Legal

1. The complaint

• A complaint can be made by letter, email, by video or in person.
• Complaints should be sent to: 
  Chief Executive Officer
  Convo Communications Australia Pty Ltd
  C/- BDO Services Pty Ltd
  Collins Square, Tower Four
  Level 18, 727 Collins Street
  Melbourne, Victoria 3008
  
  Complaints by email should be sent to feedback@convoaustralia.com
• When received, all complaints will be logged and passed to the senior member of staff in the relevant service area.
• All complaints will be acknowledged by letter, email or video, as appropriate, within 48 hours.
• All complaints will initially be investigated at a local level.
• At any time should the investigation uncover information that suggests a complaint of a serious nature, the decision may be taken to pass the complaint directly to an external body for investigation. If this decision is taken, all involved parties will be informed in writing. 

2. Initial Investigation

• The senior member of staff will investigate the complaint to the best of their ability. This will always involve contacting all relevant parties and where necessary may include input from other staff members, professionals or independent professional bodies.
• The senior member of staff will provide a full response to the complaint within 28 working days, in an appropriate format.

3. Further Investigation

• If for any reason the complainant is not satisfied with the initial investigation, they should then contact the Chief Executive Officer again. This can be in the form of a letter, email or video and should explain in detail any areas of the initial investigation that do not satisfy the complainant, and why.
• Any such complaints will be acknowledged by letter, email or video, as appropriate, within five working days.
• The Chief Executive Officer will conduct a further investigation of the complaint.
• The initial investigation will be reviewed, and all concerned parties may be contacted to confirm - or to provide further - information. In addition, the following may be contacted as appropriate:
  • staff members not directly involved with the service professionals
  • independent professional bodies
  • The Directors of Convo Australia and/or Convo Global
  • A full response will be made either by the Chief Executive Officer or Senior staff member within 28 working days, in an appropriate format

3a. External Investigation

• If for any reason the complainant is not satisfied with the further investigation, they should again contact the Chief Executive Officer via letter, email or video, requesting that the complaint is passed to a relevant external body.
• Complaints that cannot be settled through the above procedure will be passed to the relevant external body. All involved parties will be informed in writing.
• Relevant external bodies will be determined by the nature of the complaint, for example: 
  
  NDIS Quality and Safeguards Commission
  NAATI with regard to interpreting services 
  Convo Australiaʼs HR Consultancy
  Convo Australia Company Lawyer 
  Fair Work Commission with regard to equal opportunities and workplace issues
• Documentation regarding the initial and further investigations, as well as any previous correspondence, will be made available to the external body undertaking the investigation.

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Privacy Policy

Convo Communications Australia Pty Ltd (“Convo”) is committed to protecting your privacy. This privacy policy describes the information Convo collects from its customers through its websites and through our business functions, how we use and protect such information, and to whom and underwhat circumstances we disclose such information. By using our Websites and by disclosing information to us in furtherance of our business relationship, you signify your agreement to this
Privacy Policy.

1. What Information Do We Collect?

i. Personal Information
In general, Convo collects personal information from you when you voluntarily provide it to us by (1) registering on any of our Websites; (2) signing up to enter a promotion, participate in an event or survey, receive newsletters or other literature; (3) making product or service inquiries; (4) contacting us (including our webmaster, customer service representatives, or other employees) by e-mail or Live Chat; or (5) providing other personal information to us in furtherance of our business relationship. In connection with these activities, we may collect personal information from you, including, but not limited to, your name, physical address, email address, age, gender, contact numbers, user name and/or password associated with the use of any our Websites or web portal(s), occupation, whether you are a Convo customer, the type of product you are seeking, how you use the Video Relay Interpreting Service, how you heard about Convo, or other information necessary to conduct business with you. We do not allow third-parties to collect personal information directly from the use of our Websites.

