Legal
Privacy Policy
Version 2, effective 1 October 2026. We review our policies regularly and always publish the current version on this page.
Our commitment
Digital Soul Australia (Digital Soul) respects the privacy of every person who interacts with us. This policy explains how we handle personal information under the Australian Privacy Principles (APPs 1–13) of the Privacy Act 1988 (Cth), the Telecommunications Act 1997 (Cth), and related telecommunications legislation.
What we collect
We collect personal information reasonably necessary to:
- provide carrier, co-location, connectivity and professional services;
- respond to enquiries made through this website;
- meet our regulatory obligations as a registered Australian carrier (ACMA Carrier Licence No. 647).
Typical information includes name, business contact details, job title, and details of the enquiry or service. Where you are a customer of our connectivity services, we may also collect service address, billing details, and network usage information necessary to deliver the service.
How we use it
We use personal information to respond to enquiries, provide services, meet carrier licence obligations, and send service-related communications. We do not sell personal information.
Automated decisions
Section added July 2026. The Privacy Act automated-decision transparency obligation commences on 10 December 2026.
From 10 December 2026, if we arrange for a computer program to use personal information to make, or substantially assist in making, a decision that could reasonably be expected to significantly affect an individual's rights or interests, this policy will describe the kinds of personal information used and the kinds of decisions made or assisted. We are reviewing our service qualification, credit, fraud and disconnection processes against this requirement and will update this section before that date.
Telecommunications-specific obligations
As a licensed Australian carrier, we are subject to additional privacy and information-handling obligations under the Telecommunications Act 1997 (Cth), including:
- Part 13, protection of communications: We are prohibited from disclosing information about the contents or substance of communications carried on our network, or personal information about our customers, except as authorised by law.
- Data retention: Where required by the Telecommunications (Interception and Access) Act 1979 (Cth), we retain certain telecommunications data (such as subscriber information and network session data) for the period prescribed by law. We do not retain the content of communications.
- Lawful interception and access: We may be required to disclose customer information or communications data to law-enforcement and national security agencies where compelled by valid warrant, authorisation, or as otherwise required by Australian law. We maintain internal processes to verify the lawfulness of any such request before disclosure.
- Carrier licence conditions: We comply with the conditions of our carrier licence, including obligations relating to the security of our network and the protection of customer information from unauthorised access or interference.
Disclosure
We may disclose personal information to:
- our service providers (for example, email infrastructure and hosting providers) under appropriate confidentiality arrangements;
- for nbn services: nbn co limited and Leap Telecommunications Pty Ltd (ABN 51 607 668 566), trading as Leaptel, the wholesale carriage service provider through which we acquire nbn services, to qualify your address, connect, maintain and repair your service and manage technician appointments. We give them your name, the service address, your contact details, site access information for a visit and, because the wholesale provider's systems require it on every customer record, the account holder's date of birth. They use that information only for those purposes and may contact you about an appointment or work at your premises;
- payment processors (Stripe) to take payments and hold your payment method securely; we never store card numbers ourselves;
- regulators including the Australian Communications and Media Authority (ACMA) and the Telecommunications Industry Ombudsman (TIO), as required;
- law-enforcement or national security agencies where required by law, warrant, or authorisation under the Telecommunications (Interception and Access) Act 1979 (Cth).
The section below, "Who we share your information with, and where it is stored", lists every one of these organisations by name and says which country holds your information.
Who we share your information with, and where it is stored
Section added in Version 2, October 2026, addressing Australian Privacy Principles 1.4(f) and (g) and 5.2(i) and (j), which require us to say whether we are likely to disclose personal information to overseas recipients and, if practicable, which countries.
The table below lists every organisation we currently share personal information with, what we share, why, and the country where each one holds it.
| Who | What we share | Why | Where it is held |
|---|---|---|---|
| nbn co limited | Your service address and connection details | To qualify, connect and maintain your nbn service | Australia |
| Leap Telecommunications Pty Ltd (Leaptel), our wholesale nbn provider | Your name, service address, contact details, site access details and date of birth | To connect, maintain and repair your service and manage technician appointments | Australia |
| Splynx, our billing and customer management platform | Your name, contact details, date of birth, service and billing records and support tickets | To run your account, send invoices and track support tickets | Singapore. Splynx's own support staff, who can see this information to help run the platform, work from the Czech Republic |
| Stripe Payments Australia Pty Ltd | Your payment card details | To take payments and hold your payment method securely; we never see or store your full card number | United States |
| Xero | Your name and your invoice and payment records | For our own accounting | United States |
| Resend | Your name, email address and the content of emails we send you | To send order, account and service emails | United States, sent through servers in Japan |
| Amazon Web Services (AWS) | Your mobile number and the content of texts we send you | To send verification codes and other service texts | Australia (Sydney) |
| Twilio | Your mobile number and the content of texts you send us | To receive replies you text to our customer desk | United States |
| The address you type in when checking coverage or placing an order | To look it up and confirm it | United States | |
| OpenStreetMap Foundation | The address you type in | A backup address lookup if Google's service is unavailable | United Kingdom |
| Anthropic | The content of your support ticket, email or message to us | To help our customer desk draft and check replies to you | United States |
| Supabase | Every record we hold about you, including your account, orders and service history | This is our database, where your information is stored | Australia (Sydney) |
| Vercel | Every request you make to this website, including any personal information in it, while the website handles that request | This is who hosts this website and runs it for us | United States |
| Microsoft 365 | Emails and attachments you send us, and our own records of dealing with you | Our email and document storage | Australia |
We take reasonable steps to make sure that when an overseas recipient handles your personal information, they handle it consistently with the Australian Privacy Principles. We remain accountable for your personal information under the Privacy Act 1988 (Cth) even when it is held or processed overseas.
Our backups follow the same storage locations as the live systems listed above.
My Account sign-in and activity
When you sign in to My Account we email a one-time code to the address on your account and record the time, network (IP) address and browser type of each sign-in attempt and of the actions you take in your account (for example running a connection test), so that we can detect and investigate misuse. We keep those records with your account records. We never ask you for a sign-in code by phone, text or email.
Storage and security
We hold personal information in secure systems and take reasonable steps to protect it from misuse, loss and unauthorised access. As a carrier, we maintain competent supervision and effective control over our network and systems, consistent with the Telecommunications Sector Security Reforms (TSSR) and the Security of Critical Infrastructure Act 2018 (Cth).
Access, correction and complaints
You may request access to, or correction of, personal information we hold about you by writing to the contact below. You may also lodge a privacy complaint with us, and if dissatisfied with our response, with the Office of the Australian Information Commissioner (www.oaic.gov.au).
For complaints about our telecommunications services, you may also contact the Telecommunications Industry Ombudsman, which is free and independent for eligible customers (www.tio.com.au or 1800 062 058).
Contact
Privacy enquiries: enquiries@digitalsoulaustralia.com.au