Privacy Policy

BroadSource Group Subprocessors and Subcontractors

Last Updated on 17/09/2021 10.30 AEST

BroadSource Group (“BroadSource”) uses certain subprocessors (including members of the BroadSource Group and third parties, as listed below) to assist it in providing our Products and Services.

What is a Subprocessor

A subprocessor is a third party data processor engaged by BroadSource, including entities from within the BroadSource Group, that has or potentially will have access to or process service and marketing related data (which may contain Personal Data).

BroadSource engages different types of subprocessors to perform various functions as explained in the tables below. BroadSource refers to third parties that do not have access to or process Service Data but who are otherwise used to provide the Services as “subcontractors” and not subprocessors.

Due Diligence

BroadSource undertakes to use a commercially reasonable selection process by which it evaluates the security, privacy and confidentiality practices of proposed subprocessors that will or may have access to or process Service Data.

Safeguards

BroadSource requires its subprocessors to satisfy equivalent obligations as those required from BroadSource (as a Data Processor), including but not limited to the following requirements:

• Only process Personal Data in accordance with data controller’s (i.e. Broadsource or our Subscribers) documented instructions (as communicated in writing to the relevant subprocessor by BroadSource)
• In connection with their subprocessing activities, use only personnel who are reliable and subject to a contractually binding obligation to observe data privacy and security, to the extent applicable, pursuant to applicable data protection laws
• Provide regular training in security and data protection to personnel to whom they grant access to Personal Data
• Implement and maintain appropriate technical and organizational measures (including measures consistent with those to which BroadSource is contractually committed to adhere insofar as they are equally relevant to the subprocessor’s processing of Personal Data on BroadSource’s behalf) and provide an annual certification that evidences compliance with this obligation. In the absence of such certification BroadSource reserves the right to audit the subprocessor
• promptly inform BroadSource about any actual or potential security breach
• Cooperate with BroadSource in order to deal with requests from data controllers, data subjects or data protection authorities, as applicable.

BroadSource Group Subprocessors

The following entities are part of the BroadSource Group, they act as subprocessors to provide services on behalf of BroadSource

Entity	Country
Broadsource Australia Pty Ltd	Australia
Broadsource Europe Limited	United Kingdom
Broadsource USA LLC	United States
BroadSource India Private Limited	India

Third-Party Subprocessors

The following third-party entities act as subprocessors to provide services on behalf of BroadSource

Entity	Services Provided	Subprocessor Location
Zoho Corporation	Customer Relationship Management and Email Marketing Services	United States
Zendesk Inc	Customer Helpdesk and Ticketing Platform	United States
Twilio Inc	Telephony and SMS Messaging Services	United States
Xero Australia Pty Limited	Invoicing and Accounting Platform	Australia
Microsoft Corporation	Office 365 Platform	Australia and United States

Subcontractors

The following third-party entities act as subcontractors and provide service components on behalf of BroadSource

Entity	Services Provided	Subprocessor Location
Amazon Web Services Inc	Hosting Services and Data Storage	United States, Australia and Germany

We have appointed a data protection officer (DPO), who is responsible for overseeing questions in relation to our Privacy Policy and related matters. If you have any questions, requests, concerns or about our Privacy Policy, how we manage your Personal Information or any other issues related to your Personal Information please contact our DPO:

BroadSource Group Pty Ltd
Attention: Data Protection Officer
privacy@broadsource.com.au
Level 13/664 Collins Street
Docklands 3008, Victoria, Australia
Phone: +61 3 9006 1050

Collection of Personal Information

As a visitor to the BroadSource website, you can engage in many activities and access basic product or service information without a requirement to provide any Personal Information.

When you access our website(s), BroadSource may also collect certain technical information about your computer to facilitate use of the Site and our products / services. As an example we may log environmental information such as Web Browser Type, Operating System and the Internet Protocol (IP) address of your computer in order to facilitate your access to the Site and track your usage of the various products / services contained within the Site. We may also use this information in combination with Personal information to better understand the needs of visitors and subscribers.

