group may share or grant access to Personal Information with other companies in the group (i.e. subsidiary or affiliate companies). This is on a need-to-know basis, and where necessary to fulfil a request you have submitted via our websites, or for customer support, marketing, technical operations and account management purposes.

Change in ownership

If the ownership of the Delacon Group or any part of it is transferred (e.g. as the result of a corporate merger, or bankruptcy), or there is a sale of assets, then some or all the Personal Information and non-Personal Information we hold may be transferred to the new owner.

We will notify Customers (for example, via a message to the email associated with your account) of any such transfer or sale and outline your choices in the event,

Cross Border Disclosures

Delacon may disclose Personal Information to a member of the Delacon Group or Sub-processors in other locations around the world, as necessary to provide the Services. The countries to which we may transfer Personal Information include the United States, the United Kingdom, New Zealand, Singapore, Japan, India, Hong Kong and Malaysia.

Making Complaints

If you have a question or concern about how we have handled your Personal Information, please let us know so we can address it, by contacting us using any of the details below.

We will aim to respond to all requests, complaints and other contracts within a reasonable time, usually 30 days. Delacon takes all privacy complaints seriously and our Privacy Officer aims to efficiently resolve any issue arising from a complaint.

Security

Security measures by Delacon

Delacon will implement and maintain appropriate technical and organizational security measures to protect against Personal Information Breaches and to preserve the security and confidentiality of Personal Information processed by Delacon. Delacon may update or modify the Security Measures from time to time provided that such updates and modifications do not result in the degradation of the overall security of the Services purchased by the Customer.

Notification of Data Breach

In accordance with its obligations under Data Protection Laws, Delacon will inform the competent regulatory authority and the Data Subject(s) in the event of a Personal Information Data Breach affecting Customer Information.

Upon becoming aware of a Personal Information Data Breach affecting Individual Information, Delacon will notify Customer without undue delay and will provide all information relating to the Data Breach as reasonably requested by Customer.

Delacon will use reasonable endeavours to assist Customer in mitigating the adverse effects of any Personal Information Data Breach.

Other provisions

Scope

This Privacy Policy applies to Delacon Pty Limited (ABN 42 074 596 553) and its subsidiary and affiliate companies (collectively “Delacon”, “we”, “us”, “our” and “Delacon Group”).

It applies to the activities of Delacon to the extent they fall outside the operation of the GDPR.

Definitions

In this policy:

Customer includes all users of any of our services, any prospective customers, suppliers and other third parties who we may deal with, individuals who may contact us by phone or email and other visitors to our Site.

Customer Suppliers means an entity the Customer has engaged, selected or nominated as an integration partner.

Data Protection Law means the Privacy Act 1988 (Cth).

GDPR means Regulation 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data (General Data Protection Regulation).

Personal Information has the same meaning as defined in the Data Protection Law.

Personal Information Data Breach has the same meaning as ‘eligible data breach’ in the Data Protection Law.

Sensitive Data has the meaning given to it in the Data Protection Law.

Site means our website www.delacon.io and our other websites.

Sub-processor means any third party entity engaged by Delacon to processes Personal Information for Call Analytics Services but does not include Processors when acting in their capacity as Customer Suppliers.

Access to Policy

Our Privacy Policy is available on our websites, or you can request a copy in a different format (e.g. a hard copy or email attachment) by emailing privacy@delacon.io or telephoning +61 2 8019 0200.

If you have any queries about Delacon’s privacy practices, please contact our Privacy Officer by emailing privacy@delacon.io or telephoning +61 2 8019 0200.

Changes to our Privacy Policy

We will review this Privacy Policy from time to time, and we reserve the right to modify or update it at any time.

You acknowledge that we may make changes to this Privacy Policy. Changes to this Privacy Policy will come into effect immediately when uploaded to our Site or Delacon’s iOS or Android apps. If you continue using our products or services after changes to this Privacy Policy are uploaded, you will be taken to have accepted those changes.

Policy last updated: March 2025