Information we collect from you
In order to set up services with Sublime IP, or place an order, we will need to request certain information from you. This will normally include your name, address and contact phone number(s) and may also include payment information such as credit card details.
In the first instance, we make sure you are confident about who you are sending this information to, and also that it gets to us and no-one else. We use a strong encryption including an Extended Validation (EV) SSL certificate certified by GeoTrust Inc. for this purpose. Our separate information page on online order security has further details on the security of information you submit to us.
We may collect and retain information relating to your business dealings and communications with us, including documents sent and received by fax, telephone calls and items of postal mail.
Other information sources
In the course of providing services to you, may also obtain additional details to help us provide services to you, or for general statistical and administrative tasks. This can include such information as your IP address, your browser manufacturer and version, web pages that referred you to our site, the date and times of access to our services and similar information.
Calls to and from our offices may be recorded. We may also collect Calling Line Identifier (CLI or “caller ID”) information about your calls made to us. This may be the case even if you dial a CLI blocking prefix with your carrier or have a private or unlisted number.
The privacy of CLI information is upheld rigorously and used only for purposes defined in the ACA’s guidelines on carriers and carriage service providers’ handling of CLI information. This typically includes fraud prevention, law enforcement and similar circumstances. We do not provide CLI information to end-users, even if you are the account holder, unless specifically required to do so (for example, by a court order).
We may utilise various public information sources (such as ASIC, the Australian White Pages, registry whois data, and similar) to help maintain the accuracy of your contact details. If you are applying for ongoing services or if we have reason to suspect credit risk, we may request a commercial and/or personal credit reference check from D&B, Baycorp Advantage or other information providers to assess or credit risk in dealing with you. This information will not be used for any other purpose.
Why we need this information
Personal information you provide will be kept confidential and used only to ensure we are able to identify you as our client (as we are required to do under Australian law) and to see that we have sufficient details to be able to provide the requested services to and ensure their smooth ongoing operation.
Some information, such as telephone call recordings or copies of written correspondance, may be retained as evidence of requests to provide (or cease to provide) a service or to ensure an adequate audit trail is maintained for activities relating to your services with us and that no unauthorised changes are made.
In our normal course of business we may need to contact you in order to continue to provide service for you, e.g. to arrange a change of password for your account, to obtain additional information if necessary, to ensure customer service and so on. We also have government obligations under Australian telecommunications industry law to be able to identify the authorised owner of several of the services we provide.
Domain name registrations
Please note: If you are registering a domain name, you should see the important additional information below as some of the details you provide do need to be made publicly available as part of the domain name registration process. By requesting us to register a domain on your behalf, you consent to the disclosure of the information you provide during the registration process to the required third party registries. Note that the various domain registries around the world each have their own independent privacy policies and may be subject to different legal jurisdictions.
Email privacy and the “postmaster” function
While it may be technically possible for Sublime IP to read the contents of your mail messages we are certainly not in the habit of doing this.
Occasionally, however, routine system operation, diagnostic or maintenance tasks can require closer examination of activity and data including stored email.
If Internet mail is unable to be delivered or returned to the sender, it is diverted to a person who has a “postmaster” function in preference to being lost (like the former “dead letter office” of Australia Post). Internet RFCs (standards) specify that all sites on the Internet are required to provide a “postmaster”. It is possible that misaddressed or deferred mail will be redirected to us for investigation of any possible technical faults or system anomalies. Any such information we come into contact with will be kept in the highest confidence, and will be investigated only in sufficient detail for us to determine the likely cause of email delivery problems.
Once your mail or data leaves Sublime IP and goes through our Internet gateways, Sublime IP has absolutely no control over what happens to it. There is considerable scope for other parties on the Internet to view your mail without your knowledge or consent. If you are sending sensitive information via email, you are strongly advised to take appropriate precautions to ensure your message is only readable by the intended recipient(s). There are several packages to achieve this, such as PGP (which is free for non-commercial use) and the The GNU Privacy Guard (GNUPG) (which is free for any use under the GNU public license).
Sublime IP, as with almost every other Internet Service Provider, maintains detailed logs of mail activity for statistical and diagnostic purposes. These logs may contain the address from which you send email, addresses to which you send mail, the size of such messages, the time and date of email activity and the status or outcome of the delivery (e.g. successful, deferred, bounced due to unknown user, etc). These logs do not contain any information from the actual message body, or subject of messages you send or receive.
