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Privacy policy
Simbye Privacy Policy
Effective Date: 01.04.2024
Simbye we are committed to protecting the privacy and security of your personal information. This Privacy Policy outlines how we collect, use, disclose, and protect your data when you use our website and services.
We value your privacy and are committed to protecting it through compliance with this Privacy Policy ("Policy"). This Policy explains the types of information we may collect from you or that you may provide ("Personal Data") on the Simbye.com website ("Website"), the "Simbye" mobile application ("Mobile Application"), and other related products and services (collectively "Services"). Additionally, it describes our practices regarding the collection, use, maintenance, protection, and disclosure of these personal data. It also outlines the choices available to you regarding the use of your personal data and how you can access and update this information.
This Policy constitutes a legally binding agreement between you ("User", "You", or "Your") and Simbye Ltd. If you are entering into this agreement on behalf of a company or other legal entity, you represent that you have the authority to bind such entity to this agreement. In this context, the terms "User", "You", or "Your" refer to such an entity. If you do not have such authority or do not agree to the terms of this agreement, you must not accept this agreement and may not access or use the Services. By accessing and using the Services, you acknowledge that you have read, understood, and agreed to the terms of this Policy. Please note that this Policy does not apply to the practices of companies that we do not own or control, or to individuals that we do not employ or manage.
What Information Do We Collect?
1.1. Personally Identifiable Information
We may collect personal data when you voluntarily provide it to us, such as when you sign up for our newsletter or chat, create an account, request further information on our contact page, respond to a survey or questionnaire, and provide personal information like your email address, name, phone number, or other information. Where applicable, personal data may include personal information as defined by applicable law.
This Privacy Policy does not apply to the privacy practices of third parties that we do not own or control, including but not limited to third-party websites, services, applications, online resources that this Website may link to or otherwise reference (collectively Third-Party Services or TPS), which you may access through the Services. For example, the Services use Facebook API services as TPS, and you agree to be bound by Facebook's terms of use, privacy policy, and API services terms of use when using Facebook content and services through the Service. We are not responsible for the content or privacy practices of TPS. We encourage you to carefully read the privacy policies of any TPS you access.
Simbye does not consider personal data to be anonymized information, so it does not allow a third party to identify a specific person. We collect and use your personal data to provide the services, operate and improve our service, provide customer service, conduct research and analysis to improve our products, services, and technologies, and display content tailored to your interests and preferences.
You always have the choice not to provide personal data, but if you choose not to, certain parts of the Service may not be available to you. If you have registered an account with us, you have agreed to provide your personal data to access the Services. This consent gives us the legal basis we need under applicable law to process your data. You retain the right to withdraw such consent at any time. If you do not agree with the use of your personal data in accordance with this policy, please do not use our Services.
1.2. Sensitive Personal Data
Subject to the following paragraph, we ask you not to send or disclose any sensitive personal data (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background, or union membership) on or through the Services or otherwise to us.
If you send or disclose any sensitive personal data to us when submitting content to the Services, you consent to the processing and use of such sensitive personal data in accordance with this Policy. If you do not consent to the processing and use of such sensitive personal data, you must not submit such content to us. Please note that we will not store it anywhere on our site, even if this information is provided.
1.3. Non-Personally Identifiable Information
We may collect and aggregate non-personally identifiable information, which is information that does not enable you to be identified either alone or in combination with other information available to third parties. This information may include information like a website that referred you to us, your IP address, browser type and language, hardware types, geographic location, and access times and duration. We may also collect navigation information, including information about the content of the Service or pages you view, the links you click, and other actions taken in connection with the
Service. We use this information to analyze usage patterns to make improvements to the Service.
1.4. Privacy of Children
We do not knowingly collect personal data from children under 13 years of age. If you are under 13, please do not submit any personal data through the Services. If you have reason to believe that a child under 13 has provided us with personal data through the Services, please contact us to request that we delete this child's personal data from our Services.
We encourage parents and guardians to monitor their children's internet usage and to help enforce this Policy by instructing their children never to provide personal data through the Services without their permission. We also ask all parents and guardians supervising children in their care to take the necessary precautions to ensure that their children are instructed never to give out personal information without their permission when online.
