Privacy Policy
This Privacy Policy applies to all personal information collected by Oncall Language Services Pty Ltd (ACN 151 001 777) via the website located at https://captionconnect.com.au/ and through the CaptionConnect software platform.
1. What is “personal information”?
(a) The Privacy Act 1988 (Cth) currently defines “personal information” as meaning information or an opinion about an identified individual or an individual who is reasonably identifiable:
- (i) whether the information or opinion is true or not; and
- (ii) whether the information or opinion is recorded in a material form or not.
(b) If the information does not disclose your identity or enable your identity to be ascertained, it will in most cases not be classified as “personal information” and will not be subject to this privacy policy.
2. Scope of this Policy
This policy outlines our practices across:
- Website visitors: Users interacting with https://captionconnect.com.au
- CaptionConnect software users: Users of our real-time captioning and translation software, including enterprise clients and their authorised users (e.g. students, patients, event attendees)
Additional data processing specific to CaptionConnect software is outlined in section 4.1.
3. What information do we collect?
The kind of personal information we collect depends on your interaction with us.
(a) Website usage:
We may collect:
- (i) Name
- (ii) Email address
- (iii) Telephone number
- (iv) Postal address
- (v) Patterns and history of website usage
(b) CaptionConnect software usage:
We may collect:
- (i) Audio data provided for transcription or translation
- (ii) Real-time text transcripts and subtitles
- (iii) Language selections and session metadata
- (iv) Device/browser information for performance monitoring
- (v) Any personal information voluntarily disclosed through speech or text in the platform
4. How we collect your personal information
(a) We may collect personal information from you when you:
- (i) input such information into the website;
- Use the CaptionConnect software (as an end user or admin)
- (ii) register online or place any order for our products or services;
- (iii) complete a customer survey or provide feedback; or
- (iv) interact with our employees, officers, or agents by email, online forms, telephone, and other means.
We also collect cookies from website visitors (see section 4.2).
4.1 Use of AI in CaptionConnect Software
CaptionConnect uses Artificial Intelligence (AI) technologies, including Machine Learning (ML), Language Models (LM), and Large Language Models (LLMs) to deliver speech-to-text and translation functionality.
We collect and process data (including audio and text) solely for the purpose of providing accurate and real-time captioning, translation, and transcripts.
- Data may include personal information if users speak names, locations, or identifiable content.
- We do not use data from the software to train or improve public AI models.
- All data is handled in secure environments and may be processed by trusted third-party providers strictly for delivering CaptionConnect services.
- Enterprise customers are responsible for ensuring appropriate notices are provided to their end users.
4.2 Cookies
We use cookies on the CaptionConnect website (https://captionconnect.com.au) to enhance your browsing experience, analyse website traffic, and support website functionality. These cookies may be used to:
- Maintain your session (e.g. keeping you signed in)
- Understand how you interact with our website
- Troubleshoot issues and optimise performance
- Deliver targeted advertising via third-party providers
Cookies may collect information such as your IP address, browser type, device ID, and pages visited. This information is used in accordance with our Privacy Policy and may be shared with third-party analytics or advertising services such as Google Analytics.
You can manage or disable cookies through your browser settings. Please note that disabling cookies may impact the functionality of our website.
Important: Cookies are not used within the CaptionConnect software platform itself. No cookies are set or collected during use of the real-time captioning and translation service. CaptionConnect software operates independently of web-based tracking technologies and does not passively collect usage data through cookies.
4.3 Sub-Processors
To deliver our services, CaptionConnect engages carefully selected third-party sub-processors who process limited personal data on our behalf. These sub-processors are contractually obligated to maintain confidentiality and adhere to security and privacy obligations consistent with applicable laws.
| Sub-Processor | Purpose/Description | Data Types Processed | Data Location(s) | Policy Link |
|---|---|---|---|---|
| Amazon Web Services (AWS) | Hosting infrastructure, compute & storage | Audio data, transcripts, metadata, IP | Australia (default), Global (failover) | https://aws.amazon.com/privacy/ |
| Microsoft Azure | AI transcription & translation (Speech services) | Audio data, speech-to-text transcripts | Australia | https://privacy.microsoft.com/ |
| CrowdStrike | Endpoint protection and security monitoring | Device metadata, user interaction logs | United States | https://www.crowdstrike.com/privacy-notice/ |
5. Purpose of collection
(a) The purpose for which we collect personal information is to provide you with the best service experience possible on the website.
