The Softphone App (the Application) is owned and operated by Telcoinabox Operations Pty Ltd (‘TIAB’/, “We”/ “our”/ “us”). By using the Application, you agree to the Privacy Policy of the Application. The Privacy Policy relates to the collection and use of personal information you may supply to us through your usage of the Application.

We reserve the right, at our discretion, to modify or remove portions of this Privacy Policy at any time. This Privacy Policy is in addition to any other terms and conditions applicable to the Application. We do not make Any representations about third party websites that may be linked to the Application.

We recognise the importance of protecting the privacy of information collected about the users, through the Application, in particular, information that is capable of identifying an individual (“personal information”). Our Privacy Policy explains what information we collect and how we manage it, how we use that information and whom we disclose that information to, how to access the information we collect about you and how to correct it, how to make a privacy complaint and how we deal with such complaints.

1. What personal information we collect

We collect from you directly, when you use our Services, and from third parties.

Name and contact data

We collect your first and last name, email address, postal address, phone number, and other
similar personal information data.

Credential

We collect passwords and security information used for authentication and account access.

Payment data

We, or our third-party service providers, collect data necessary to process your payment if you
make purchases, such as your credit card number, CCV number or PayPal account information.

Usage data

We collect information about how you interact with our Services. In some cases, we do this
through cookies, pixel tags, and similar device identification technologies that create and
maintain unique identifiers. This includes information about the operating systems and other
software installed on your device. Moreover, it contains data about the performance of the
products or services and any problems you experience with them.

Device Information

We may collect information about your mobile device, including, for example, the hardware
model, operating system and version, software and file names and versions, preferred language,
unique device identifier, advertising identifiers, serial number, device motion information, and
network information.

Location and Demographic data

We collect information about your location in two ways. When you register or purchase a product
or service, we may request a billing address or country location. We also may derive data from
your IP address. We also collect information about your preferred language.

Content

We collect the content of your files and communications when necessary to provide you with the
services you use. For example, if you receive a message using the Application messaging
service, we need to collect the content of that message to deliver it to your softphone client,
display it to you, enable you to reply to it, and store it for you until you choose to delete it.
Examples of this data include the content of instant messages, or documents, photos, music or
videos you file transfer using the services.

We also collect the content of the messages you send to us, such as feedback and product
reviews you write, or questions or information you provide for customer support. When you
contact us, such as for customer support, chat sessions with our representatives may be
monitored and recorded.

Information We Collect from Other Sources

We may also receive information from other sources and combine that with information we
collect through our Services. For example:

• If you choose to link, create, or log in to the Application account with a payment provider or
social media service (e.g., Facebook), or if you engage with a separate app or website that
uses our API (or whose API we use), we may receive information about you or your
connections from that site or application.

• If you use the Application through an account associated with a partner distribution
company, we may receive information about you from that partner company.

2. How We Use Personal Data

We use the data we collect to provide you with the services we offer and to improve and
personalise your experiences. We also may use the data to communicate with you, including
sending you information on security updates, account status notices and product changes or
updates. Further details on how we specifically use your data are outlined below:

Providing and improving our products and services

We use data to provide and improve the services we offer and perform essential business
operations. This includes operating the services, maintaining and improving the performance of
the services, including the development of new features, research, and providing customer
support;

Business operations and compliance

As a publicly traded company, Inabox is required to file numerous reports with different
administrative bodies. As such, we may provide aggregate statistics about customers, sales and
traffic patterns. None of these reports or statistics include personally identifiable information.
However, we reserve the right to use the personally identifiable information to investigate and
help prevent potentially unlawful activity that threatens either Inabox or any company affiliated
with Inabox.

• Perform internal operations, including, for example, to prevent fraud and abuse of our
Services; to troubleshoot software bugs and operational problems; to conduct data
analysis, testing, and research; and to monitor and analyse usage and activity trends; and

• Personalise and improve the Application, including to provide or recommend features,
content, social connections, referrals, and advertisements.

When we may disclose your personal information

We may share the information we collect about you as described in this Statement or as described at the timeof collection or sharing, including as follows:

Law Enforcement Agencies

In response to a request for information by competent authority if we believe disclosure is in accordance with
the efficient administration of justice or is otherwise required by, any applicable law, regulation, ordinance,
licence, operating agreement, or legal process;

• With vendors, consultants, marketing partners, and other service providers who need access to such
information to carry out work on our behalf;

• With the general public if you submit content in a public forum, such as blog comments, social media
posts, or other features of the Application that are viewable by the general public;

• If we otherwise notify you and you consent to the sharing; and

• In an aggregated and/or anonymised form which cannot reasonably be used to identify you.