Upon registration for a new account, Convo asks for your 1) status as a deaf or hard of hearing person; 2) name; 3) e-mail address; 4) consent to receive communications from Convo.

ii. National Disability Insurance Scheme (“NDIS”)
As part of the standard operation of our service for participating NDIS customers, we will collect additional information from you in addition to your personal information you have registered with the NDIS. Information to include, 1) your plan number; 2) your plan start date; 3) service option (plan); 4)names and contact details of your plan manager, local area coordinator and/ or NDIS support coordinator; and 5) consent agreement to service agreement.

iii. Non-Personal Information
As part of the standard operation of our Websites, we may collect/obtain certain non-personal information from you, including, but not limited to, your browser type (e.g. Chrome or Internet Explorer), operating system (e.g. Windows or Macintosh), Internet Service Provider (ISP), IP address, Websites visited, and domain name from which you accessed the website (e.g. Yahoo.com). In addition, we may collect information about your browsing behaviour, such as the date and time you
visit our Websites, the areas or pages of our Websites that you visited, the amount of time spent viewing our Websites, the number of times you returned to our Websites, and other click-stream data. We may use cookies to collect this information, which may be combined with your personal information. A cookie is a small text file that may be stored on the hard drive of your computer that enables us to recognise your computer when you return to our Websites. You are always free to decline
cookies, but in doing so you may not be able to use certain features on our Websites. The “help” segment of the toolbar on most browsers explains how to configure a browser to not accept new cookies, how to have the browser inform a user when they receive a new cookie, and how to erase cookies from your computer’s hard drive. Further, Convo may use tools like Google Analytics to measure traffic on Convo’s website and apps and how users interact with both. No personally identifiable information may be collected through this software.

iv. Information Collected by Convo During Video Relay Calls
When making video calls through our Video Relay Platform, Convo collects, at minimum, the following information: 1) Customer ID; 2) your registered phone number you used to make your call; 3) the time that the call was connected; 4) the Internet Protocol (IP) address used to make the call, if applicable; and 5) the duration of the call. Convo submits information collected during calls on the accounting database for billing purposes. Convo does not disseminate the information to any other party and does not keep records of the contents of any conversation relayed during the video calls.

How Do We Use Your Information?

Convo maintains the confidentiality of personal information collected from its registered users. From time to time, Convo may use the information we collect from you such as email address or phone numbers for any of the following purposes: 1) to get in touch with you regarding your account or to provide you with updates regarding Convo’s services; 2) to facilitate your use of our Websites and better understand your needs; 3) to fulfill your requests for information about certain products, services, and projects; 4) to send you information, promotional materials, and offers from our company, as well as from our subsidiaries and affiliates; 5) to contact visitors to our Websites when necessary; 6) to help address problems with our Websites; 7) to administer our Websites; 8) to conduct internal reviews of our Websites; 9) to help us better understand visitors’ use of our Websites; 10) to protect the security or integrity of our Websites; 11) to conduct business with you (including obtaining and disclosing credit and billing information); and 12) for such other purposes provided in this Privacy Policy. Non-personal information will be used for these purposes, as well as to monitor our Websites and provide a greater online experience for our visitors. Convo will use, disclose or permit access to your information in strict compliance with the Australian Privacy Act (reference
https://www.oaic.gov.au/privacy/the-privacy-act/).

Will We Disclose Information We Collect From You?

Convo may transfer or otherwise disclose information collected from you to the following entities for the purposes: 1) to Convo’s employees, independent contractors, subsidiaries, affiliates, consultants, business associates, service providers, and suppliers, if the disclosure will enable that entity to perform a business, professional, or technical support function for Convo; 2) to employees, independent contractors, service providers, and suppliers of Convo to fulfill a product or service
request; and 3) to respond to judicial process and provide information to law enforcement agencies or in connection with an investigation on matters related to public safety, as permitted by law. As stated above, Convo will use, disclose or permit access to your information in strict compliance with the Privacy law

Do We Collect Information From Children?

We do not direct our Websites to, nor do we knowingly collect any personal information from, children under the age of 13. The Privacy Act 1988 (Cth) does not specify an age after which an individual can make their own privacy decision. For their consent to be valid, an individual must have the capacity to consent. Convo Australia will handle the personal information of an individual under the age of 18 and will decide if the individual has the capacity to consent on a case-by-case basis. As a general rule, an individual under the age of 18 has the capacity to consent if they have the maturity to understand what’s being proposed. If they lack maturity it may be appropriate for a parent or guardian to consent on their behalf.

