Privacy Policy

1. Who we are

For the purpose of this Privacy Policy, “you” or “your” means any end user accessing or receiving our services or using our Website (as defined below), and “we” or “us”, “our” or “Touchstream” means Touchstream International Pty Ltd ACN 603 396 112, and our other office branches set out below. Our offices are located at Level 1, 1 Queens Road, Melbourne Victoria 3004 Australia. Our Spanish branch (Touchstream International Pty Ltd, with CIF number W80012091) is located at C/ Balmes, 368, Pr 2a 08006, Barcelona.

2. How we Process Personal Data

This Privacy Policy, any other documents referred to in it, aims to give you information on how and the basis any personal data that we collect from you, or that you provide to us will be processed by us. This Privacy Policy also sets out how you can instruct us if you prefer to limit the use of that personal data, and the procedures that we have in place to safeguard your privacy.

Please read this Privacy Policy carefully to understand our views and practices regarding your personal data and how we collect, use and protect it.

By using or accessing our website www.touchstream.media (“Website”) and OTT Operations Hub platform (“Platform”) or communicating with us, you understand and agree that we will collect and process your personal data in accordance with this Privacy Policy. If you do not agree with this Privacy Policy you must not access or use our Website or Platform or submit information to us through or in connection with our products, services, the Website, Platform or otherwise.

Children’s Privacy

Our Website, Platform and related services are not directed to, or intended for use by, children under the age of 13, or, where applicable under local or state law (including but not limited to the California Consumer Privacy Act, the Texas Data Privacy and Security Act, and similar U.S. state laws), individuals under the age of 16 or 18. We do not knowingly collect, process, share, or sell personal data from minors. If we become aware that we have inadvertently collected personal data from a child without appropriate consent, we will take immediate steps to delete such data from our systems.

If you are a parent or legal guardian and believe your child may have provided us with personal data, you may contact us at privacy@touchstream.media to request access to, correction of, or deletion of that information.

Touchstream also confirms that we do not knowingly “share” or “sell” personal data of minors, as those terms are defined under applicable data protection and privacy laws, including through our use of Google Analytics, Clicky, or any similar web analytics or tracking technologies. Any processing of personal data from users is performed in accordance with applicable data protection laws, including the General Data Protection Regulation (EU and UK), COPPA (U.S.), and relevant state privacy frameworks.

Controller

For the purpose of applicable data protection laws, we will each be regarded as an independent data controller of your personal data when we collect your personal data through our Website or Platform.

Processor

When our customers use our products and services to process their own customer and client data, they are acting as data controller and are responsible for ensuring that personal information collected about data subjects is being processed lawfully, and we act as processor, processing such personal data only as instructed by the customer.

This Privacy Policy only applies to the extent that we act as controller. It does not apply to personal data that we process on your behalf as your data processor.

3. Contact us

For questions, complaints or requesting further information from us on data protection and privacy, or any requests concerning your personal data, or where you’ve identified a risk to our processing of personal data, please write to privacy@touchstream.media

4. Types of Personal Data we may collect about you

Personal data means any information about an individual from which that person can be identified.

We may collect, use, store and transfer the following types of personal data about you:

• Identity Data: your full name, organisation and job role/title;
• Contact Data: your contact address, email address and telephone number;
• Profile and Marketing Data: login information regarding password protected platforms or services when provided by us, your preferences in receiving marketing information from us, your communication preferences, feedback and survey responses; and
• Technical and Usage Data: internet protocol (IP) address, login data, browser type and version, device type, time zone setting, browser plug-in type and versions, operating system and platform and other technology on the devices you use to access the Website and the Platform, preferred language, access times and information on how you interact with and use our Website, the Platform and other products and services.

We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals’ Technical and Usage Data to calculate the percentage of users accessing a specific feature of our Website in order to analyse general trends as to how users are interacting with our Website and Platform, to help improve our service offering.

5. Personal Data we may collect about other individuals

You may provide us with the personal data of other individuals, such as your employees, to enable facilitation of user account opening, billing, enabling support requests and other activities related to the provision of our services. In such instances, you must ensure that you have their permission to do so.