Important Information About Platform Permissions

Most mobile platforms (iOS, Android, etc.) have defined specific types of device data that applications cannot
access without your consent. Moreover, these platforms have different permission systems for obtaining your
consent. Most platform will alert you the first time the Application wants permission to access certain types
of data and will let you consent (or not consent) to that request. Some Android devices will notify you of the
permissions that the Application seeks before you first use the app, and your use of the application
constitutes your consent.

Storage and security

We are committed to ensuring that your information is secure. We typically hold the personal information we
collect on servers in electronic databases which may be located overseas and managed by our related entities
and/or service providers.

We have put in place suitable physical, electronic and administrative procedures to safeguard and protect the
information about you that we collect. The Personal Information and associated data stored on servers is
encrypted and is stored through data isolation technology. We limit access to personal information to
individuals we or our related entities employ or contracted service providers whom we believe reasonably
need access to such information to provide products or services to you or us or to perform their jobs.

Your Rights

Correcting your personal information

You may correct your account information at any time by logging into your online or in-application account. If
you wish to delete your account, please contact our support and request deletion of your account. Please note
that in some cases we may retain certain information about you as required by law, or for legitimate business
purposes to the extent permitted by law.

Access your information

In most cases, you have access to your personal information that we hold about you. We handle your access
information requests in accordance with the Australian Privacy Principles. We deal with all requests for
information as quickly as possible. Requests for a significant amount of personal information, or information
that is not currently in use, may require further time before a response can be given. We may charge you a fee
for access if a cost is incurred by us in order to retrieve your data, but in no case will we charge you a fee for
your application for access.

In some cases, we may refuse to give you access to data that we hold about you. This may include
circumstances where giving you access would:

• be unlawful (eg, where a record that contains data about you is subject to a claim for the legal
professional privilege by one of our contractual counterparties);

• have an unreasonable impact on another person’s privacy; or

• prejudice an investigation of unlawful activity.

• We may also refuse access where the data relates to existing or anticipated legal proceedings, and the
information would not be accessible by the process of discovery in those proceedings.

If we refuse to give you access, we will provide you with reasons for our refusal.

GDPR for EU Residents only

The Application complies with the data handling regime laid out in the GDPR in respect of any data of data
subjects in the EU that we may obtain.

GDPR rights

You are entitled to request details of the information that we hold about you and how we process it. We
will provide this information for no fee;
• You may also have a right to:
o Have that information rectified or deleted;
o Restrict our processing of that information;
o Stop unauthorised transfers of your data to a third party;
o In some circumstances, have that information transferred to another organisation; and
o Lodge a complaint in relation to our processing of your data with a local supervisory authority.
• Where we rely upon your consent as our legal basis for collecting and processing your data, you may
withdraw that consent at any time.
• If you object to the processing of your data, or if you have provided your consent to the processing and
you later choose to withdraw it, we will respect that choice in accordance with our legal obligations.
However, please be aware that:
• Such objection or withdrawal of consent could mean that we are unable to provide our services to you,
and could unduly prevent us from legitimately providing our services to other customers/clients’
subject to appropriate confidentiality protections; and
• Even after you have chosen to withdraw your consent, we may be able to continue to keep and process
your data to the extent required or otherwise permitted by law, in particular:
• To pursue our legitimate interests in a way that might reasonably be expected as part of running our
business and which does not materially impact on your rights, freedoms or interests; and
• In exercising and defending our legal rights and meeting our legal and regulatory obligations.

Duration of retention of your data

We will only keep your data for as long as is necessary for the purpose for which it was collected, subject to
satisfying any legal, accounting or reporting requirements. At the end of any retention period, your data will
either be deleted completely or anonymised (for example, by aggregation with other data so that it can be
used in a non-identifiable way for statistical analysis and business planning). In some circumstances, you can
ask us to delete your data.

We may amend this Privacy Policy from time to time. When there are changes to this Privacy Policy, we will
update this page. The date on the bottom will always indicate when we last made changes.

Questions or Concerns

If you have any questions or concerns about this privacy policy, please contact us at info@tecloinabox.com.
We will take these issues seriously and make every effort to address your concerns.

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