Quality Monitoring

From time to time, authorised staff may conduct quality monitoring of live conversation for quality improvement and/or providing support with or without caller’s knowledge. These conversations may be recorded for training purposes only and will not jeopardise the privacy protections outlined in the Privacy Policy

Does This Privacy Policy Cover Practices on Third-Party Websites?

Our Websites may contain links to other third-party Websites, which may have private policies that differ from our own. We are not responsible for the activities and practices that take place on these Websites. Accordingly, we recommend that you review privacy policies posted on any third-party Website that you may access through our Websites.

How Can I Contact Convo?

If you have any questions or concerns about this Privacy Policy, you can contact us at gday@convoaustralia.com.

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SMS Policy

Convo Communications Australia Pty Ltd (“Convo”) is committed to protecting your privacy. This SMS policy (“SMS Policy”) outlines the terms and conditions that govern the use of Short Message Service (SMS) by Convo for communicating with our customers about our products, promotions, interpreting services, and company updates. This SMS Policy governs how Convo treats the Personal Information that we collect and receive from you in connection with your use of the SMS Service (“SMS Service”), which we make available to you through a third party service provider. This SMS Policy is incorporated into Convo’s Legal webpages found at https://convoaustralia.com/legal and is intended to provide guidance on acceptable and prohibited use of SMS for customer communications.

The purpose of this policy is to ensure that SMS is used in a professional, ethical, and lawful manner to communicate with our customers. By using the SMS Service, you agree to the terms of this SMS Policy herein. Convo reserves the right, in its sole discretion, to modify or change this Policy at any time with or without prior notice to you. The date of the last update will be posted at the footer of this SMS Policy for your convenience. This SMS Policy, and any changes, are effective as soon as posted. Your continued use of the SMS Service following the posting of any changes to the Policy constitutes your full acceptance of those changes.

Definitions:

• SMS: Short Message Service, a text messaging service that allows for the sending and receiving of short text messages on mobile devices.
• Sender ID: A unique identifier used to identify the sender of an SMS message. All SMS messages sent by Convo to customers must clearly identify the sender using a unique Sender ID that is associated with Convo.
• Consent: Before sending an SMS message, Convo will obtain consent from the recipient. Consent will be obtained through an opt-in process, or as part of an existing business relationship.

Purpose of SMS Service:

The purpose of SMS Service is to provide our customers (“you”) with: (1) updates regarding Convo's services; (2) to facilitate your use of our services and better understand your needs; (3) to fulfil your requests for information about certain products, services, and projects; (4) to send you information, promotional materials, and offers from our company, as well as from our subsidiaries and affiliates; (5) to contact visitors to our Websites when necessary; (6) to help address problems with our Websites & services; (7) to administer our Websites; (8) to conduct internal reviews of our Websites (e.g., to determine the number of visitors to specific pages within the site); (9) to help us better understand visitors' use of our Websites; (10) to protect the security or integrity of our Websites; (11) to conduct business with you (including obtaining and disclosing credit and billing information); and (12) for such other purposes provided in this SMS and Privacy Policy at https://convoaustralia.com/legal/. Non-personal information will be used for these purposes, as well as to monitor our Websites and provide a greater online experience for our visitors.

Personal Information collected about you:
Through the use of the SMS Service, Convo will receive the following information from our third party service provider: your mobile phone number when you sign up with us, send a text message to us, the text of messages that you send to other users of the SMS Service, any user or screen name that you select in connection with the SMS Service, as well as any comments or feedback regarding the SMS Service that you send to us.