(b) We customarily disclose personal information only to our service providers who assist us in operating the website. Your personal information may also be exposed from time to time to maintenance and support personnel acting in the normal course of their duties.
(c) By using our website, you consent to the receipt of direct marketing material. We will only use your personal information for this purpose if we have collected such information direct from you, and if it were material of a type which you would reasonably expect to receive from us. We do not use sensitive personal information in direct marketing activity. Our direct marketing material will include a simple means by which you can request not to receive further communications of this nature.
(d) For CaptionConnect software users we capture personal information to deliver services to customers and users.
We may disclose data to service providers involved in hosting, AI processing, or analytics, all bound by confidentiality and privacy obligations.
We do not use sensitive personal information for marketing.
6. Privacy policies of third parties
The website contains links to other websites. Our privacy policy applies only to our website and the CaptionConnect software. If you click on a link to another website, your access and personal information is governed by the terms and conditions and the privacy policy of the third-party website. You are solely responsible for ensuring that you read and check that their privacy policy is acceptable to you.
7. Access and correction
Australian Privacy Principle 12 permits you to obtain access to the personal information we hold about you in certain circumstances, and Australian Privacy Principle 13 allows you to correct inaccurate personal information subject to certain exceptions. If you would like to obtain such access, please contact us as set out below.
8. Complaint procedure
If you have a complaint concerning the manner in which we maintain the privacy of your personal information, please contact us as set out below. All complaints will be considered by our Data Protection Officer and we may seek further information from you to clarify your concerns. If we agree that your complaint is well founded, we will, in consultation with you, take appropriate steps to rectify the problem. If you remain dissatisfied with the outcome, you may refer the matter to the Office of the Australian Information Commissioner.
9. Data Transfer and Storage for Australian Customers
Your personal information is stored within Australia and may be transferred or disclosed to third parties within Australia for the purposes of processing, customer support, and other functions related to our services. We ensure that any such third parties are obligated to protect your personal information in accordance with the Australian Privacy Principles. If these third parties violate these principles leading to a mishandling of your personal information, we will take specific steps such as legal action, termination of contract, or other measures to enforce the protection of your personal information under Australian law.
9.1. Data Transfer and Storage for Overseas Customers
Your personal information may be transferred or disclosed to third parties, including those located overseas, for purposes such as processing, customer support, and other functions related to our services. Due to the global nature of our operations, it is not possible to identify each and every country or third party to which your personal information may be sent. We ensure that any such third parties are obligated to protect your personal information in accordance with the Privacy Principles of the region where the third party is located. If these third parties violate these principles leading to a mishandling of your personal information, we will take specific steps such as legal
action, termination of contract, or other measures to enforce the protection of your personal information under the laws of the region where the third party is located.
10. GDPR
(a) In some circumstances, the European Union General Data Protection Regulation (GDPR) provides additional protection to individuals located in Europe. Where this is the case, there may be additional rights and remedies available to you under the GDPR if your personal information is handled in a manner inconsistent with the GDPR.
(b) Some of the rights you have under the GDPR, where it applies, include:
- (i) Access: you have the right to ask us for copies of your personal data, and we may charge a small fee for this retrieval.
- (ii) Rectification: you have the right to request that we correct any information we hold about you which is inaccurate, as well as completing any information about you that is incomplete.
- (iii) Erasure: you have the right to request that we erase your personal information under certain conditions (e.g. legal requirements for data retention may prevent us from erasing some types of personal information).
- (iv) Restrict or object to processing: you have the right to ask that we restrict the processing of your personal information, or to object to the processing of your personal information, under certain conditions.
- (v) Portability: you have the right to ask us to transfer the personal information that we have about you, to another organisation or directly to you, under certain conditions.
(c) If you make any requests outlined above, you can contact us at the details below, and we will have one month to respond to you.
11. Data Retention
We retain personal information collected through CaptionConnect only for as long as necessary to fulfil the purposes for which it was collected, including service delivery, support, compliance with legal obligations, or as agreed with the customer (e.g. a school or education provider).
- Transcripts and session data may be stored temporarily to enable review, editing, and publishing by authorised users.
- User account information (such as name and email address) is retained for the duration of the user’s account access.
- Upon request by an organisation, data can be deleted earlier or retained for longer if required under contractual or legal obligations.
All data retention is managed in accordance with applicable privacy laws and data governance policies.
12. How to contact us about privacy
If you have any queries, or if you seek access to your personal information, or if you have a complaint about our privacy practices, you can contact us through: [email protected].