Privacy Policy

This Privacy Policy sets out the approach that the Circle Business Consulting Pty Ltd ABN 97 161 069 Trading as Telco Broker and its Related Bodies Corporate (together Telco Broker) will take in relation to the treatment of personal information.

It includes information on how Telco Broker collects, uses, discloses and keeps secure individuals’ personal information. It also covers how Telco Broker makes the personal information it holds available for access to and correction by the individual.

This policy has been drafted having regard to Telco Broker’s obligations under the Telecommunications Act 1997 and the Privacy Act 1988 as amended from time to time (including the National Privacy Principles or Australian Privacy Principles as applicable) (the Privacy Act). For the purposes of this Privacy Policy, “personal information” has the same meaning as given in the Privacy Act.


1.1 Telco Broker will only collect personal information where Telco Broker considers that the information is necessary for Telco Broker to perform one or more of its functions or activities. In this context, “collect” means to gather, acquire, or obtain by any means information for the purpose of recording it.

1.2 Telco Broker collects Personal information primarily to: supply customers with the products and services ordered from it and related companies. Telco Broker also collects and uses Personal information for secondary purposes, including:

(i) supply customers with the products and services ordered from it and related companies

(ii) billing and account management;

(iii) Consulting, management or procurement services Telco Broker also collects and uses personal information for secondary purposes, including:

(iii) to provide individuals with information about promotions, as well as additional products and services, and the products and services of other Telco Broker companies and other organisations; and

(iv) research and reporting in connection with users use of Telco Broker’s services and transactions relating to Telco Broker’s services.

The type of information collected will depend on the goods or services Telco Broker is asked to provide, and may include, without limitation, names, addresses, telephone numbers, email addresses, gender, date of birth, age-group, personal interests, and records of your correspondence with us. Telco Broker will collect such information if you elect to provide your information to Telco Broker.

Other examples of when Telco Broker may collect personal information are:

  • when an individual completes the ‘mandatory fields’, which will enable your specific request to be processed; and
  • When a purchase is made via the Telco Broker website

Telco Broker may collect data relating to internet traffic activity undertaken via its products and services using tracking technologies such as cookies. Telco Broker generally uses this information to report statistics, analyse trends, administer its services, diagnose problems, and target and improve the quality of our products and services. To the extent this information does not constitute personal information, the Privacy Act does not apply, and Telco Broker may use this information for any purpose and by any means whatsoever. To the extent that such information does constitute personal information, Telco Broker will store and disclose that information in accordance with this privacy policy.

1.3 From time to time, Telco Broker may also receive information relating to you that we have not requested (Unsolicited Information). In the event that Telco Broker does receive Unsolicited Information, we will check whether it is reasonably necessary for us to keep it. If it is, we will treat the Unsolicited Information in the same way as other personal information that we requested you provide to us. If Telco Broker determines that it is not reasonably necessary for us to keep it, we will, as soon as practicable, destroy or de-identify the relevant Unsolicited Information.

1.4 Unless it is obvious in the circumstances, Telco Broker will notify individuals (including, but not limited to, our users) of the matters listed below, amongst other things, before collecting any personal information:

(i) the main reason that we are collecting Personal information (this reason will be the Primary Purpose);

(ii) other related uses or disclosures that we may make of the Personal information (Secondary Purposes);

(iii) our identity and how individuals can contact us;

(iv) that individuals can access the personal information that Telco Broker holds about them;

(v) that individuals should contact us (even if they are not a customer) if they wish to access or correct personal information collected by us, or have any concerns in relation to personal information;

(vi) where applicable, any law that requires the personal information to be collected (for example, information that is required to be collected for the Integrated Public Number Database, which is used by directory publishers);

(vii) the consequences (if any) for the individual if all or part of the personal information is not provided to Telco Broker ;

(viii) if Telco Broker is likely to disclose the personal information to overseas recipients,

the information listed above is collectively the Collection Information.

1.5 Telco Broker will use reasonable endeavours to provide you with the Collection Information when it receives Unsolicited Information.

1.6 Where it is not practicable for Telco Broker to notify individuals of all of the Collection Information before the collection of personal information, Telco Broker will ensure that individuals are notified of the Collection Information as soon as possible after the collection. Telco Broker will provide “post collection notification” in those circumstances where it is not practicable to notify individuals about the collection of their personal information before it is collected.