When you register to receive marketing information or Product / Service updates from BroadSource, we may collect the following information from you:

• Contact Information such as your name, email address and mobile or office phone numbers
• Demographic Information such as your job title, job description, business name and business type
• Marketing Interests such as the products or services you are interested in and if you would like to receive information about them

Alternatively when you register as part of subscribing to any BroadSource Products or Services we may collect the following additional information from you:

• Business Information such as business name, business type, business address
• Billing Information such as contact details for Accounts Payable Department or your credit card number, expiration date, card type and billing address
• User Profile Data such as your email address or username, password and details of the BroadSource products or services you have subscribed to
• Communications Preferences such as your preferred method of receiving mandatory notifications or communication from BroadSource related to your subscription(s)

Depending upon the type of activity, some of the information we ask you to provide is identified as required or mandatory and some as optional. If you do not wish to provide the mandatory information required for a particular activity, you will not be able to engage in that activity or subscribe to that product / service.

How Your Personal Information is Used

BroadSource collects and uses your Personal Information in order to provide services to you, comply with relevant legal and regulatory obligations, and to improve our products and services. We do not sell, rent, or share your personally identifiable information to or with third parties in any way other than is disclosed in this Privacy Policy.

BroadSource may use this information to:

• Keep you informed about updates or special offers related to BroadSource Products and Services
• Send you requested Product or Service information
• Administer your account in our platform(s)
• Respond to Customer Service / Support Requests, questions or concerns
• Register your right to access technical support and other services that may be available to our Customers
• Send you billing information and order confirmations
• Send you non-marketing notifications directly related to the Services or Subscriptions you hold with BroadSource

In certain situations, BroadSource may be required to disclose personal data in response to lawful requests by public authorities and agencies, including to meet national security or law enforcement requirements. Where required by law (e.g. to comply with a subpoena, warrant, court order, or legal process served on BroadSource), and when we believe that disclosure is necessary to protect our rights, to avoid litigation, protect your safety or the safety of others, investigate fraud, and/or respond to a government request.

At our discretion, we may also disclose information about you if we determine that such disclosure should be made for reasons of national security, law enforcement or other issues deemed to be of public importance.

Updating Your Privacy Preferences and Personal Information

You have the right to view, correct or request deletion of your personal information and privacy preferences at any time and this can be accomplished by contacting us at privacy@broadsource.com.au

Upon request BroadSource will provide you with information about whether we hold or process any of your personal information. To request this information please contact us at privacy@broadsource.com.au

We will respond to these requests via email promptly within a reasonable time-frame.

Protection of Your Personal Information

The Personal Information you provide in connection with receiving marketing information or subscribing to our services is protected in several ways:

• Your Personal Information is stored on password protected secure servers that only can only be accessed by selected BroadSource staff and contractors
• Access to your subscribed products and services including your personal information is available through use of your email address and a strong alpha numeric password, selected by you, with the option to use two-factor authentication via supported methods. Your password is encrypted and should not be divulged to anyone
• Where applicable, sensitive data may be “encrypted at rest” as an additional layer of security
• Your Personal Information and any sensitive information (e.g. credit card or payment details) is encrypted in transit at all times using Transport Layer Security (TLS) technology

We strive to protect the Personal Information submitted to us, both during transmission and once we have received it, and use reasonable measures to protect your Personal Information based on its sensitivity and available technology. No method of transmission over the internet or electronic storage is 100% secure, and we cannot guarantee its absolute security.

If you have any questions or concerns about security on our Websites or in our Products and Services, you can contact us via email at privacy@broadsource.com.au

Data Retention

We will retain your information for as long as it is required to provide you marketing information with your consent, provide you with services or fulfil our legal obligations.
In the event that you request BroadSource to delete your Personal Information or no longer use it to provide you with services or marketing information, please contact us at privacy@broadsource.com.au

Once received, we will respond to your request within 30 days but will still retain or use your information where necessary to comply with our legal obligations, resolve disputes and enforce agreements.

Information Sharing with Third Parties

BroadSource does not sell or otherwise provide any Personal Information to third parties for the marketing of their own products or services, but does use third-party companies to perform services on our behalf and only share the minimum Personal Information required that is necessary for them to provide those services. An example of this is credit card processing facilities provided by a third-party company, who we use to bill your for our products and services. To the best of our knowledge these companies do not store, share or use personally identifiable information for any other purpose apart from processing payments on our behalf.

We require that any company we may share Personal Information with to protect the data in a manner consistent with this policy and limit the use of this information to the performance of services on behalf of BroadSource.

Opt Out / Choice

You may “opt out” of receiving marketing related updates at any time via Email by contacting us at privacy@broadsource.com.au

Once you have opted out of marketing related updates, BroadSource may still contact you in the following scenarios:

• Updates to our Terms of Service
• Updates to our Privacy Policy
• Service Related Announcements such as:
  • Registration Emails
  • Emails triggered by Actions taken in the Site or Service
  • Service Status or Planned Maintenance Notifications
  • Billing related Notifications

Generally you may not opt out of these communications, which are not promotional in nature and are related to a subscription you have with BroadSource. If you wish not to receive these communications, you have the option of deactivating your account.

