Overview

Our mission at Cooee is to help Australians stay connected to home. Protecting your privacy and keeping your information secure is critical for us.

This policy explains what information we collect about you and how we use, hold and share it.  This policy applies to MLKA Limited and all Cooee Products and to the information collected by the Cooee Team.  We may update this policy from time to time and any updates to this policy become effective when published on our website.  When subscribing to Cooee you agree that we can use information about you in accordance with this policy. 

Type of information we collect about you

• We commit to only collecting information we need to provide you with the service, information required by the Australian Communications and Media Authority(ACMA), or with the operator of the Integrated Public Number Database (IPND)to assist with the provision of directories, emergency services and safeguard national security.

• If you do not provide certain information that we may require, we may not be able to provide you the service as described, or restrict the service until required information is provided

• The information we collect and hold includes information about you: 

  • Identifiers such as your name, date of birth, registered address, social media login, email address, passwords, partial payment details and documents that verify your identity, as well as

  • User Images for the purposes of supporting identity verification and confirming physical possession of identification documentation

  • Information about how you use our app

  • Information about the subscription you have with us

  • Information about the device you use to access our app, including the model of the device, the operating system version, the unique device identifier, the IP address, and the mobile network information. This information helps us to provide and improve our services, troubleshoot technical issues, and analyze usage trends. We may also use this information for advertising and marketing purposes as described in this Privacy Policy.

  • Data relating to your administrative use of our services, such as account and payment information. 

Please note we do collect your contact list information to enable us to connect you with your friends and family members through our app. We do not share your contact list information with any third-party companies or advertisers.

We use your contact list information solely for the purpose of enabling you to use our app and to provide you with a better user experience. We do not sell your contact list information to anyone.

How we collect your information

Directly from you when you:

• Interact with us via your mobile device, over email or through our website, apps, or social media.

• Automatically through your use of our network, products or services

• When you interact with our websites, mobile sites, apps, electronic communications and other online products and services, we or our service providers may use cookies and other similar technologies to collect information about you

• Service providers that work with Cooee, like companies that help us provide products and services to you, or identity and fraud checking services, or analytics and advertising-related services (including ad-serving/targeting platforms).

How we use your information

Administration and business operations

• Providing our products or services (and those of our business partners), communicating with you, managing your account and billing, and delivering customer or technical support.

• Developing, operating and improving our network, product, service, apps, content offerings and business processes.

Security and verification purposes.

• Identity checks or internal investigations, including in relation to fraud and crime.

Marketing

• Communicating with you to market products and services we think might interest you (including those from our selected partners).   

• Developing products and services that may be of interest to you.

• Communicating with you when you have previously expressed an interest in our products or services (e.g. when you have explored a new type of product on our website

Analytics 

• Deriving insights about you and who you interact with to identify market segments, market products and services, or carry out market research.

• Assessing the effectiveness of our marketing campaigns to optimise our marketing spend and to personalise our products, services, and marketing messages.

• Analysing ratings information and anonymous viewing and/or browsing data to understand how you and others engage with our products and services (including our content services).

• Supplementing, matching and analysing information about you with information from third party sources (e.g. from Meta or Google) to learn more about your preferences and interests and to create aggregated market segments.

Relevant advertising

• Delivering targeted advertising or other content which might interest you via websites, apps, online services and content


Compliance

• Using your information as otherwise required or permitted by law.

When we share your information

We share your information with our business partners and selected third parties for the purposes outlined above, including:

• Our service providers to diagnose service interruptions or service quality issues 

• Other telecommunications companies (e.g. to administer number portability requests).

When we share your information, we put measures in place to ensure it is kept confidential, used securely and only used for the purposes outlined above. We will not otherwise sell or share information that directly identifies you with any third-party for commercial purposes, unless you give us your express consent. 

However, for commercial purposes, we may de-identify your information and share it so that our business partners may combine it with other information. We also share your information:

• To comply with our legal obligations in response to warrants, subpoenas or similar lawful requests for this information (including from credit reporting bodies).

• With government and regulatory authorities and law enforcement agencies, as required or authorised by law.

• With the operator of the Integrated Public Number Database to assist with the provision of directories, emergency services and safeguard national security.

• With directory producers when you elect to have your information disclosed to such organisations.  For example, if you choose to have a listed number.

Your privacy options

You can review and update your account information by logging in to your account using your username and password. Additionally, you can control whether you want to receive marketing messages and targeted online advertising from Cooee or our partners.

You can also request for the  deletion of your information by submitting a service request via our app and website. Information such as Social ID, usernames, passwords and payment details can all be deleted. IPND regulations stipulate that certain information must be retained including full name, email address, registered address and identification documents.

If you would like to manage the way we use browser or device information for relevant advertising, you may do so on your device or browser settings.

How we secure & protect your information

We take the protection and security of your information very seriously.  We’ll continue to review and improve our security measures to ensure your information remains protected. Some of the measures we currently take include:

• Providing account IDs and passwords, as well as asking for information about you to confirm your identity when you contact us or log into our system.

• Following the Payment Card Industry Data Security Standard (PCI DSS) when handling credit card data.

• Using firewalls, virus scanning and access logging tools and encrypting data to protect against unauthorised access to your data and our network.

• Using secure work (and sometimes closed) environments and workflow systems to prevent unauthorised access and copying of your personal information.

• Managing access privileges to ensure that only those who really need it can see your personal information.

• Ongoing security reviews.

How to access, update and delete your personal information

For simple updates, you can use our application to view and update your account information, such as your contact and payment details.  

You are able to request a deletion of your personal information held by Cooee. To request a deletion, please submit a deletion  request via the App or Website from the Support Ticket Menu. 

However, it is worth noting that not all of your personal information can  be deleted, particularly due to regulatory requirements that legally oblige MVNO providers  to retain. For example the Telecommunications Interception and Access Act 1979 (Cth) and IPND guidelines may require us to hold some of your personal information for a period of time. IPND regulations also stipulate that certain information must be retained including full name, email address, registered address and identification documents.

How to contact us

If you have a question regarding this policy, a complaint about how we handle your information, or wish to make a complaint, please Contact Us via our website If you make a complaint, we’ll acknowledge receipt and aim to investigate and respond to you within 30 days or earlier. If we can’t resolve your complaint, you may contact the Office of the Australian Information Commissioner or where appropriate, the Telecommunications Industry Ombudsman