6. How we collect your personal data

We use different methods to collect data from and about you including through:

• Your interactions with us. You may give us your personal data by filling in online forms or by corresponding with us by phone, email or otherwise. This includes personal data you provide when you:
  • purchase a Touchstream product;
  • contacting our sales team;
  • create an account on our Website or Platform;
  • viewing and navigating the Website;
  • accessing and using the Platform;
  • sign up to evaluate a service (for example a demo);
  • sign up to use a service;
  • contact our support team;
  • participate in a marketing/sales promotion or online survey;
  • request marketing materials;
  • sign up for a webinar; or
  • give us feedback or contact us.
• Automated technologies or interactions. As you interact with our Website and Platform, we will automatically collect Technical and Usage Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookies policy https://touchstream.media/cookie-policy/ for further details.
• Third parties or publicly available sources. We may receive personal data about you from various third parties and publicly available information.

7. How we use your personal data

Legal basis

The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

1. Performance of a contract with you: where we need to perform the contract we are about to enter into or have entered into with you.
2. Legitimate interests: where it is necessary to conduct our business and pursue or legitimate interests (for example to enable us to give you the best and most secure customer experience) for and your interests and fundamental rights do not override those interests. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
3. Legal obligation: where we need to comply with a legal obligation to which we are subject.
4. Consent: we rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example for direct marketing or if you subscribe to an email newsletter.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use the various categories of your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Direct marketing

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving the marketing.

We may also analyse your Identity Data, Contact Data, Profile and Marketing Data and Technical and Usage Data to form a view which products, services and offers may be of interest to you so that we can then send you relevant marketing communications.

Third party marketing

We will get your express consent before we share your personal data with any third party for their own direct marketing purposes.

Opting out of marketing

You can ask to stop sending you marketing communications at any time by contacting us at privacy@touchstream.media.

If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes.

8. Disclosure of your Personal Data

Your personal data may, for the purposes set out in this Privacy Policy, be disclosed for processing to:

• our corporate group, including our related bodies corporate, subsidiaries, affiliates companies and divisions;
• our employees;
• our subcontractors;
• our service providers who may access your personal information when providing services to us;
• third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them;
• to any third party where such disclosure is required in order to enforce or apply any contracts we have in place, or to protect the rights, property, or safety of our company, our customers, our employees or contractors, or others but always in accordance with applicable laws; and/or
• protect the rights, property or safety of Touchstream, our customers, our employees, our contractors, or others. This includes exchanging information with other companies and organisations for the purposes of fraud prevention and credit risk reduction.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

9. International Transfers

A portion of our offices and workforce is located around the world. As a result, we will access and transfer your personal data in Australia, the United Kingdom, Spain, the United States and Asia.

We may also transfer your personal data to service providers that carry out certain functions on our behalf.

Whenever we transfer your personal data internationally to countries whose privacy laws do not offer an adequate, substantially similar or otherwise sufficient level of protection required under the applicable laws of the jurisdiction in which the personal data was originally collected, we will implement appropriate measures to meet the requirements of the relevant data protection frameworks. These safeguards may include:

• entering into contractual agreements that impose strict data privacy and security obligations (e.g. the European Commission’s Standard Contractual Clauses or the International Data Transfer Addendum to the European Commission’s Standard Contractual Clauses). You may request a copy of these safeguards by contacting us at privacy@touchstream.media;
• applying technical and organisational security measures (such as encryption, access controls, and data minimisation protocols);
• conducting data transfer risk assessments or legal evaluations, where required under applicable laws;
• ensuring compliance with US transfer regulations; or
• relying on the explicit consent of the individual, where permitted or required under relevant law.

10. Information Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

However, please be aware that communications over the internet, such as e-mails, are not secure unless they have been encrypted. Your communications may route through a number of countries before being delivered – this is the nature of the internet.

We cannot accept responsibility for any unauthorised access or loss of personal information that is beyond our control.

We believe that we have appropriate policies, rules and technical measures to protect the personal data that we have under our control (having regard to the type and amount of that data) from unauthorised access, improper use or disclosure, unauthorised modification, unlawful destruction or accidental loss.

11. Your rights in relation to your information

You can write to us at any time to obtain a copy of your information and to have any inaccuracies corrected. Please write to: privacy@touchstream.media

You have the following rights under data protection laws in relation to your personal data:

• Access: you are entitled to be provided with a copy of the personal data we hold about you, and verify we are lawfully processing it.
• Deletion: you have the right to ask us to delete personal information we hold about you though please bear in mind that we may need to keep all or part of your data for specific legal reasons, which will be notified to you, if applicable, at the time of your request.
• Rectification: you are entitled to have any incomplete or inaccurate personal data corrected.
• Withdraw consent: where we collect and/or process your personal data for which you have provided consent, you have the right to withdraw your consent in relation to such processing.
• Restriction: under certain circumstances specified by data protection law, you have the right to request us to restrict the processing of your personal data, or we may restrict the processing of your data (e.g. if you claim your data is inaccurate, you object to the processing of your personal data and we are considering your request, if processing is unlawful and you oppose erasure and request restriction instead, etc.).
• Object: you have the right to object to our processing of your personal data based on: (i) our legitimate interests or the performance of a task in the public interest; (ii) direct marketing (including profiling); (ii) processing for purposes of scientific/historical research and statistics. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
• Portability: you have the right to request us to provide you with your personal data in a structured, commonly used and machine-readable form and to ask us to transmit the data directly to another organisation if this is technically feasible.

