Simple Technology Pty Ltd (“Simple”, “we”, “us”, “our”) are committed to protecting and respecting your privacy by handling all Personal Information securely and with care in accordance with the Australian Privacy Principles (the APPs) as set out in the Privacy Act 1988 (Cth) (the Act). The APPs regulate the manner in which personal information is handled, from collection to use and disclosure, storage, accessibility and disposal. As an Australian based business offering services in the EU, we must comply with the General Data Protection Regulations (GDPR) in respect of data protection.
WHAT IS ‘PERSONAL INFORMATION’?
‘Personal Information’ is any information or an opinion about you that identifies you or that could reasonably identify you. This could include information such as your name, contact details or date of birth.
PURPOSES FOR COLLECTING INFORMATION
Simple collects Personal Information which is necessary to conduct business with you.
Simple and its service providers may use your personal or business information and information you have supplied for purposes including to:
- identify you as the User and to provide better client service to you, your business partners and your employees;
- perform authorised financial transactions with you and your associated service providers;
- operate our business as it applies to you;
- keep you informed about Simple products and services and those of relevant business partners;
- participate in the process of any third party acquisition or potential acquisition of an interest in us or our assets;
- protect our lawful interests; and fulfil legal and regulatory obligations with our third-party service suppliers and vendors.
We may not be able to do these things, or those outlined below (under ‘How we use and disclose your information’), without your personal information. For example, we may not be able to manage your registration or process transactions where applicable.
HOW WE USE AND DISCLOSE YOUR INFORMATION
Simple uses and discloses your Personal Information and the information you supply in many ways necessary for us to do business together, for example: product promotion, user access to products, user registration, to provide client support and for secure access to Simple products and/or websites.
Simple may contact you about product upgrades and new product releases and to inform you of new services relevant to your business. You may notify us at any time that you do not want to receive any marketing communications from Simple.
When setting up a user account to access products and services, you must provide contact information (such as name, email address, phone number and other information as required). In some cases financial information (such as a credit card number and expiration date if you are using this payment method). Simple uses this information to fulfil your order and bill you. If we have trouble processing an order, this contact information is also used to get in touch with you to resolve the problem.
To facilitate the provision of the transactional service for which you have applied Simple is required to pass information you have provided to its service providers. See the section ‘Disclosure to third parties’ below for more on Simple’s service providers.
User registration links your Simple product to your contact details. This allows our support consultants to provide you with quality advice relevant to your particular situation when you call Simple customer support or lodge a support ticket. If software or documentation needs to be emailed to you, the consultant has all the information needed to ensure fast service.
To others within your organisation or with your permission
After a person demonstrates proof that he belongs to a certain organisation, we may disclose to that person the names of that organisation’s Users where required as part of the normal course of supplying Simple’s Products and Services. We may also disclose your Personal Information with your permission.
Aggregated data that contains no information specific to a particular individual or business may be shared with our business partners, for example, aggregated statistical trends in a particular industry sector.
Disclosure to third parties
We may provide your personal information to our related bodies corporate and our service providers who assist us with client contact, archiving, auditing, accounting, legal, business consulting, banking, delivery, data processing, automated communications, and website or technology services.
Some of the third parties described above (including our service providers) may be located outside of Australia. You acknowledge that while these parties will often be subject to other confidentiality or privacy obligations, they may not in all cases be subject to the specific requirements of Australian or New Zealand privacy laws.
We may use Personal Information for service-related purposes. There are some circumstances in which we may provide it to third parties to allow us to facilitate Simple’s Services in providing you the ability to use Simple’s products and services.
We reserve the right to disclose your personal information when we believe it is appropriate to comply with the law, facilitate court proceedings or to protect our rights.
MANAGING AND DELETING COOKIES
Cookies can be monitored and deleted from your browser. Since browsers create and store cookies, they are also the most direct way to access, manage, and delete cookies. If you wish to delete your browser’s cookies, we recommend that you contact your web browser developer to find out how. Please keep in mind that if you disable all cookies, certain portions of our website may not work properly since certain necessary cookies and functionality cookies will be disabled.
Using cookies allows Simple to use a program called “Google Analytics”. This program assists in the collection of information about visitors to its website. These systems help analyse how users use the Website. The information generated about your use of the Website will be transmitted to and stored by Google on servers that may be located outside Australia. This information is only accessible and used by Simple to improve our Website, products and systems.
