Summary of Changes

Important: We’ve updated our Terms and Conditions and proposed new sub-processors 

The Terms and Conditions within our Customer Contracts are changing and we’re also planning to add new sub-processors to our service stack. You’ll find a short summary below. 

What’s changing? 
Terms and Conditions 
We’ve made the following key changes to our Terms and Conditions to take effect on 19 May 2023: 


  • Updated the European Commission Standard Contractual Clauses for customers subject to the GDPR and incorporated the UK International Data Transfer Addendum to apply to customers subject to the UK GDPR.   
  • Clarified various rights and obligations in relation to our billing processes, charges and fees, including: 
  • removing the terms in relation to Prepaid Plans as we do not provide Prepaid Plans to you;  
  • describing how changes in our pricing are notified. Plus, specifying when certain charges may change without prior notification (e.g. international messaging charges); 
  • describing how and when third party charges (e.g. credit card companies and carries) may be passed on;  
  • outlining our Service suspension rights and collection cost reimbursement rights if your payment obligations are not met. This includes if direct debit arrangements are not maintained, or if your account remains inactive for an extended period of time; 
  • clarifying how you can pay and when you must pay; and 
  • clarifying that we do not accept payments via BPAY or by direct debit. 
  • Added a new section of our Terms and Conditions. This details various rights and obligations if you are a Reseller.  
  • Added a new section of our Terms and Conditions. This details the additional security obligations and usage restrictions applicable to customers’ or resellers’ use of our API in Integrations (as defined in the Terms and Conditions). We have also reserved our rights to we conduct monitoring activities to verify compliance with the new requirements. 
  • Noted that in relation to our resellers’ use of developer APIs, we specifically require compliance with applicable developer terms, including security terms. 
  • Extended our Services use restrictions so that: 
  • the Services may not be used to transmit, store or process Cardholder Data; 
  • you must ensure that you use best security practices in using the Services, including securing any website or infrastructure you have which may affect our Services; 
  • we have the ability to block / restrict sending to international destinations at our discretion; and 
  • you provide additional warranties and indemnities in respect of specified uses of the Services. 
  • Extended the liability disclaimers in our Terms and Conditions to cover liability arising from your use of any third-party products. 


  • What exactly is a ‘sub-processor’?  
  • A sub-processor is a third-party service provider that processes personal data on our behalf. This includes actions such as collection, recording and organisation, among other tasks.  
  • We use sub-processors for several reasons, including to operate our platform and improve our customer experience.  
  • You can find a full list of the sub-processors we use here. 
  • Here’s a summary of the proposed new sub-processors: 
Name Location Types of data processed Purpose 
Match My Email (RAE Internet, Inc.). Germany Customer and prospect information. Provision of CRM and marketing platform functionality. 
Arcaris, Inc. d/b/a Playvox Australia Customer and prospect information Enable and improve customer support and customer experience. 

Any questions?  

Please reach out to us at any time at +64 9 307 1764. We’ll be happy to help. 


The Bulletin Team