Pilot Privacy Policy

# First Families Pilot — Privacy Policy

**Effective Date:** 13 April 2026
**Last Updated:** 13 April 2026

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## 1. About This Policy

This Privacy Policy explains how **Landie Communications Pty Ltd** (ABN 71 691 334 291) ("we," "us," "our") collects, uses, and protects personal information in connection with our First Families Pilot program and the Home Phone device and calling service provided as part of the pilot.

We comply with the *Privacy Act 1988* (Cth) and the Australian Privacy Principles (APPs), and we follow guidance from the Office of the Australian Information Commissioner (OAIC) and the *Online Safety Act 2021* (Cth).

By joining the First Families Pilot, you agree to the collection and use of information as described in this Privacy Policy.

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## 2. Information We Collect

### From Parents (during signup and support)

- Name
- Email address
- Shipping address
- Child's first name
- How you heard about the pilot (referral source)
- Any support emails or messages you send to us

### From the Device and Calling Service

- Call log metadata generated by our telecommunications provider, Twilio (e.g., calling and called numbers, timestamp, call duration)
- Basic technical diagnostics (connectivity status, error events) for troubleshooting

### What We Do Not Collect

- No call audio is recorded or retained
- No precise location data, photos, biometric data, or user-generated content is collected
- No data is collected directly from children

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## 3. How We Use Your Information

We use the information we collect to:

- Ship your Home Phone to you
- Set up and operate your phone and calling service through Twilio and the public telephone network (PSTN)
- Register your address with our telecommunications provider for emergency calling (000)
- Communicate setup instructions, updates, and safety information
- Monitor service performance and resolve technical issues
- Request occasional feedback about the pilot (you are not obligated to respond)
- Comply with legal and safety requirements under Australian law

We will not use your information for any purpose other than operating the pilot program and communicating with you about it.

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## 4. Children's Information

- The Home Phone is designed for children under the supervision of a parent or guardian.
- We collect only the child's first name (provided by the parent during signup) for the purpose of personalising communications.
- We do not collect information directly from children.
- We do not record or monitor conversations.
- The child's assigned phone number is not published or shared.

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## 5. Disclosure of Information

We may share your information only with:

- **Twilio** — our telecommunications provider, which routes calls and provides VoIP/PSTN connectivity. Twilio may process data outside Australia, including in the United States. Your registered address is provided to Twilio for emergency calling purposes.
- **Shopify** — our website platform, which processes signup form data. Shopify may store data outside Australia, including in Canada and the United States.
- **Klaviyo** — our email communications platform, which processes email addresses on our behalf. Klaviyo may store data outside Australia, including in the United States.
- **Professional advisers** — legal, accounting, or insurance advisers where necessary.
- **Regulators or law enforcement** — where required by law.

We do not sell, rent, or share your personal information for marketing purposes.

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## 6. Emergency Calling (000)

Your Home Phone supports 000 emergency calling. The address you provide during signup is registered with our telecommunications provider and made available to emergency services.

**Important:**

- If your Home Phone is moved to a different address, you **must** update your registered address by emailing us at info@landie.com.au. Failure to update your address may result in emergency services being directed to the wrong location.
- Emergency calling requires a working Wi-Fi connection and active internet service. If your internet or power is out, 000 calls cannot be made from the Home Phone.
- The Home Phone uses Voice over IP (VoIP) technology. Emergency calling via VoIP may not operate identically to traditional landline emergency calling.
- We strongly recommend that every household maintains an alternative means of contacting emergency services (such as a mobile phone).

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## 7. Cookies and Website Data

Our website uses essential cookies for site functionality and may use analytics cookies (such as those provided by Shopify) to understand how visitors use our site. You can disable cookies through your browser settings.

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## 8. Data Security

We take reasonable steps to protect your personal information from misuse, interference, loss, unauthorised access, modification, and disclosure. Data is transmitted using industry-standard encryption (SSL/TLS) and access is restricted to authorised personnel.

Parents should keep their home Wi-Fi network secure and supervise child use.

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## 9. Data Retention and Deletion

- **Call log metadata:** retained for up to 90 days, then deleted or anonymised unless needed for legal purposes.
- **Support communications:** kept for up to 12 months after the pilot ends, then securely deleted.
- **Diagnostics data:** purged automatically on a rolling basis.
- **Signup information (name, email, address):** retained for as long as your Home Phone is active. You may request deletion at any time (see Section 11).

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## 10. Your Rights

Under the Australian Privacy Principles, you have the right to:

- **Access** the personal information we hold about you
- **Request correction** of any inaccurate or incomplete information
- **Request deletion** of your personal information
- **Opt out** of receiving non-essential communications from us

To exercise any of these rights, please contact us using the details in Section 12.

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## 11. Direct Marketing

We do not direct-market to children. You may receive pilot updates, product announcements, or safety notices. You can opt out of non-essential communications at any time by contacting us.

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## 12. Contact Us

If you have any questions, concerns, or complaints about this Privacy Policy or our handling of your personal information, please contact us:

**Landie Communications Pty Ltd**
Email: info@landie.com.au

We will acknowledge your enquiry and aim to respond within 30 days.

If you are not satisfied with our response, you may contact the **Office of the Australian Information Commissioner (OAIC)**:
- Website: www.oaic.gov.au
- Phone: 1300 363 992

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## 13. Changes to This Policy

We may update this Privacy Policy from time to time. Any changes will be reflected by an updated "Last Updated" date at the top of this page and communicated to pilot families via email.