Hosted web sites
If you have a web site hosted by Sublime IP, detailed logging information is collected from visitors to your web site. Your web site logs will not be disclosed to any third parties without your explicit consent. This information is used to provide you with summarised statistical reports (“web stats”) indicating information such as the most popular pages on your site, top search engine key words, and the growth in your site traffic over time. These logs are also one factor used for our billing processes for some hosting plans.
The logs are standard “common log format” logs and contain information including the hostname and/or IP address of visitors to your site, the request page URL, date and time of the request, size of the request, status (e.g. successful, page not found) and referring URL (if provided).
Use of your personal information
Under no circumstances will your personal information be sold to any outside organisation. We do not share or distribute mailing lists, user lists or other databases of our client details. (If you are registering a domain name, please see the important information below.)
Your details are treated with the utmost privacy and respect. We do not send regular advertising material or subscribe you to any on-going mailing list, electronic or otherwise.
We may occasionally contact you to inform you of any changes to the service or any new services we think you may be interested in.
We may disclose some aspects of the information you provided to us to some of our service providers under specific situations for the purposes of delivering the services to you. This may include:
- passing certain details about the nature of your account to third party help desk and technical support organisations for the purpose of responding to technical issues with your account;
- obtaining a credit reference or rating for your account;
- passing your contact and service details to our solicitors and/or a third party collection agency for the collection of overdue amounts owed to us.
Maintenance of your information
Should you need to update any personal information you have previously provided to us, a secure online service is available from our web site to do this via the Customer Service facility on our web site. You can also contact us to amend your details at any time.
It is important your contact information is kept up-to-date as we rely on this to confirm your identity. For example, to reset a password on your account or provide billing details to you, we will need to contact you to confirm your identity. If your current contact details differ from those we have on record, we will need to take further steps to confirm who you are and this may introduce unnecessary delays.
As a Carriage Service Provider under the Telecommunications Act Sublime IP is also required to have accurate contact details for your account while you are using any relevant services (in particular Internet access, telephony, and hosting services).
Note for Domain Name registrants
If you register a domain name, details of the domain name owner will normally be available on a public database on the Internet (maintained by the relevant authority and outside of our control). The registrant’s postal address, telephone number and email address will usually also be made available.
While it is uncommon for information in such registries to be used for marketing or other unintended purposes, we cannot guarantee this will not happen. Most domain name registrations will be in a company name where this information is probably already in the public domain.
However, if you are registering a domain name in your own personal name, for your protection you may prefer not to list a silent telephone number or your home address. We suggest you use a post office box number or equivalent.
If you do not have access to a post box or suitable phone number for the public record, we may be able to act us your authorised agent for the maintenance of the domain name to avoid publication of any sensitive details. Please contact us if you have any specific privacy requirements you wish to discuss.
Requirements of ICANN and most registrar agreements require that the administrative information listed for a domain name be true, correct and kept up to date. Deliberately entering misleading or incorrect information into domain whois records is certainly not recommended and may result in losing your domain license and may even now be a criminal offence in some juristictions including the United States. While you do need to provide real information, there is generally no problem with using a post office box address or mobile phone number which may be beneficial to your privacy while still meeting the requirements for accurate contact information.
Note that providing misleading, inaccurate or out of date information on your domain name registration can be sufficient grounds for the domain name to be de-registered in many cases. This means you may lose the right to the domain name as well as any web or email addresses associated with it. Consequently it is very important to ensure your details are accurate at all times.
If you have any special privacy requirements you wish to discuss, or any concerns about the information you are being asked to provide or have already provided, please contact us for assistance. If your request or query contains or relates to sensitive information, you may wish to send your query directly to:
Sublime IP AG
Complaints about privacy issues
If you have a complaint about our handling of a privacy issue or any privacy-related request you feel requires further attention, please send your request our Privacy Officer at the address above.
As part of our ongoing commitment to ensuring high privacy standards, in July 2002 we elected to voluntarily opt-in to the Privacy Act 1998 (Commonwealth). This may give you additional privacy rights under the Act and a recourse to the Office of the Federal Privacy Commissioner of Australia should you remain dissatisfied.
Useful privacy resources
- The Office of the Federal Privacy Commissioner of Australia (OFPC), a Government body providing advice on privacy issues and dealing with complaints under the Privacy Act 1988.
- The Australian Privacy Foundation, the main non-governmental organisation dedicated to protecting the privacy rights of Australians.
- Online Privacy and Surveillance information provided by Electronic Frontiers Australia, a group committed to protecting and promoting online civil liberties.