Terms
At Superloop, the protection of your personal information is a priority for us. Our Privacy Policy (this document) outlines how we collect, use, store and most importantly, how we protect your information, so please take the time to read through and see what we are doing.
The Superloop group of companies, including Superloop Limited and its subsidiaries, Exetel Pty Ltd, Vostronet (Australia) Pty Ltd and Acurus Pty Ltd, is committed to protecting the privacy of your personal information. The entities of the Superloop group that are acting under this Privacy Policy are specified further in Part 1-5 of this Privacy Policy (“Superloop” or “we”) and are acting as data controllers in accordance with Art. 4 No. 7 EU Regulation 2016/679 (GDPR). You can access the contact information of each relevant Superloop entity here.
Superloop complies with Australian government laws and obligations towards your privacy under the Telecommunications Act 1997 (Cth), Telecommunications (Interception and Access) Amendment (Data Retention) Act 2015, the Do Not Call Register Act 2006 (Cth), the Spam Act 2010 (Cth) and Privacy Act 1988 (Cth), and is bound by the Australian Privacy Principles (APPs) set out in the Privacy Act 1988 (Cth).
This policy explains how Superloop collects, uses, shares, holds and retains your personal information as required in the normal course and scope of Superloop's business or when required by law, whether you are a website visitor, employee, employment applicant, staff member of a Superloop customer, or other private individual whose personal information is affected by Superloop's services or activities (Data Subject or you). Personal information is any information relating to an identified or identifiable natural person as defined by privacy laws in each country that we operate[1]).
Part 1 of this policy relates to Superloop's customers and how we use the information that we collect from them, including any personal information and information transmitted via Superloop's network in the course of providing services according to a Superloop services agreement (Services). Part 2 relates specifically to recruitment and recruitment-related personal information. Part 3 applies to all visitors to the Superloop websites, including, where applicable, customers and job applicants. This also includes the use of cookies.
Part 4 sets out information on how Superloop protects personal information and on your rights as a data subject. Parts 4 and 5 will be relevant to all visitors to the Superloop websites.
Superloop may update this policy from time to time by posting the revised version on Superloop's website.
In order to provide our customers with Services, or to perform a function related to providing our customers with Services, Superloop may need to collect and process certain data from our customers, which may include personal information relating to their staff or private individuals (Collection Data). This includes, in particular, the following types of data:
As Superloop may also collect personal information such as names and contact details from our customers' employees or authorised representatives, each customer must make sure that they have obtained the consent of such employees or authorised representatives to Superloop collecting and using such personal information in accordance with this Privacy Policy.
The Data Controller with regards to the Collection Data and the related Services is Superloop Limited or, if you are located in one of the countries with a local Superloop subsidiary, this local subsidiary is the data controller.
Providing the Collection Data is voluntary and based on the free will of the individual or entity providing the Collection Data. However, if a customer does not provide Superloop with the information Superloop needs, Superloop may not be able to provide that customer with the Services that customer wants or Superloop may be restricted in the way that Services can be supplied.
Superloop usually collects Collection Data when our customers interact directly with Superloop. For example, Superloop collects information when our customers and members of staff provide information to Superloop in person, by phone or email, or when customer details are entered on our websites. Superloop may also collect Collection Data, including from:
Superloop uses Collection Data to the extent necessary to provide customers with Services and related support. In doing so, Superloop may useCollection Data for related purposes as required in the normal course and scope of Superloop's business, such as:
Collecting and processing Collection Data for the purposes specified above is necessary to fulfil the Services towards the Customer[2], to protect Superloop's protected interests specified above[3], and to supply promotional communication to which the Customer has consented[4].
Superloop may need to share Collection Data within the Superloop group of companies and with other organisations to the extent necessary for the supply of Services to our customers[5]or to protect Superloop's interests specified below[6]. However, Superloop will not share customer information with any third party for the purpose of marketing or for other purposes without the customer's consent, except to the extent necessary for providing the Services or to protect Superloop's protected interests as required or permitted by law. In particular, Superloop may disclose Collection Data to:
When you apply for a service with Superloop you may be subject to a credit check with a Credit Reporting Body (CRB). The CRB that we use is:
Illion Australia Pty Ltd
Telephone: 13 23 33
Address: Level 20/201 Elizabeth Street, Sydney NSW 2000
Website: https://www.illion.com.au/
You can find their contact details, more about what they do and how they manage your credit information on their website. We work with customer service partners that are located within and outside of Australia on credit-related matters. Where necessary, we give our partners secured access to the credit information they need to help manage your credit and your services.