What Do We Do With The Information We Collect?
We need the information to verify your identity and process your order when you first sign up for our services. Additionally, we may use your personal data for the following purposes:
2.1. Compliance with Regulatory Requirements
We may use your personal data to fulfill our regulatory obligations, and in some cases, we must disclose the data to regulatory authorities, for example, in case of a complaint from you.
3. Marketing
If you request information about our products and services, we try to contact you by phone or email regarding the specific product you wish to inquire about. If we hear nothing more from you, we will delete your data after twelve months.
If you have agreed to the use of personal data for marketing purposes, we may use your personal data to send you information about additional services we offer.
4.Managing Information
You can delete certain personal information that we hold about you. The personal information you can delete may change as the Services change. However, even if you delete personal data, we may retain a copy of the unrevised personal data in our records for the duration required to fulfill our obligations to our affiliates and partners and for the purposes described below. If you wish to delete your personal data or permanently delete your account, you can do so on the settings page of your account in the Services.
5.Disclosure
Generally, Simbye will not disclose any of your personal data except under one of the following circumstances:
We have your permission, including the permission granted by your acceptance of this Privacy Policy.
We determine in good faith that it is legally required to be disclosed by a relevant law, regulation, rule, administrative or court order, decree, or subpoena.
It is information we determine must be disclosed to correct what we believe to be incorrect or misleading information or to address activities we believe to be manipulative, misleading, or otherwise in violation of the law, if you were otherwise notified at the time of data collection.
6.Information Retention
We will retain and use your personal data for the period necessary as long as your user account is active, to enforce our agreements, resolve disputes, and unless a longer retention period is required or permitted by law.
We may use any aggregated data derived from or incorporating your personal data after you update or delete it, but not in a manner that would identify you personally. Once the retention period expires, personal data will be deleted. Therefore, the right to access, the right to erasure, the right to rectification, and the right to data portability cannot be enforced after the expiration of the retention period.
7.Data Protection Rights under GDPR
If you reside in the European Economic Area ("EEA"), you have certain data protection rights, and we strive to take reasonable steps to allow you to correct, amend, delete, or limit the use of your personal data. If you wish to be informed about what personal data we hold about you and if you want it to be removed from our systems, please contact us. Under certain circumstances, you have the following data protection rights:
(i) You have the right to withdraw your consent at any time where you have previously given your consent to the processing of your personal data. As far as the legal basis for our processing of your personal data is consent, you have the right to withdraw that consent at any time. The withdrawal will not affect the lawfulness of the processing before the withdrawal.
(ii) You have the right to be informed if your personal data is being processed, to obtain disclosure regarding certain aspects of the processing, and to obtain a copy of the personal data undergoing processing.
(iii) You have the right to verify the accuracy of your information and ask for it to be updated or corrected. You also have the right to have us complete the personal data you believe is incomplete.
(iv) You have the right to object to the processing of your data if the processing is based on a legal basis other than consent. Where personal data is processed for a public interest, in the exercise of an official authority vested in us, or for the purposes of the legitimate interests pursued by us, you may object to such processing by providing a reason related to your particular situation to justify the objection. You must, however, be aware that if
your personal data is processed for direct marketing purposes, you can object to that processing at any time without providing any reason. To find out if we are processing personal data for direct marketing purposes, you may refer to the relevant sections of this policy.
(v) You have the right, under certain circumstances, to restrict the processing of your personal data. Such circumstances include: the accuracy of your personal data is contested by you, and we need to verify its accuracy; the processing is unlawful, but you oppose the erasure of your personal data and request the restriction of their use instead; we no longer need your personal data for the purposes of the processing, but you require them for the establishment, exercise, or defense of legal claims; you have objected to processing pending the verification whether our legitimate grounds override yours. Where processing has been restricted on this basis, such personal data will be marked accordingly and, except for storage, will be processed only with your consent or for the establishment, exercise, or defense of legal claims, for the protection of the rights of another natural or legal person, or for reasons of important public interest.
(vi) You have the right, under certain circumstances, to obtain the erasure of your personal data from us. Such circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. For example, where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise, or defense of legal claims.
