Acceptable Use Policy

Effective 1 April 2026.

PICKLE PTY LTD ABN 36 165 711 731

Acceptable Use Policy

Effective date: 1 April 2026 | Version: 2.0

Table of contents

1. Purpose and Scope

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1.1 This AUP applies to:

  • (a) all customers who have entered into a service agreement with Pickle ("Customer"); and
  • (b) any end users, employees, contractors, or third parties who access or use the Services through a Customer's account ("Authorised Users").

1.2 Customers are responsible for ensuring all Authorised Users comply with this AUP. A breach by an Authorised User is treated as a breach by the Customer.

2. Definitions

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  • ACMA — Australian Communications and Media Authority
  • CLI — Calling Line Identification; the telephone number transmitted as the originating number when a call is made
  • Criminal Code — Criminal Code Act 1995 (Cth)
  • Customer — the business entity that has entered into a service agreement with Pickle
  • Network — Pickle's telecommunications infrastructure and any third-party networks used to deliver the Services
  • SIP — Session Initiation Protocol used to establish and manage VoIP calls
  • VoIP — Voice over Internet Protocol

3. General Obligations

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3.1 Customers must use the Services:

  • (a) in accordance with all applicable Australian laws and regulations
  • (b) in a manner that does not harm Pickle's Network, other customers, or third parties
  • (c) consistently with any directions issued by ACMA or other regulatory authorities

3.2 Customers must not resell, resupply, or provide access to the Services to any third party other than Authorised Users, unless Pickle has agreed in writing.

4. Prohibited Conduct — General

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4.1 Customers must not use the Services to:

  • (a) engage in any activity unlawful under Australian law, including under the Criminal Code Act 1995 (Cth), Telecommunications Act 1997 (Cth), Spam Act 2003 (Cth), Privacy Act 1988 (Cth), or Do Not Call Register Act 2006 (Cth)
  • (b) transmit, distribute, or store defamatory, obscene, offensive, menacing, or harassing content
  • (c) infringe any intellectual property rights
  • (d) access, alter, or destroy data or systems without authorisation — including activities constituting computer offences under Part 10.7 of the Criminal Code Act 1995 (Cth)
  • (e) transmit or distribute malware, viruses, ransomware, spyware, or any other malicious code
  • (f) conduct or facilitate denial-of-service (DoS or DDoS) attacks against any system or network
  • (g) conduct network scanning, port scanning, or penetration testing of systems the Customer does not own or have explicit written authorisation to test
  • (h) attempt to gain unauthorised access to any system, account, or network — including Pickle's own infrastructure

5. Prohibited Conduct — Voice and VoIP Services

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5.1 Customers using Pickle voice services must not:

  • (a) CLI spoofing — transmit a false or misleading Calling Line Identification. All calls must present an accurate CLI reflecting a number legitimately allocated to or authorised for the Customer. ACMA has issued specific directions regarding CLI integrity under the Telecommunications Act 1997 (Cth).
  • (b) SIP fraud and toll fraud — use or allow use of SIP credentials, extensions, or trunk access to make unauthorised calls, including through compromised PBX systems or weak credentials. Customers are responsible for securing their SIP infrastructure. Pickle may suspend voice services immediately where toll fraud is detected.
  • (c) International Revenue Share Fraud (IRSF) — artificially inflate call volumes to international premium rate or revenue-share numbers.
  • (d) Traffic pumping — artificially generate or inflate call traffic to any destination for any purpose.
  • (e) SIM box and grey routing — use SIM boxes, SIM farms, GSM gateways, or any device that routes calls through the mobile network in a way that misrepresents call origin or bypasses regulated interconnect arrangements.
  • (f) Auto-dialler misuse — operate automatic dialling systems in contravention of the Do Not Call Register Act 2006 (Cth) or Spam Act 2003 (Cth), or in any manner that causes unreasonable Network interference.
  • (g) Number misuse — transfer, sell, or deal in allocated telephone numbers without Pickle's prior written consent, in compliance with the ACMA Numbering Plan.

5.2 Customers must configure and maintain SIP and PBX equipment with appropriate security controls including strong authentication, firewall rules, and access controls. Where Pickle reasonably believes a Customer's equipment has been compromised, Pickle may suspend the affected voice service without notice and will notify the Customer as soon as practicable.

6. Prohibited Conduct — Spam and Unsolicited Communications

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6.1 Customers must not use the Services to send unsolicited commercial electronic messages in contravention of the Spam Act 2003 (Cth), including:

  • (a) bulk unsolicited email, SMS, or MMS messages
  • (b) using Pickle's network as a relay or proxy for sending spam
  • (c) harvesting email addresses or telephone numbers for unsolicited communications
  • (d) using false or misleading sender information in commercial electronic messages

6.2 Where Pickle receives a complaint or direction from ACMA regarding spam activity, Pickle will cooperate fully and may suspend the relevant service pending investigation.

