The Privacy Act 1988 (Cth) and Australian Privacy Principles (“APPs”) regulate how organisations handle personal information. The APPs contain obligations regarding the collection, storage, use and disclosure of personal information.
Telnyx Australia Pty Ltd (“Telnyx” or “we”) considers itself bound by the Privacy Act 1988 (Cth). APP 5 requires Telnyx to notify you of certain matters when it collects personal information about you. This Privacy Notice applies to your personal information that we collect when you register on Telnyx’s website and purchase a prepaid mobile number service. Telnyx acknowledges that the United States of America does not have laws equivalent to the Privacy Act 1988 (Cth).
This notice should be read alongside our Privacy Policy, which is available at our website: https://telnyx.com/privacy-policy. Telnyx is committed to protecting the privacy of its customers.
Telnyx’s business is predominantly online and sales and distribution is offered via its online portal. As a result, Telnyx uses a secure online identification service provided by its subcontractor, Onfido UK Limited and its affiliates (together “Onfido”), to verify the identity of prepaid mobile customers as required by law. Onfido’s Facial Scan and Voice Recording Policy is available at: https://onfido.com/facial-scan-policy-and-release/. Information held by Onfido relating to you is stored in the United States of America.
Under the APPs, personal information may only be collected where it is reasonably necessary for the collecting organisation’s functions or activities.
Telnyx and/or Onfido collect personal information (including sensitive information) about you when you register on Telnyx’s website and purchase a prepaid mobile number service. Information that Telnyx (or Onfido) may collect includes:
This information is collected via direct interactions with you (e.g. filling in forms, uploading document and selfies) and through the use of the website and services.
In relation to each verification request, Telnyx stores the document type (e.g. passport, license) used as part of the ID verification request, together with the status for the Onfido ID verification request and the verification request ID.
The purpose of collecting this information is to provide you with access to the online portal, verify your identity as part of Onfido’s identity verification services, and to comply with our regulatory obligations,[1] so that we may provide services to you. Biometric information and other personal information may be used to verify your identity or authenticate you and your use of Telnyx’s services,and detect and prevent fraud, evaluate the authenticity of images and ID documents.
If we do not collect this information, Onfido will not be able to complete the verification process and you will need to contact Telnyx for an alternative way to verify your identity such as in-person verification. If an alternative is not available, we will be unable to provide you with a prepaid mobile number service.
We may disclose your biometric data and other personal data to third parties including Microsoft Ireland Operations Limited (whose technology is used to convert your voice recording into written text (Speech to Text)) and Amazon Web Services (who provides another Speech to Text service as well as Onfido’s cloud storage), who process this data on our behalf. The data will be stored in the United States or as otherwise agreed between you and us. Notwithstanding the foregoing, except as necessary to provide the Australian services, we will not disclose biometric data to third parties, including Microsoft and Amazon.
Our Privacy Policy contains information about how you may access your personal information and ask us to correct any information you believe to be inaccurate. In addition, our subcontractor, Onfido, will delete your biometric information within 48 hours after a report is generated.
Our Privacy Policy also contains information about how you may complain about a breach of the Australian Privacy Principles and how we will deal with such a complaint.
Telnyx maintains a range of physical, electronic and procedural safeguards to protect the confidentiality of personal information provided by you.
If you have any questions or concerns relating to our collection and use of this information, you may email us at [email protected].
[1] Telecommunications (Service Provider — Identity Checks for Prepaid Mobile Carriage Services) Determination 2017.