Privacy Policy

1. Introduction

This Privacy Policy is issued by JND Comms Pty Ltd (ABN 58 686 602 666), trading as heardle ("we", "our", or "us"). It explains how we collect, use, disclose, and safeguard personal information when you visit heardle.com.au, use YOUR.heard, or take a telecommunications service from us in Australia.

We handle personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs). Other laws that can apply include the Telecommunications Act 1997 (Cth), the Telecommunications (Interception and Access) Act 1979 (Cth), the Spam Act 2003 (Cth), and the Notifiable Data Breaches scheme. If you do not agree with this policy, please do not use our services.

2. Information we collect

2.1 Information you give us

Depending on how you deal with us, this may include:

• Name, email, phone number, postal and service address
• For business accounts: legal name, trading name, ABN, and job title of the contact
• Account credentials and YOUR.heard preferences
• Billing details and payment method tokens processed by Stripe (we do not store full card or bank account numbers)
• Information you put in forms, quotes, support tickets, or complaints
• Proof of identity (for example a driver licence or passport number) only when we need it to verify you for account changes, fraud prevention, or a carrier / ACMA requirement — we do not collect these documents as part of ordinary website signup

We do not currently obtain consumer credit reports from a credit reporting agency. If that changes, we will update this policy before we do so and tell you at the time we collect the information.

2.2 Information from other sources

We may collect information from nbn® address and service-qualification checks, wholesale carriers, payment processors (Stripe), our hosting and security providers, and (for business accounts) the Australian Business Register when you look up an ABN. We do not buy marketing lists.

2.3 Technical information

When you visit our website or YOUR.heard we may collect IP address, device identifiers, browser and operating system, pages viewed, referring site, and essential cookies. See our Cookie Policy.

2.4 Service and communications information

When you use a telecommunications service we may collect call and message records, numbers called or received, time, duration, type of communication, approximate location of the equipment used, data-session volume, service configuration, and support records. We do not record the content of your calls or internet sessions except where you ask us to (for example a support session) or the law requires it.

3. How we use your information

• Service delivery: to connect, maintain, bill, and support nbn®, mobile, and phone / PBX services
• Identity and account security: to verify you, prevent fraud, and protect YOUR.heard
• Payments: to take payment through Stripe and manage invoices
• Network and fault management: to diagnose faults and protect the network
• IPND and emergencies: to supply public-number customer details to the Integrated Public Number Database and to emergency services where the law requires it
• Legal compliance: including telecommunications, tax, and data-retention laws
• Communication: service updates and account notices; marketing email or SMS only where the Spam Act 2003 (Cth) allows it, with a clear opt-out
• Analytics: to understand how the website and services are used, using our own logs (not third-party advertising pixels)

4. Disclosure

We may disclose personal information to:

• nbn®, wholesale carriers, and other suppliers who need it to deliver or repair a service
• the operator of the Integrated Public Number Database, and emergency service organisations
• law enforcement, ACMA, the TIO, or a court where required or authorised by law
• Stripe and our hosting / security providers
• professional advisers, and a debt-collection agency if an account is seriously overdue
• a buyer or successor if we sell or restructure the business, on the basis they handle the information consistently with this policy

We do not sell personal information for marketing. We do not currently disclose information to a credit reporting agency.

5. IPND and emergency services

If we supply you with a public telephone number (including many voice / PBX and mobile services), we must give your name, address, and number — including unlisted numbers — to the Integrated Public Number Database. That database is used by Triple Zero and other emergency services, and for directory and related purposes allowed by law. Unlisted numbers are still available to emergency services.

6. Telecommunications metadata

As a carriage service provider we may be required under the Telecommunications (Interception and Access) Act 1979 (Cth) to collect and retain prescribed information about a service: the identity of the subscriber, the source and destination of a communication, the date, time and duration, the type of communication, and the location of the equipment used. We handle that information in accordance with this policy and those laws. We do not use it for marketing.

7. Sensitive information

We do not seek health or other sensitive information. Our Key Facts Sheet warns that medical and security alarms may not work on nbn® — that is a service warning, not a request for health data. If you volunteer sensitive information (for example when discussing a medical alarm), we will only use it for the purpose you gave it and with your consent, unless another exception in the Privacy Act applies.

8. Data security

We implement reasonable technical and organisational measures to protect personal information from misuse, interference, loss, and unauthorised access, modification, or disclosure. No internet transmission or storage method is completely secure.

9. Retention

We keep personal information for as long as we need it for the purposes in this policy, and as required by telecommunications data-retention, tax, and other laws. When it is no longer needed we take reasonable steps to destroy or de-identify it.

10. Access, correction, and complaints (APP 12 and 13)

You can ask us for access to the personal information we hold about you, or ask us to correct it if it is inaccurate, out of date, incomplete, irrelevant, or misleading.

Write to the Privacy Officer at the address in section 16, or email privacy@heardle.com.au. Please say what information you want and include enough detail for us to find it. We will take reasonable steps to verify your identity before we give access or make a change.

We will respond within 30 days. We may charge our reasonable costs of giving access (we will tell you first). We may refuse access in the limited situations the Privacy Act allows — for example where giving access would unreasonably affect someone else’s privacy, is unlawful, or is required to be withheld by a court order. If we refuse, we will give reasons (unless it is unreasonable to do so) and tell you how to complain.

If you are not satisfied with our response, you may complain to the Office of the Australian Information Commissioner (details below). If the issue is about how we handled personal information in connection with a telephone or internet service, you may also use our Complaints Handling Policy or contact the TIO.

11. Direct marketing

You can opt out of marketing emails or SMS by using the unsubscribe link or by emailing privacy@heardle.com.au. We will still send account, billing, fault, and legally required messages.

12. Cookies

We use essential cookies needed for security, signup, and YOUR.heard login. We do not currently use advertising or third-party analytics cookies. See our Cookie Policy.

13. Overseas disclosure

Some processors (including Stripe for payments, and our hosting or security providers) may handle information outside Australia. We take reasonable steps, consistent with APP 8, so those processors handle the information in a way that is substantially similar to the APPs, including contractual obligations where appropriate.

14. Data breaches

If we experience an eligible data breach under the Notifiable Data Breaches scheme, we will assess the incident promptly and, where required, notify affected individuals and the OAIC as soon as practicable, with information about the breach and steps you can take.

15. Children's privacy

Our services are not directed to individuals under 18. We do not knowingly collect personal information from children. If you believe we have, contact us and we will delete it unless the law requires us to keep it.

16. Changes and contact

We may update this policy by posting the new version on this page and updating the date above. Material changes will be notified through YOUR.heard or the email on your account where practicable.

Privacy Officer
JND Comms Pty Ltd trading as heardle
ABN 58 686 602 666
Email: privacy@heardle.com.au
Phone: 1300 1 Heard (1300 143 273)
Address: Factory 8, 3 Fairmile Close, Charmhaven NSW 2263
PO Box: PO Box 4604, Lake Haven NSW 2263

OAIC
Website: www.oaic.gov.au
Phone: 1300 363 992