1.7 Telco Broker will not collect Sensitive Information from individuals except with consent and only where it is necessary for Telco Broker to collect such information for an activity or function.

1.8 Telco Broker will only collect personal information via lawful and fair means.

1.9 While Telco Broker endeavours to collect personal information from the individual involved, in some instances it may also receive personal information from third parties.

In the unlikely event where Telco Broker receives, (and retains) or uses personal information from third parties, it will attempt to contact the individual and advise that it holds this information.


2.1 Telco Broker may hold your personal information in electronic or hard copy form or both. Unless we are required by law or court or tribunal order to retain your personal information, we will take reasonable steps to destroy or de-identify it once we no longer need it.

2.2 From time to time, Telco Broker may also need to transfer your information overseas. For example, we may store your personal information in a cloud, or other type of networking electronic storage which is based in a jurisdiction outside Australia. If we do this, Telco Broker will ensure reasonable steps are taken so that the overseas recipient does not breach the Privacy Act or the Australian Privacy Principles in relation to that information, or adheres to laws substantially similar to Australian privacy laws. Telco Broker will also take reasonable steps to prevent unauthorised access and reduce the risk of disclosure to unknown entities.

2.3 Telco Broker will obtain an individual’s consent for use of non-sensitive personal information for Secondary Purposes at the time of collection, unless the use is a related Secondary Purpose that would be within the relevant individual’s reasonable expectations.

2.4 Telco Broker uses personal information primarily for the purposes listed in 1.2 above.

2.5 Where personal information (other than sensitive information) is used for Direct Marketing, you can opt out of receiving this information at any time by notifying us.

2.6 Telco Broker will not use Sensitive Information for Direct Marketing except with consent.

2.7 Telco Broker may otherwise use your personal information as permitted by law. For example, if we are legally required to do so (such as pursuant to a court or tribunal order or under taxation laws), if there is a serious threat to an individual’s health or safety, there is reasonable suspicion of unlawful activity, for the conduct of surveillance and intelligence gathering by an enforcement body, or to assist in locating a missing person.

2.8 Telco Broker will not use personal information without taking reasonable steps to ensure that the information is accurate, complete, and up to date.


3.1 Telco Broker may disclose personal information to related or unrelated third parties if consent has been obtained from the individual or it is otherwise permitted to do so by law. For example, Telco Broker may disclose personal information to law enforcement agencies, government agencies, courts or external advisers or to avoid an imminent threat to a person’s life or to public safety.

3.2 Telco Broker may disclose personal information between Related Bodies Corporate. Where information is disclosed to such a Related Body Corporate, that Related Body Corporate is bound by the original Primary Purpose for which the information was collected.

3.3 Telco Broker may disclose personal information to unrelated third parties to enable outsourcing of functions (such as billing), where that is disclosure or use for a related secondary purpose and individuals have been notified, or where such disclosure is within the individual’s reasonable expectations. Individuals will be notified of Telco Broker ‘s usual disclosures via the Collection Information.

3.4 Telco Broker will take all reasonable steps to ensure that its contracts with third parties include requirements for third parties to comply with the use and disclosure requirements of the Privacy Act.

3.5 If a disclosure is not for a Primary Purpose; is not for a related Secondary Purpose; or upfront consent has not been obtained, Telco Broker will not disclose personal information otherwise than in accordance with the exceptions set out in paragraph 3.1 above.

3.6 Telco Broker does not generally sell or share its customer lists on a commercial basis with third parties but if it did, it would only do so if it had the appropriate consent of the individual involved. If the consent provided is conditional, Telco Broker will take steps to ensure (by contract) that the use of its customer list by third parties does not exceed the scope of the consent.


4.1 Telco Broker will review, on a regular and ongoing basis, its collection and storage practices to ascertain how improvements to accuracy can be achieved.

4.2 Telco Broker will take reasonable steps ensure that your personal information we hold about you is accurate, up-to-date and complete.


5.1 Telco Broker has physical, electronic, and procedural safeguards for personal information and takes reasonable steps to ensure that personal information is protected.

5.2 Electronic records are stored within our electronic database that requires passwords for access.

5.3 Paper records are stored within secure premises. Externally, the premises have several barriers to unauthorised entry, including secured entry and monitored alarms. Internally, steps are taken to ensure access to personal information is limited, including filing in a locked cabinet within a secured office.