Requests must be made in writing to privacy@touchstream.media. Please provide us with your name and address when making any such request, along with brief details of the information of which you would like a copy or which you would like to be corrected (this helps us to locate more readily your data).

We may require proof of your identity before providing you with details of any personal data we may hold about you.

We may only request a reasonable fee from you when your request is manifestly unfounded or excessive or repetitive or we receive a request to provide further copies of the same information.

12. Cookies

We use cookies to distinguish you from other users of the Website. This helps us to provide you with a good experience when you browse our Website and also allows us to improve our Website. For detailed information on these cookies, the way we use them and the purposes for which we use them, please see our cookie policy at https://touchstream.media/cookie-policy/

13. Web Analytics and Tracking Technologies

We use third-party analytics services, including Google Analytics and Clicky, to help us understand how users interact with our Website and Platform, measure engagement, and improve performance and user experience. These tools collect information such as your device type, browser, operating system, referring URLs, time spent on pages, geographic region (based on IP address), and general usage patterns. The data collected is aggregated and anonymised wherever possible and is used only for statistical and service-improvement purposes.

These analytics providers may set cookies or similar technologies on your device to enable their functionality. Data generated by these tools (including your IP address) is transmitted to and stored by the respective analytics providers on their servers, which may be located in other jurisdictions, including outside the European Economic Area (EEA), the United Kingdom, and Australia. Where such transfers occur, we implement appropriate safeguards consistent with applicable data protection frameworks (e.g., the EU Standard Contractual Clauses).

You can learn more about how each provider processes data and how to opt-out of analytics tracking by visiting their privacy pages:

• Google Analytics: https://policies.google.com/privacy
• Clicky Analytics: https://clicky.com/terms/privacy

You may also opt-out of analytics tracking by adjusting your browser settings to refuse all or some browser cookies, or by using available opt-out tools such as the Google Analytics Opt-Out Browser Add-On. Please note that disabling cookies may limit certain functionalities of our Website or Platform.

Touchstream does not use Google Analytics or Clicky to identify or profile individual users, nor do we use these tools to share or sell personal data, including any data relating to minors, as defined under applicable privacy laws.

14. Where we store and process your information

Personal information we collect may be stored and processed in the country where it was collected or in the countries where we operate. We take all reasonable steps to protect personal information, regardless of the country in which it is held.

However, your information may be stored, processed, accessed, or used in countries whose privacy laws differ from and may offer less protection than those applicable in the jurisdiction where the personal data was collected. By using our services or providing your personal information, you acknowledge and consent to such international transfers and the associated processing and storage of your data in accordance with this privacy notice.

15. Changes to this Privacy Policy

We reserve the right to amend or modify this Privacy Policy and if we do so we will post the changes on our Website. It is your responsibility to check the Privacy Policy every time you submit information to us. Historic versions of this Privacy Policy can be obtained by contacting us.

In the event the purposes for which we process personal information change, then we will contact you as soon as practicable to inform you of the change (and where appropriate to obtain your consent), where such notification relates to a new additional purpose for processing which is not compatible with, or similar to, the originally specified purposes.

16. Use of your personal information submitted to other Apps or websites

We are not responsible for the privacy policies and practices of other apps or websites (such as social media plugins), even if you accessed the third party website or app using links from our Website, Platform or by means of our products or services.

We recommend that you check the policy of each website or app you visit and contact the owner or operator of such website or app if you have concerns or questions.

17. Data retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

18. Complaints

You have the right to make a complaint at any time to the relevant regulator for data protection issues in your jurisdiction (which, in Australia is the Office of the Australian Information Commissioner, in Spain is the Agencia Española de Protección de Datos and in the United Kingdom is the Information Commissioner’s Office). However, we would appreciate the chance to deal with your concerns before you approach them. Please contact us in the first instance by writing to privacy@touchstream.media

Last update: 18/12/2025