imei Pty Ltd (ABN 16 095 165 576) (imei, we, us, our) is committed to protecting the privacy of the people whose personal information we handle. This Privacy Policy explains how we collect, use, disclose, store and protect your personal information, and how you can access it, correct it, or make a complaint.

We handle personal information in accordance with the Privacy Act 1988 (Cth) (the Privacy Act) and the Australian Privacy Principles (APPs). The APPs govern how we collect, use, disclose, store, secure and dispose of personal information. A copy of the APPs is available from the Office of the Australian Information Commissioner (OAIC) at oaic.gov.au.

1. What is personal information?

Personal information is information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information is true or not and whether it is recorded in a material form or not.

2. The personal information we collect

Depending on how you interact with us, we may collect:

• contact and identity details – your name, postal and email address, and phone number;

• account and login details – username and authentication information for our websites and the imei 360 portal;

• service and billing information – the products and services you hold with us, device and service identifiers (such as phone numbers and SIM details), and billing and account information;

• technical and usage data – IP address, device information and usage analytics collected when you use our websites, services and the imei 360 portal; and

• records of your dealings with us – enquiries, support requests and other correspondence.

3. How we collect personal information

Where reasonable and practicable, we collect personal information directly from you – for example, when you contact us, complete a form on our website, create or use an account, or use our products, services or the imei 360 portal. In some cases we may collect it from third parties, such as your employer if you are an authorised user of a customer account, or our business partners and suppliers. Where we do, we take reasonable steps to make you aware of that collection.

4. Why we collect and use personal information

We collect, hold and use personal information to:

• provide, manage and improve our products, services and the imei 360 portal;

• set up and administer accounts, process orders and provide support;

• communicate with you, including about service and account matters;

• send you marketing and updates where you would reasonably expect this or have consented (see “Direct marketing and your choices”);

• meet our legal, regulatory and contractual obligations; and

• protect the security of our services, and prevent fraud and misuse.

We use personal information for the purpose for which it was collected, a related purpose you would reasonably expect, or another purpose with your consent or as permitted or required by law.

5. Sensitive information

We do not generally collect sensitive information (such as health information, or information about racial or ethnic origin, that is defined as sensitive under the Privacy Act). Where we need to collect it, we will do so only with your consent and where it is reasonably necessary for our functions. Please do not provide sensitive information to us unless we have asked for it.

6. Cookies, analytics and advertising

Our websites use cookies and similar technologies to help the site function, remember your preferences, measure how the site is used, and support our marketing. These include analytics and advertising technologies such as Google Analytics and our website platform (HubSpot). Some of these providers process information overseas (see “Overseas disclosure”). You can control or disable cookies through your browser settings or, where offered, our cookie controls; some parts of the site may not work as well if you do. Our site may also include social media features (such as LinkedIn and X); your use of those features is subject to the relevant provider’s privacy policy.

7. When we disclose personal information

We do not sell, rent or trade your personal information. We may disclose it:

• to service providers and suppliers who help us deliver our products, services and the portal (such as hosting, communications, analytics and support providers), under obligations of confidentiality and security;

• to our carriers and partners (including Telstra) where necessary to provide the services you have requested;

• where required or authorised by law, or where reasonably necessary to protect the rights, safety or property of imei, our customers or others; and

• with your consent.

8. Overseas disclosure

Some of our service providers store or process personal information outside Australia, including in the United States and other countries where our cloud, analytics and communications providers operate. Where we disclose personal information to an overseas recipient, we take reasonable steps to ensure it is handled consistently with the Australian Privacy Principles.

9. Security of your personal information

We protect personal information through technical and organisational controls operated under our information security management system, which is aligned with ISO/IEC 27001. These include access controls, encryption in transit and at rest, network security, logging and monitoring, supplier assurance and staff training. While no system can be guaranteed completely secure, we take reasonable steps to protect personal information from misuse, interference and loss, and from unauthorised access, modification or disclosure.

10. Data breaches

If we experience a data breach involving your personal information that is likely to result in serious harm, we will assess, contain and respond to it under our incident management process and, where the Notifiable Data Breaches scheme under the Privacy Act requires, notify you and the OAIC.

11. How long we keep personal information

We keep personal information only for as long as it is needed for the purposes described in this policy, or as required by law, in accordance with our data retention practices. When it is no longer required, we take reasonable steps to securely destroy or permanently de-identify it.

12. Accessing and correcting your personal information

You may request access to the personal information we hold about you, and ask us to correct it if it is inaccurate, out of date or incomplete. We will respond within a reasonable time and do not charge a fee for an access request, although we may need to verify your identity before we release information. To make a request, contact us using the details below.

13. Direct marketing and your choices

We may send you marketing communications where you would reasonably expect this or have consented. You can opt out at any time by using the unsubscribe option in the message, or by contacting us, and we will action your request promptly.

14. Third-party websites

Our websites and communications may contain links to third-party sites and services. We are not responsible for the privacy practices of those sites, and we encourage you to review their privacy policies before providing personal information.

15. Changes to this policy

We may update this Privacy Policy from time to time. The current version is published on our website with its effective date, and significant changes will be made clear on this page.

16. How to contact us and make a complaint

If you have a question, request or complaint about your privacy or this policy, please contact our Privacy Officer:

imei Pty Ltd – Privacy Officer 
Level 4, 18 Aquatic Drive 
Frenchs Forest NSW 2086 
Australia 

Email: privacy@imei.com.au 

Phone: 1300 65 77 99

We will acknowledge your complaint within five business days and respond within 30 calendar days. If you are not satisfied with our response, you may refer the matter to the Office of the Australian Information Commissioner at oaic.gov.au.

This Privacy Policy operates alongside our Website Terms of Use and, for users of the imei 360 portal, the imei 360 Portal Terms of Service.