We will take reasonable steps to store information in a secure manner, protected by a combination of physical and technical measures. Personal Information that we store electronically is stored in secure cloud services.
We will take all reasonable steps to protect the security of your Personal Information as held by us. This includes appropriate technology to protect Personal Information stored electronically, as well as limiting the number of personnel who have access to such information.
Despite our reasonable efforts, we cannot guarantee that the security of your Personal Information will not be breached, therefore, to the fullest extent permitted by law, we disclaim all liability any responsibility for any damage you may suffer due to any loss, unauthorised access, misuse or alteration of any information we collect, except to the extent that our liability cannot be excluded by applicable laws and regulations which we are subject to.
You can confirm that any Simple data-entry page uses encryption by checking that:
- the page address in the Web browser’s toolbar or status bar begins with https://; or
- the padlock icon in the web browser’s toolbar or status bar is locked.
If you are considering sending us any personal information through unencrypted electronic means (e.g. standard email), please be aware that the information may be less secure in transit.
If you are a registered user of any Simple website or service, access to your account may be controlled by a username and password chosen by you. To prevent unauthorised access, you should choose a strong password and keep it protected from others.
By using Simple’s Services or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of Simple’s Services. If we learn of a security system breach, we may attempt to notify you electronically or sending an email to you.
DELETION, RETENTION AND PORTABILITY OF PERSONAL INFORMATION
If, at any point in time, you wish for your Personal Information to:
- be destroyed; or
- be de-identified; or
- have access to; or
- a copy to be provided to you.
You can submit a request to Simple by contacting the Privacy Officer via firstname.lastname@example.org or simply to visit your “Preference Centre” via our homepage, unless, we are legally allowed or required to maintain your (or part of) your Personal Information.
Simple keeps your Personal Information only as long as necessary to provide our services to you (refer to ‘Purposes for Collecting Information’ section) and for legitimate and essential business purposes, such as complying with our legal obligations and/or settling disputes.
It is unlikely but possible that we will disclose your Personal Information to overseas recipients. If we transfer your Personal Information outside Australia, we will comply with requirements of the Act that relate to trans-border data flows. While we will not directly disclose your Personal Information to overseas recipients without your consent, the entities to which we may disclose your Personal Information may theoretically do so. We are unable to say what countries, if any, those recipients are likely to be located in.
INFORMATION ACCESS AND CORRECTION
In the event that you need to access, update or correct your personal or business information, you can do so by contacting email@example.com. Alternatively, you can contact us to request access, erasure or changes to your Personal Information by telephoning 1300 740 679. Please provide us with as much detail as you can about the particular information you are interested in, in order to help us locate it.
If you have a complaint about the way we have dealt with your Personal Information we invite you to provide written details of your complaint to our Privacy Officer (firstname.lastname@example.org).
Our Privacy Officer will contact you within 14 days of the date we receive the written details of your compliant to acknowledge that we have received it. Our Privacy Officer will then:
- review the way we dealt with your Personal Information;
- conduct an internal investigation (if necessary) into how your Personal Information came to be handled in the way that it was; and
- provide a report to you within one month of the date we acknowledged receipt of your complaint.
If you believe we have breached the APPs you may also lodge a complaint with the Office of the Australian Information Commissioner.
As you may be aware, Simple is a worldwide provider of services and may, from time to time, offer services in the European Union (EU). As an Australian based business offering services in the EU, we must comply with the General Data Protection Regulations (GDPR) in respect of data protection.
The GDPR is effective from May 25, 2018. The GDPR replaces the EU’s existing national privacy and security laws and provide the EU with a single, comprehensive EU-wide law that governs the use, sharing, transferring and processing of any personal data that originates from the EU.
In accordance with the GDPR, Simple has taken the following steps:
- Reviewed our data processing activities to determine which data processing activities are subjected to the GDPR.
- Followed appropriate security measures and precautions in accordance with GDPR.
- Ensured employees of Simple who are authorised to process personal data have committed to confidentiality.
- Where appropriate, we have offered contractual language documenting our commitments to our customers to support their GDPR obligations.
- Updated and expanded internal processes to accommodate data subject rights requests.
Last Modified: May 2018