(vii) You have the right to receive your personal data, which you have provided to us, in a structured, commonly used, and machine-readable format and, if technically feasible, to have it transmitted without hindrance from us to another controller, provided such transfer does not adversely affect the rights and freedoms of others.
(viii) You have the right to lodge a complaint with a data protection authority about our collection and use of your personal data. If you are not satisfied with the outcome of your complaint directly with us, you have the right to submit a complaint to your local data protection authority. For more information, please contact your local data protection authority in the EEA. This provision applies provided your personal data is processed automatically and the processing is based on your consent, a contract in which you are a party, or pre-contractual obligations thereof.
8.Data Retention
We constantly review and improve our measures to protect your personal data from unauthorized access, accidental loss, or destruction.
If we have a contract with another organization to provide a service on our behalf, we ensure that they have appropriate security measures and process your information only as we have authorized. These organizations are not allowed to use your personal data for their purposes. If necessary, our security teams will review them to ensure they meet the security requirements we have set.
Communication over the internet (e.g., emails) is not secure unless encrypted. Your communication may go through several countries before being delivered - this is the nature of the internet. We cannot take responsibility for unauthorized access or loss of personal data that is beyond our control.
9.Updates to Our Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our privacy practices or for other operational, legal, or regulatory reasons. If we make material changes to this Privacy Policy, we will notify you of such changes by posting the revised policy on this website and, where appropriate, by other means. If you continue to use this website or the support service after the posting of these changes, you agree to the revised policy.
10.Control Over and Access to Your Personal Data
We may charge you up to £10 to cover the cost of processing your request and providing your information to you. We will ask you to provide identification to ensure that we do not give your information to the wrong people.
Simbye understands that you have rights over your personal data and takes reasonable steps so that you can correct, amend, delete, or limit the use of your personal data.
If you have concerns about data collected when visiting the Website or using our support services at support@simbye.com, please contact us to make the necessary changes. It's important to remember that the Services may not function properly if you delete or restrict the use of your personal data.
If you have a complaint about how we handle your personal data, you can contact the Information Commissioner (https://ico.org.uk). Our ICO registration number is ZB633151.
Last Update: 01.04.2024
Effective Date: 01.04.2024
Simbye we are committed to protecting the privacy and security of your personal information. This Privacy Policy outlines how we collect, use, disclose, and protect your data when you use our website and services.
We value your privacy and are committed to protecting it through compliance with this Privacy Policy ("Policy"). This Policy explains the types of information we may collect from you or that you may provide ("Personal Data") on the Simbye.com website ("Website"), the "Simbye" mobile application ("Mobile Application"), and other related products and services (collectively "Services"). Additionally, it describes our practices regarding the collection, use, maintenance, protection, and disclosure of these personal data. It also outlines the choices available to you regarding the use of your personal data and how you can access and update this information.
This Policy constitutes a legally binding agreement between you ("User", "You", or "Your") and Simbye Ltd. If you are entering into this agreement on behalf of a company or other legal entity, you represent that you have the authority to bind such entity to this agreement. In this context, the terms "User", "You", or "Your" refer to such an entity. If you do not have such authority or do not agree to the terms of this agreement, you must not accept this agreement and may not access or use the Services. By accessing and using the Services, you acknowledge that you have read, understood, and agreed to the terms of this Policy. Please note that this Policy does not apply to the practices of companies that we do not own or control, or to individuals that we do not employ or manage.
What Information Do We Collect?
1.1. Personally Identifiable Information
We may collect personal data when you voluntarily provide it to us, such as when you sign up for our newsletter or chat, create an account, request further information on our contact page, respond to a survey or questionnaire, and provide personal information like your email address, name, phone number, or other information. Where applicable, personal data may include personal information as defined by applicable law.
This Privacy Policy does not apply to the privacy practices of third parties that we do not own or control, including but not limited to third-party websites, services, applications, online resources that this Website may link to or otherwise reference (collectively Third-Party Services or TPS), which you may access through the Services. For example, the Services use Facebook API services as TPS, and you agree to be bound by Facebook's terms of use, privacy policy, and API services terms of use when using Facebook content and services through the Service. We are not responsible for the content or privacy practices of TPS. We encourage you to carefully read the privacy policies of any TPS you access.