Disclosure of your information:
We will not rent or sell your Personal Information to other companies or individuals without consent. We may use or disclose such information in any of the following limited circumstances:

• We provide such information to trusted businesses or persons for the sole purpose of processing Personal Information on our behalf. When this is done, it is subject to agreements that oblige those parties to process such information only on our instructions and in compliance with this Policy and appropriate confidentiality and security measures. If the third
  party fails to comply with our terms, Convo is not accountable in any way for any liability or reimbursement.
• We provide such information to a company controlled by, or under common control with Convo for any purpose permitted by this SMS Policy.
• When required in response to subpoenas, court orders, or legal process, or to establish or exercise our legal rights, or the legal rights of others, or defend against legal claims.
• When necessary in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of Convo’s Privacy Policy & User Agreement, or as otherwise required by law.

Frequency:

Convo will send SMS messages to customers only when necessary and with a reasonable frequency. Customers have the option to opt-out of receiving SMS messages at any time.

Message Content:

All SMS messages sent by Convo to customers must be professional, courteous, and relevant to the customer. Messages must comply with all applicable laws, regulations, and industry standards and in compliance with our Terms and Conditions and our Code of Conduct for our Customers.

Children:

The SMS Service is not intended for children under 13, and Convo does not knowingly collect information from children under the age of 13. Children aged 13 or older should not submit any Personal Information without the permission of their parents or guardians. By using the SMS Service, you are representing that you are at least 18, or that you are at least 13 years old and have your parents’ permission to use the SMS Service.

Opt-Out:

Customers have the right to opt-out of receiving SMS messages at any time by replying with the word "STOP" to the SMS message. Upon receiving an opt-out request, Convo will remove the customer's phone number from its SMS list and will no longer send SMS messages to that customer for that campaign and/or future Convo product and services.

We reserve the right to send you certain communications relating to the SMS Service, such as announcements and administrative messages, without offering you the opportunity to opt-out of receiving them.

Contact Information:

If you have any questions or concerns about this SMS Policy, you can contact us at gday@convoaustralia.com.

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Code of Conduct

Convo Australia is committed to providing the highest standard of services and upholding the highest standard of safety, dignity and well-being of its employees and customers.

The Code of Conduct (the “Code”) provides guidelines on the standards of conduct and behaviours you can expect from our representatives. This Code outlines the standards of behaviours we expect from our customers to ensure that Convo Australia and their employees can continue the best service possible.

Our commitment to you:

• Act with respect for an individual’s right to freedom of expression, self-determination and decision-making in compliance with any applicable laws and conventions.
• Respect the privacy of all individuals.
• Provide support and services safely and competently, with care and skill.
• Act with integrity, honesty and transparency.
• Promptly take steps to raise and act on concerns about matters that may impact the quality and safety of supports and services provided to individuals.
• Take all reasonable steps to prevent and respond to all forms of violence against and exploitation, neglect and abuse of any individual.
• Take all reasonable steps to prevent and respond to sexual misconduct.
• Ensuring the provisioning of services adheres to professional codes of ethics, conducts and practices including but not limited to the ASLIA Code of Ethics (link to Auslan version) and the AUSIT Code of Ethics.
  
  

Your commitment to Convo Australia:

• No form of harassment, bullying or discrimination will be tolerated.
• Your interactions with our employees and other individuals through our services must be conducted with integrity, respect, and in a non-threatening manner.
• You will respect our employees and other customers' values, beliefs, cultures and religions.
• You will comply with all reasonable instructions our employees give, including all rules governing access to our digital platforms. We will seek to ensure that any such additional rules will be communicated to you.
• You will adhere to relevant legislation (such as road rules and laws) when using our services and digital platforms through any mobile device.
  
  

Consequences of breaching our Code:

We reserve the right to refuse service to anyone who breaches this Code, including disconnecting customers who breach the Code. Repeated or serious breaches of the Code may result in suspension and/or cancellation of the customer’s account.
Any breach of conduct should be reported to the Convo Australia management team. Our team will endeavour to take appropriate corrective action to resolve the breach. Customers may make complaints by submitting written complaints to admin@convoaustralia.com or leaving videos through customer feedback on the Convo Australia app or website (in Auslan).
If the customer is unsatisfied with our response, the customer may complain to the relevant authorities, using the links below which also include their complaint procedure.

• NDIS Quality and Safeguard Commission
• Job Access
• My Aged Care