5.4 Telco Broker requires employees and contractors to perform their duties in a manner that is consistent with Telco Broker ‘s legal responsibilities in relation to privacy.

5.5 Telco Broker will take all reasonable steps to ensure that paper and electronic records containing personal information are stored in facilities that are only accessible by people within Telco Broker who have a genuine “need to know” as well as a “right to know”.


6.1 Telco Broker will allow its records containing Personal information to be accessed by the individual concerned in accordance with the Privacy Act.

6.2 Telco Broker will correct its records containing personal information as soon as practically possible, at the request of the individual concerned in accordance with the Privacy Act. If we are unable to correct your personal information, we will, within a reasonable period, provide you with a written notice setting out the reason why we cannot correct your personal information and the complaint mechanisms open to you.

6.3 Individuals wishing to lodge a request to access and/or correct their personal information should do so by contacting Telco Broker, as per the details on the website. While some requests for access may be handled by Customer Service, it may be necessary for your request to be escalated to the Telco Broker Customer Relations Group.

6.4 Telco Broker will not normally charge a fee for processing an access request unless the request is complex or is resource intensive. Telco Broker does, however, reserve the right to charge a $25.00 administration fee if an individual requests access to their personal information more than once in a three-month period.

6.5 Where Telco Broker offers on-line account management facilities, customers can use this capability to control aspects of their account, including amending or updating certain Personal information.


7.1 Telco Broker’s Customer Service representatives will be the first point of contact for inquiries about privacy issues. Individuals wishing to make an inquiry or complaint regarding privacy should do so by contacting Telco Broker via ( or on our website. (

7.2 Privacy complaints will be managed in accordance with Telco Broker ‘s Complaint Handling Policy, which complies with the C628:2007 Telecommunications Consumer Protections Industry Code (as amended from time to time).

7.3 Telco Broker websites will contain a prominently displayed privacy statement and will include a copy of this Privacy Policy.

7.4 You may also lodge privacy complaints with the Federal Privacy Commissioner. For more details on how to do this, please visit


8.1 Telco Broker will not make it mandatory for visitors to its web sites to provide personal information unless such personal information is required to answer an inquiry or provide a service. Telco Broker may, however, request visitors to provide personal information voluntarily to Telco Broker (for example, as part of a competition or questionnaire, or request of service). Where you are updating your account, requiring a service or making a purchase, the provision of some personal information will be mandatory.

8.2 Telco Broker will allow its customers to transact with it anonymously or use a pseudonym wherever that is reasonable and practicable.


Other matters that you should consider in relation to your personal information online are set out below.

i. Social Media. Our website may contain links to online forums such as Meta, LinkedIn and X. Think carefully before you post or publish any personal information in these forums as it will be publicly available.

ii. Links to other websites. Sometimes our website contains links to third party websites, for further information about a venue or event. We recommend that you review the privacy policies of each site you visit because Telco Broker is not responsible for privacy practices of that site.


If you are a vendor who makes available products and services for sale via the Telco Broker service, you will:

(i) provide a privacy policy setting out how you collect, use, disclose and keep secure individuals’ personal information; and

(ii) comply with the Privacy Act and equivalent laws in the territory of your residence, incorporation or operation in respect of the use of personal information of Buyers


Direct Marketing means the marketing of goods or services through means of communication, including written, verbal or electronic means. The goods or services that are marketed may be those of Telco Broker or a Related Body Corporate, or those of an independent third-party organisation.

Related Body Corporate means that where a body corporate is:

(a) a holding company of another body corporate;

(b) a subsidiary of another body corporate; or

(c) a subsidiary of a holding company of another body corporate,

(d) the first mentioned body corporate and the other body corporate are deemed to be related to each other.

Sensitive Information means:

(a) information or an opinion about an individual’s:

(i) racial or ethnic origin; or

(ii) political opinions; or

(iii) membership of a political association; or

(iv) religious beliefs or affiliations; or

(v) philosophical beliefs; or

(vi) membership of a professional or trade association; or

(vii) membership of a trade union; or

(viii) sexual preferences or practices; or

(ix) criminal record that is also personal information; or

(x) health

“Use” means the handling of personal information within Telco Broker.

Last updated: January 2024