Simbye does not consider personal data to be anonymized information, so it does not allow a third party to identify a specific person. We collect and use your personal data to provide the services, operate and improve our service, provide customer service, conduct research and analysis to improve our products, services, and technologies, and display content tailored to your interests and preferences.
You always have the choice not to provide personal data, but if you choose not to, certain parts of the Service may not be available to you. If you have registered an account with us, you have agreed to provide your personal data to access the Services. This consent gives us the legal basis we need under applicable law to process your data. You retain the right to withdraw such consent at any time. If you do not agree with the use of your personal data in accordance with this policy, please do not use our Services.
1.2. Sensitive Personal Data
Subject to the following paragraph, we ask you not to send or disclose any sensitive personal data (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background, or union membership) on or through the Services or otherwise to us.
If you send or disclose any sensitive personal data to us when submitting content to the Services, you consent to the processing and use of such sensitive personal data in accordance with this Policy. If you do not consent to the processing and use of such sensitive personal data, you must not submit such content to us. Please note that we will not store it anywhere on our site, even if this information is provided.
1.3. Non-Personally Identifiable Information
We may collect and aggregate non-personally identifiable information, which is information that does not enable you to be identified either alone or in combination with other information available to third parties. This information may include information like a website that referred you to us, your IP address, browser type and language, hardware types, geographic location, and access times and duration. We may also collect navigation information, including information about the content of the Service or pages you view, the links you click, and other actions taken in connection with the
Service. We use this information to analyze usage patterns to make improvements to the Service.
1.4. Privacy of Children
We do not knowingly collect personal data from children under 13 years of age. If you are under 13, please do not submit any personal data through the Services. If you have reason to believe that a child under 13 has provided us with personal data through the Services, please contact us to request that we delete this child's personal data from our Services.
We encourage parents and guardians to monitor their children's internet usage and to help enforce this Policy by instructing their children never to provide personal data through the Services without their permission. We also ask all parents and guardians supervising children in their care to take the necessary precautions to ensure that their children are instructed never to give out personal information without their permission when online.
What Do We Do With The Information We Collect?
We need the information to verify your identity and process your order when you first sign up for our services. Additionally, we may use your personal data for the following purposes:
2.1. Compliance with Regulatory Requirements
We may use your personal data to fulfill our regulatory obligations, and in some cases, we must disclose the data to regulatory authorities, for example, in case of a complaint from you.
3. Marketing
If you request information about our products and services, we try to contact you by phone or email regarding the specific product you wish to inquire about. If we hear nothing more from you, we will delete your data after twelve months.
If you have agreed to the use of personal data for marketing purposes, we may use your personal data to send you information about additional services we offer.
4.Managing Information
You can delete certain personal information that we hold about you. The personal information you can delete may change as the Services change. However, even if you delete personal data, we may retain a copy of the unrevised personal data in our records for the duration required to fulfill our obligations to our affiliates and partners and for the purposes described below. If you wish to delete your personal data or permanently delete your account, you can do so on the settings page of your account in the Services.
5.Disclosure
Generally, Simbye will not disclose any of your personal data except under one of the following circumstances:
We have your permission, including the permission granted by your acceptance of this Privacy Policy.
We determine in good faith that it is legally required to be disclosed by a relevant law, regulation, rule, administrative or court order, decree, or subpoena.
It is information we determine must be disclosed to correct what we believe to be incorrect or misleading information or to address activities we believe to be manipulative, misleading, or otherwise in violation of the law, if you were otherwise notified at the time of data collection.
6.Information Retention
We will retain and use your personal data for the period necessary as long as your user account is active, to enforce our agreements, resolve disputes, and unless a longer retention period is required or permitted by law.
We may use any aggregated data derived from or incorporating your personal data after you update or delete it, but not in a manner that would identify you personally. Once the retention period expires, personal data will be deleted. Therefore, the right to access, the right to erasure, the right to rectification, and the right to data portability cannot be enforced after the expiration of the retention period.