7. Emergency Services

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7.1 Customers must not:

  • (a) make false or hoax calls to emergency services (000) through any Pickle voice or VoIP service
  • (b) use any Pickle service to obstruct, interfere with, or misuse emergency telecommunications infrastructure
  • (c) misuse Pickle's emergency lift phone services, including making false emergency calls through lift communication systems

7.2 Customers are advised that VoIP and SIP-based voice services may have limitations in relation to 000 emergency calling that differ from standard fixed-line services. These limitations are set out in the Customer Terms and relevant product disclosures. Customers must ensure all Authorised Users are aware of these limitations and that alternative means of contacting emergency services are available.

7.3 Making a false call to emergency services is a criminal offence under the Criminal Code Act 1995 (Cth) and relevant state and territory legislation. Pickle will report confirmed instances to relevant authorities.

8. Fair Use of Internet Services

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8.1 Pickle's internet services are provided for legitimate business use. Where a plan includes a data allowance, the Customer must not exceed it other than as permitted under the plan.

8.2 Where a plan is described as "unlimited," it is subject to fair use. The following are not considered standard business use and are prohibited:

  • (a) using the Services as a wholesale internet product to supply access to third parties who are not Authorised Users
  • (b) operating large-scale public Wi-Fi hotspots or open access networks without prior written approval
  • (c) sustained bulk data transfer at rates that cause Network congestion affecting other customers
  • (d) using the Services for a purpose that would ordinarily require a dedicated wholesale or carrier-grade service

8.3 Where Pickle determines usage is inconsistent with fair use, Pickle will notify the Customer and may take the actions set out in clause 11.

9. Security Obligations

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9.1 Customers must:

  • (a) implement and maintain appropriate access controls and authentication for all accounts, SIP credentials, and connected systems
  • (b) promptly change credentials known or suspected to be compromised
  • (c) apply security patches and updates to systems connected to Pickle's Network within a reasonable time
  • (d) implement and maintain firewall, intrusion detection, and malware prevention controls on systems connecting to Pickle's Network
  • (e) notify Pickle immediately at [email protected] or 1300 688 588 if aware of any security incident or compromise that may affect Pickle's Network or other customers

10. Monitoring and Compliance

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10.1 Pickle reserves the right to monitor Services for the purposes of:

  • (a) ensuring compliance with this AUP and Customer Terms
  • (b) maintaining the security, integrity, and performance of the Network
  • (c) detecting and preventing fraud, including voice and toll fraud
  • (d) complying with directions from ACMA, law enforcement, or other regulatory authorities
  • (e) investigating complaints from other customers or third parties

10.2 Monitoring is conducted in accordance with the Telecommunications (Interception and Access) Act 1979 (Cth) and Privacy Act 1988 (Cth). Pickle's privacy practices are set out in the Privacy Policy at thinkpickle.com.au/legal/privacy-policy.

10.3 Where Pickle identifies activity it reasonably believes constitutes a breach of this AUP, a criminal offence, or a risk to the Network, Pickle may preserve and disclose relevant records to ACMA, law enforcement, or other regulatory authorities as required or permitted by law.

11. Enforcement

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11.1 If Pickle reasonably determines that a Customer has breached this AUP, Pickle may take one or more of the following actions having regard to the nature and severity of the breach:

  • (a) issue a written warning to the Customer
  • (b) restrict or throttle specific traffic types
  • (c) suspend access to some or all Services, with or without notice depending on severity
  • (d) terminate the Customer's service agreement in accordance with the Customer Terms
  • (e) refer the matter to ACMA, the Australian Federal Police, or other relevant authorities

11.2 Where a breach poses an immediate risk to the security or integrity of the Network or to any person, Pickle may suspend the relevant Service immediately and without prior notice. Pickle will notify the Customer as soon as reasonably practicable.

11.3 Where a breach does not pose an immediate risk, Pickle will generally provide written notice and a reasonable opportunity to remedy before taking enforcement action. This does not apply to unlawful activities or fraud.

11.4 Suspension or termination does not affect Pickle's right to recover amounts owing under the Customer Terms, including minimum term charges.

12. Reporting a Breach

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If you believe this AUP has been breached, contact Pickle at:

  • Email: [email protected]
  • Phone: 1300 688 588 (urgent Network security incidents — call during business hours)

Pickle will acknowledge all reports and investigate in accordance with its complaints handling procedure.

13. Changes to This Policy

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13.1 Pickle may update this AUP to reflect changes in law, regulatory requirements, or services.

13.2 For material changes, Pickle will provide at least 21 days' notice by email to the Customer's registered contact address and will publish the updated AUP at thinkpickle.com.au/legal/acceptable-use-policy.

13.3 For changes required by law or regulatory direction, the change takes effect on the date required, which may be less than 21 days.

13.4 Continued use of the Services following the effective date constitutes acceptance of the updated AUP.

14. Contact Details

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Pickle Pty Ltd ABN 36 165 711 731 Office 12, 7-9 Churchill Ave, Strathfield NSW 2135 Phone: 1300 688 588 Email: [email protected] Website: thinkpickle.com.au

15. Governing Law

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This AUP is governed by the laws of New South Wales, Australia. The parties submit to the non-exclusive jurisdiction of the courts of New South Wales and the Federal Court of Australia.

Pickle Pty Ltd ABN 36 165 711 731 — Acceptable Use Policy — Version 2.0 — Effective 1 April 2026