Cookie and Tracking Technologies

The Site may automatically collect information as you browse, such as Internet Service Provider, browser type and version, operating system and device type, average time spent on our site(s), pages viewed, information accessed, the Internet Protocol (IP) address used to connect your computer to the Internet and other relevant statistics. Such information is sometimes referred to as web analytics and/or click-stream data.

We may combine this automatically collected log information with other information we collect about you. We do this to improve services we offer you, to improve marketing, analytics, and provide site functionality.

Technologies such as cookies, beacons, tags and scripts are used by BroadSource and our affiliates, analytics services and service to provide site features and functionality. These technologies are used in analyzing trends, administering the site, tracking users’ movements around the site and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.

• A cookie is a small, unique text file that a website can send to your computer when you visit a site. We may use session cookies, which terminate when a user closes his or her browser, and/or persistent cookies, which remain on the user’s computer until manually deleted. Most web browsers can either alert you to the use of cookies or refuse to accept cookies entirely. If you do not want us to deploy cookies to your browser, you can set your browser to reject cookies or to notify you when a website tries to put a cookie on your computer. Rejecting cookies may affect your ability to use the Site.

Changes in Privacy Policy

BroadSource reserves the right to amend the Privacy Policy from time to time at its sole discretion and will provide notice by email or on the home page of the Site when we make material changes to this Privacy Policy prior to the change becoming effective. If as the result of such changes, you want to alter the ways in which BroadSource is allowed to use your Personal Information, you can do so by following the procedure described in the section entitled “Updating Your Personal Information and Privacy Preferences.”

You will be deemed to have been made aware of, and will be subject to, any material changes to the Privacy Policy after such notice has been posted with the following exception:

If at the time you provide Personal Information to BroadSource you are given the opportunity (as you currently are) to limit how such information will be used to communicate with you, either by BroadSource or by third parties, BroadSource will not change your preference in this regard without your express consent. However, if BroadSource is acquired by or merged with another entity, BroadSource may provide to such entity customer information that is related to that part of our business that was sold to or merged with the other entity without your consent, but BroadSource will provide notice of such asset sales, acquisitions, or mergers on this Site.

Links to Third Party Sites

Our Site includes links to other Websites whose privacy practices may differ from those of BroadSource. If you submit personal information to any of those sites, your information is governed by their privacy policies. We encourage you to carefully read the Privacy Policy of any Web site you visit.

Social Media Widgets

Our Web sites may include Social Media Features, such as the Facebook Like button and Widgets, the Share button or interactive mini-programs that run on our site. These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. Social Media features and Widgets are either hosted by a third party or hosted directly on our Site. Your interactions with these features are governed by the Privacy Policy of the company providing it.

Children

We do not intend to solicit or collect Personal Information from anyone under the age of 18. If you are under 18, do not enter information on this site or engage our services. If you believe a child under the age of 18 has entered Personal Information please contact support@broadsource.com.au to have the data removed and terminate the child’s account.

Privacy Complaints

Individuals located in certain countries, including the European Economic Area, have certain statutory rights in relation to their personal data. Subject to any exemptions provided by law, you may have the right to request access to Information, as well as to seek to update, delete or correct this Information.

To the extent that BroadSource’s processing of your Personal Data is subject to the EU General Data Protection Regulation, BroadSource relies on its legitimate interests, described above, to process your data. Where BroadSource processes certain Personal Data for BroadSource’s own direct marketing purposes, you have a right to object to BroadSource’s use of your Personal Data for this purpose at any time by emailing privacy@broadsource.com.au.

BroadSource takes its users’ privacy concerns seriously. If you believe that BroadSource has not complied with this Privacy Policy with respect to your Personal Information, you may contact the Data Protection Officer at:

BroadSource Group Pty Ltd
Attention: Data Protection Officer
privacy@broadsource.com.au
Level 13/664 Collins Street
Docklands 3008, Victoria, Australia
Phone: +61 3 9006 1050

In your letter please describe in as much detail as possible the ways in which you believe that the BroadSource Privacy Policy has not been complied with. Once received, we will investigate your complaint promptly.

If you have any questions about this Privacy Policy, the practices of this site, or your dealings with this Web site, you can contact our Data Protection Officer at privacy@broadsource.com.au.