The organisations that Superloop may share Collection Data with may be located in countries outside the European Union such as the United States, Australia, New Zealand, Singapore, Hong Kong, Sri Lanka, the Philippines or member states of the European Union such as the United Kingdom. In case the recipient is located in a country outside the European Union that does not have an adequate level of data protection from the perspective of EU data protection laws, Superloop will ensure that the recipient complies with a level of data protection that is considered to be adequate from the perspective of EU data protection laws. You can request insight in the respective documents at slcprivacy@superloop.com. You are aware that the recipient in third countries is still subject to different domestic laws and regulations regarding privacy and the protection of personal data which may vary from European standards.
Superloop will store your personal information in Collection Data only as long as needed to satisfy the above purposes for which it was collected (normally after your Global Services Agreement expired) or as required or permitted by law.
Apart from collecting and processing the Collection Data, Superloop will, while performing its Services to its customers, transmit data packages including personal data via its network (Transmission Data).
Superloop will deliver services and process all Transmission Data that is required to allow Customers to transmit information and data packages through Superloop's network. This may be in particular:
Superloop processes Transmission Data to the extent necessary to provide the Services to the Customer, in particular to build up the connection between sender and recipient of data packages and transmit these data packages and (if applicable) to calculate fees for the use of the Services if these are connected to the amount of data transmitted. Superloop may also use certain technical Transmission Data in order to detect and resolve malfunctions in Superloop's network and Services or in the case of factual indications for the unlawful use of the Services or the network to detect and prevent this unlawful use.
Superloop will share Transmission Data with other network operators and service providers to the extent necessary for fulfilling the data transmission requested by Customer and to cooperate with government, law enforcement and regulatory bodies where this is required for Superloop to comply with Superloop's legal obligations.
Superloop will delete all Transmission Data directly after the requested network connection has been terminated except where it is necessary to retain certain Transmission Data for billing purposes (where fees are connected to the amount of data transmitted) or for detecting and resolving malfunctions of or security incidents relating to the Services and Superloop's network or in the case of factual indications for the unlawful use of the Services or the network to detect and prevent this unlawful use. Superloop may also be obliged to retain certain Transmission Data by domestic laws.
In order to process and assess your job application, Superloop needs to collect and hold some personal information about you. The Data Controller in connection with this Part 2 is the relevant Superloop entity you apply to. The types of information Superloop may collect include:
If you provide us with personal information, this is based on your free decision and on your free will. However, if you don't provide us with the personal information Superloop needs, Superloop may not be able to assess or proceed with your job application.
Superloop will only process sensitive personal data which you provide to us (that is personal data relating to an individual's racial or ethnic origin, political opinions, religious or other beliefs, political or trade union membership, philosophical beliefs, health, sexual orientation or criminal convictions).
Superloop usually collects personal information about you when you interact directly with us. For example, Superloop collects your personal details when you provide information to us in person, by phone or email, or when you enter your personal details on Superloop's recruitment websites. Superloop may also collect personal information about you indirectly, including from your referees, recruitment agencies and third parties Superloop engages to provide recruitment services on our behalf.
Superloop uses your personal information to:
Superloop will process your personal information for these purposes solely to the extent this is necessary for the application process and/or your subsequent employment with Superloop.
Superloop may need to share your personal information within the Superloop group of companies and with:
Superloop will share your personal information with the above third parties only to the extent this is required for the application process or your subsequent employment with Superloop.The organisations that Superloop may share your information with may be located in countries outside the European Union such as the United States, Australia, New Zealand, Singapore, Hong Kong, Sri Lanka, the Philippines and member states of the European Union such as the United Kingdom. In case the recipient is located in a country outside the European Union that does not have an adequate level of data protection from the perspective of EU data protection laws, Superloop will ensure that the recipient complies with a level of data protection that is considered to be adequate from the perspective of EU data protection laws. You can request insight in the respective documents at slcprivacy@superloop.com. You are aware that the recipient in third countries is still subject to different domestic laws and regulations regarding privacy and the protection of personal data which may vary from European standards.
Superloop will delete your personal information directly after the application process is finished unless you are employed afterwards at Superloop or have consented to retention of your data for future employment offers.
This section applies to all visitors to the website www.superloop.com or any other Superloop website (Website). Superloop Limited, the relevant Superloop entity which operates the Website, is the relevant data controller under this Part 3 of the Privacy Policy. Where you are a customer, Part 1 will apply in addition to this Part 3. Where you apply for a job with Superloop, Part 2 will apply in addition to this Part 3.
Superloop may collect and process the following data about you:
Superloop will delete your personal information directly after the application process is finished unless you are employed afterwards at Superloop or have consented to retention of your data for future employment offers.
Superloop will use this information:
Superloop will use the above information only to the extent required for Superloop's protected interests[7], or where this is necessary to provide requested Services to you[8].