7.Data Protection Rights under GDPR
If you reside in the European Economic Area ("EEA"), you have certain data protection rights, and we strive to take reasonable steps to allow you to correct, amend, delete, or limit the use of your personal data. If you wish to be informed about what personal data we hold about you and if you want it to be removed from our systems, please contact us. Under certain circumstances, you have the following data protection rights:
(i) You have the right to withdraw your consent at any time where you have previously given your consent to the processing of your personal data. As far as the legal basis for our processing of your personal data is consent, you have the right to withdraw that consent at any time. The withdrawal will not affect the lawfulness of the processing before the withdrawal.
(ii) You have the right to be informed if your personal data is being processed, to obtain disclosure regarding certain aspects of the processing, and to obtain a copy of the personal data undergoing processing.
(iii) You have the right to verify the accuracy of your information and ask for it to be updated or corrected. You also have the right to have us complete the personal data you believe is incomplete.
(iv) You have the right to object to the processing of your data if the processing is based on a legal basis other than consent. Where personal data is processed for a public interest, in the exercise of an official authority vested in us, or for the purposes of the legitimate interests pursued by us, you may object to such processing by providing a reason related to your particular situation to justify the objection. You must, however, be aware that if
your personal data is processed for direct marketing purposes, you can object to that processing at any time without providing any reason. To find out if we are processing personal data for direct marketing purposes, you may refer to the relevant sections of this policy.
(v) You have the right, under certain circumstances, to restrict the processing of your personal data. Such circumstances include: the accuracy of your personal data is contested by you, and we need to verify its accuracy; the processing is unlawful, but you oppose the erasure of your personal data and request the restriction of their use instead; we no longer need your personal data for the purposes of the processing, but you require them for the establishment, exercise, or defense of legal claims; you have objected to processing pending the verification whether our legitimate grounds override yours. Where processing has been restricted on this basis, such personal data will be marked accordingly and, except for storage, will be processed only with your consent or for the establishment, exercise, or defense of legal claims, for the protection of the rights of another natural or legal person, or for reasons of important public interest.
(vi) You have the right, under certain circumstances, to obtain the erasure of your personal data from us. Such circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. For example, where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise, or defense of legal claims.
(vii) You have the right to receive your personal data, which you have provided to us, in a structured, commonly used, and machine-readable format and, if technically feasible, to have it transmitted without hindrance from us to another controller, provided such transfer does not adversely affect the rights and freedoms of others.
(viii) You have the right to lodge a complaint with a data protection authority about our collection and use of your personal data. If you are not satisfied with the outcome of your complaint directly with us, you have the right to submit a complaint to your local data protection authority. For more information, please contact your local data protection authority in the EEA. This provision applies provided your personal data is processed automatically and the processing is based on your consent, a contract in which you are a party, or pre-contractual obligations thereof.
8.Data Retention
We constantly review and improve our measures to protect your personal data from unauthorized access, accidental loss, or destruction.
If we have a contract with another organization to provide a service on our behalf, we ensure that they have appropriate security measures and process your information only as we have authorized. These organizations are not allowed to use your personal data for their purposes. If necessary, our security teams will review them to ensure they meet the security requirements we have set.
Communication over the internet (e.g., emails) is not secure unless encrypted. Your communication may go through several countries before being delivered - this is the nature of the internet. We cannot take responsibility for unauthorized access or loss of personal data that is beyond our control.
9.Updates to Our Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our privacy practices or for other operational, legal, or regulatory reasons. If we make material changes to this Privacy Policy, we will notify you of such changes by posting the revised policy on this website and, where appropriate, by other means. If you continue to use this website or the support service after the posting of these changes, you agree to the revised policy.
10.Control Over and Access to Your Personal Data
We may charge you up to £10 to cover the cost of processing your request and providing your information to you. We will ask you to provide identification to ensure that we do not give your information to the wrong people.
Simbye understands that you have rights over your personal data and takes reasonable steps so that you can correct, amend, delete, or limit the use of your personal data.
If you have concerns about data collected when visiting the Website or using our support services at support@simbye.com, please contact us to make the necessary changes. It's important to remember that the Services may not function properly if you delete or restrict the use of your personal data.
If you have a complaint about how we handle your personal data, you can contact the Information Commissioner (https://ico.org.uk). Our ICO registration number is ZB633151.
Last Update: 01.04.2024