CommuniTel Privacy Promise

Effective 1st July 2005.

This privacy policy should be read in conjunction with our Terms of Service.

This policy explains what information that CommuniTel collects about Subscribers to the Service and how CommuniTel uses this information.

1. Collection and Use of Personally Identifiable Information
    a. Collection

    CommuniTel only collects personally identifiable information that is volunteered by Subscribers during the registration process or in response to specific information requests presented directly to Subscribers. CommuniTel only collects information that is necessary for us to perform our business and we will not collect any personal information deemed to be sensitive under the Privacy Amendment Act 2000.

    Use & Disclosure

    Specific identifiable information is collected from Subscribers for the purpose of determining the eligibility for the program; for billing; for credit management; and for the shipping of rewards and prizes. This information includes details such as telephone number, name, address and email address.

    We WILL NOT edit, modify or disclose your personally identifiable information to any third party without your permission unless we believe such action is necessary to:

    (1) Obtain a credit reference/check or for debt collection in the event of default
    (2) Conform to legal requirements or comply with a legal procedure;
    (3) Protect and defend CommuniTel' rights and property;
    (4) Enforce the CommuniTel Terms Of Service (TOS); or
    (5) Protect the interests of our subscribers or others.

    We may access your account, including its contents, as stated above or to respond to billing, service or technical issues.

    Data Security

    Personally identifiable and billing information collected by CommuniTelis stored in accordance with our site security policy and we take reasonable steps to ensure that member information is secure from unauthorised access, modification or disclosure.

    Access & Correction

    Personally identifiable information collected by CommuniTel can be accessed and updated by the Member by using the facility provided on the Site (you may be required to log in first).

2. Collection and Use of Non-Personally Identifiable Information

CommuniTel collects and stores general information about our Subscribers and their activity on our site and affiliated sites so that we can improve our offerings and tailor content on our site and affiliated sites to meet the interests of our Subscribers. The information we collect includes the non-personally identifiable information volunteered during the registration process or in response to specific information requests presented directly to Subscribers. Wherever possible, we will use the information we hold to improve the relevance of surveys and if applicable, email promotions that we send to Subscribers.

CommuniTel may make general aggregate data (such as age groups, interest profiles, geographic regions and other non-identifying information) about our Subscribers available to existing and potential advertisers, business partners and investors. This aggregate data never contains specific identifiable information about any individual user.

The CommuniTel servers automatically record your IP address, your browser type and operating system when you access our site. We may use this information to help diagnose problems with our server, administer our web site and compile aggregate user information for our advertisers. If we detect fraud or abuse of our system we may use the IP address of the offender to take action against them.

CommuniTel uses Cookies to personalise your experience and identify you when you are logged in to our site. We may also use cookies to estimate our audience size and measure traffic to, and usage of, our web site.

CommuniTel may use technology known as ``Clear GIFs'' on our Site, in our email communications and on the web sites of our affiliates or partners. Clear GIFs do not store or contain any personally identifiable information but they allow us to better track the effectiveness of our promotions.

CommuniTel has developed a system to automatically credit our Subscribers with CommuniTel Points when they transact with our partners or affiliates, eg. at the completion of a survey. This system uses a combination of a Cookie and a Clear GIF to enable us to identify the transaction as belonging to you and to credit your account accordingly. By disabling support for Cookies in your browser we will be unable to recognise the transaction or credit your account. This system does not allow any third party to access any of your personally identifiable information.

3. Linked Sites

The CommuniTel Site, the survey invitations we send you, and if applicable, the email promotions we send you may provide links to our partner and advertiser web sites. If you link to any of these Third Party sites this policy will not apply to your use of those sites.

4. Opting out of survey invitations and email promotions

As a condition of your subscription you must provide a valid email address and accept email promotions and survey invitations from us.

If you do not wish to receive email promotions and survey invitations from us you must close your account using the facility provided on the site. By terminating your account you will forfeit any remaining credit in your account and will be ineligible for to participate in the program.

5. Transfer in certain circumstances

At its sole discretion, CommuniTel may sell or assign information collected on and through our Site, including personally identifiable information, to one or more third parties as a result of the sale, merger, change of control, reorganisation or liquidation of CommuniTel.

6. Termination of account

If you choose to terminate your account or if we terminate your account you will not receive further email promotions from us. CommuniTel does keep standard business records of all Subscribers' transactions, including calls logs and billing activity.

7. Changes to this policy

CommuniTel reserves the right to update this policy from time to time, in part or in whole. Depending on the nature of the change we may, at our sole discretion, either announce the change on our web site or notify Subscribers by email. If you do not agree with this privacy policy in whole or in part, or if you no not agree with changes made to this policy, you must terminate your account.

For more information regarding this policy please contact us at:

CommuniTel Privacy Officer

C/- Empowered Communications Pty Ltd
Ground Floor, 102 York Street
South Melbourne VIC 3205, Australia
Phone: 03 9940 1600 Fax 03 9940 1650
privacy@Communitel.com.au

© Copyright 2005 - Empowered Technologies Pty Ltd A.C.N. 096 918 080