We may share your personal information with suppliers and sub-contractors for the performance of our Services or where it is required to enable you to use our Website. We may also share your pseudonymized technical information (e.g. IP addresses) with selected third parties including Superloop group companies including:
Superloop will share your pseudonymized technical information with these third parties including its group companies only where such transfer is justified under Superloop's protected marketing and improvement interests[9]. You may object to such transfer of data by email to slcprivacy@superloop.com or by using a respective “do not track” tool in your web browser. For the above purposes, Superloop will not share any directly identifying information (e.g. names, email addresses, etc.) without your explicit prior consent except where this is necessary to provide any Services requested by you or to process any of your requests.
Superloop may further disclose your personal information to third parties:
Superloop may share your information with parties that may be located in countries outside the European Union such as the United States, Australia, New Zealand, Singapore, Hong Kong, Sri Lanka the Philippines as well as member states of the European Union such as the United Kingdom. In case the recipient is located in a country outside the European Union that does not have an adequate level of data protection from the perspective of EU data protection laws, Superloop will ensure that the recipient complies with a level of data protection that is considered to be adequate from the perspective of EU data protection laws. You can request sight in the respective documents at slcprivacy@superloop.com. You are aware that the recipient in third countries is still subject to different domestic laws and regulations regarding privacy and the protection of personal data which may vary from European standards.
Superloop retains your personal information only to the extent this is required for the purpose it has been collected for and as required or permitted by law.
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you give your respective consent upon the first visit of our Website. Cookies help Superloop to collect information about visits to Superloop's websites for marketing and statistical purposes to improve the way Superloop interacts with customers and with its other Website users. All accesses to pages on Superloop's websites are “logged”. The logged information contains such things as a list of the pages accessed and the sort of browser used. This information is used to check for attempts at “hacking”, or other fraudulent activity, to indicate missing pages or other web server problems. Superloop also uses it to provide general statistics such as the number of people viewing particular parts of the site. Superloop uses cookies to authenticate customer access or to make sure customer is the same person over a given “session” time. Superloop uses third party cookies (e.g. Google Analytics or Hubspot) to track how Superloop's Website is used. We may provide a limited amount of your information to these third parties. You can find more information about the individual cookies, which data is processed by them, how we use them and the purposes for which we use them and how to opt-out from them here. You can usually remove or block cookies by using the settings in your browser, but this may affect your ability to use Superloop's websites. Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.
Superloop treats your personal information as confidential. Superloop stores your personal information electronically and/or in hard copy form. Superloop takes a range of measures to protect the security of your personal information, including by storing electronic information in password-protected servers that are in restricted and monitored areas. Superloop does not store credit card details on Superloop's systems.
Your personal information can be accessed via your Superloop account or by contacting Superloop at slcprivacy@superloop.com. takes all reasonable steps to ensure that the personal information Superloop holds about you is accurate, complete and up-to-date. You can access and correct most of your personal information (such as your contact details) using your Superloop account. You can also contact Superloop at slcprivacy@superloop.com if you wish to access or correct personal information that Superloop holds about you.
You have the right to ask us not to process your personal data for marketing purposes. You have the right to request information about the data we store[10], to demand the correction of incorrect data[11], and to demand its deletion[12] or the blocking or restriction of the processing of data[13]. You are also entitled to object to the processing of your data, provided the reason for the objection lies in your special situation and provided it is data we process to protect one of our protectable interests[14]. You can exercise the above rights at any time by contacting us at slcprivacy@superloop.com.
If our data collection or processing is based on your consent, you may at any time freely withdraw your consent with effect for the future by email to slcprivacy@superloop.com.
Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
If you have an enquiry regarding privacy, or you wish to raise a complaint, you can contact the Privacy Officer by email at slcprivacy@superloop.com.
[1] E.G. by Art. 4 (1) of the GDPR.
[2] E.G. under Art. 6 para 1 lit b) of the GDPR.
[3] E.G. under Art. 6 para 1 lit f) of the GDPR.
[4] E.G. under Art. 6 para 1 lit. a) of the GDPR.
[5] E.G. under Art. 6 para 1 lit c) of the GDPR.
[6] E.G. under Art. 6 para. 1 lit f) of the GDPR.
[7] E.G: under Art. 6 para 1 lit f) of the GDPR.
[8] E.G. under Art. 6 para 1 lit c) of the GDPR.
[9] E.G. under Art. 6 para 1 lit f) of the GDPR.
[10] E.G. under Art. 15 of the GDPR.
[11] E.G. under Art. 16 of the GDPR.
[12] E.G. under Art. 17 of the GDPR.
[13] E.G. under Art. 18 of the GDPR.
[14] E.G. under Art. 21 of the GDPR.