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SD Privacy Policy
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Privacy Policy

June 2021 | Version 1.6

  1. INTRODUCTION                                 
                                    
    Welcome to our privacy policy. We are Symmetric Delta Pty Ltd (Registration number: 2015/131693/07) and this is our plan of action when it comes to protecting your privacy. We respect your privacy and take the protection of personal information very seriously. The purpose of this policy is to describe the way that we collect, store, use, and protect information that can be associated with you or another specific natural or juristic person and can be used to identify you or that person (“
    personal information”).                                 
  1. AUDIENCE                                 
    The purpose of this policy is to describe the way that we handle your personal information.
                                    
    This policy applies to you if you are:        
  1. a visitor to our website; or
  2. a customer who has ordered or requested the use of our software and/or services that we provide; or
  3. our data subject.                                         
  1. PERSONAL INFORMATION                                 
    This policy applies to you under certain circumstances.
                                    
  1. Personal information includes certain information we collect:                         
  1. automatically when you visit our website;
  2. on registration (refer 6.1);
  3. on submission;
  4. through a purchase order; and
  5. optional information that you provide to us voluntarily (see below).
  1. but excludes:                                                 
  1. information that has been made anonymous so that it does not identify a specific person;
  2. permanently de-identified information that does not relate or cannot be traced back to you specifically; and
  3. non-personal statistical information collected and compiled by us.
  1. Common Examples                                                                         Common examples of the types of personal information which we may collect, and process include your:                                                 
  1. identifying information – such as your name;
  2. contact information – such as your phone number or email address;
  3. address information – such as your physical or postal address
  1. Your obligations
    You may only send us:                                                 
  1. your own personal information if you are 18 years or older;
  2. someone else’s personal information if they are older than 18 and you have their permission to do so                                         
            
  1. ACCEPTANCE                                 
  1. Acceptance required
    You must accept all the terms of this policy when you subscribe to our software or request our services. If you do not agree with anything in this policy, then you may not subscribe to our software or request our services.                                 
  2. Legal capacity
    You may not access our website or subscribe to our software or request our services if you are younger than 18 years old or do not have legal capacity to conclude legally binding contracts.                                         
  3. Deemed acceptance
    By accepting this policy, you are deemed to have read, understood, accepted, and agreed to be bound by all of its terms.                 
            
  1. CHANGES
    We may change the terms of this policy at any time by updating this web page. We will notify you of any changes by placing a notice in a prominent place on the website or by sending you an email detailing the changes that we have made and indicating the date that they were last updated. If you do not agree with the changes, then you must stop using the website and our software or services. If you continue to use the website or our software or services following notification of a change to the terms, the changed terms will apply to you and you will be deemed to have accepted those updated terms.                                          
  1. COLLECTION
                                     
  1. On registration or submission                                                 
  1. Once you register on, or submit information through our website, you will no longer be anonymous to us. You will provide us with certain personal information when you register on our website. This personal information will include:                                                                 
  1. your name and surname;
  2. your email address;
  3. your telephone number;
  4. your company name, company registration number, and VAT number;
  5. your postal address or street address; and
  6. your username and password.
  1. We will use this personal information to fulfil your account, provide additional services and information to you as we reasonably think appropriate, and for any other purposes set out in this policy.
                                                                                     
  1. On order or request
    When you subscribe to our software or request our services from us, you will be asked to provide us with additional information on a voluntary basis (“software subscription or services information”).                                                
                                            
  2. From browser                                                 
  1. We automatically receive and record Internet usage information on our server logs from your browser, such as your Internet Protocol address (IP address), browsing habits, click patterns, version of software installed, system type, screen resolutions, colour capabilities, plug-ins, language settings, cookie preferences, search engine keywords, JavaScript enablement, the content and pages that you access on the website, and the dates and times that you visit the website, paths taken, and time spent on sites and pages within the website (usage information). Please note that other websites visited before entering our website might place personal information within your URL during a visit to it, and we have no control over such websites. Accordingly, a subsequent website that collects URL information may log some personal information.                
  2. For information on how we deal with Cookies, please refer to our Cookies Policy.
  1. Web beacons
    Our website may contain electronic image requests (called a single-pixel gif or web beacon request) that allow us to count page views and to access cookies. Any electronic image viewed as part of a web page (including an ad banner) can act as a web beacon. Our web beacons do not collect, gather, monitor or share any of your personal information. We merely use them to compile anonymous information about our website.                                                 
                                            
  2. Optional details
    You may also provide additional information to us on a voluntary basis (optional information). This includes content or products that you decide to upload or download from our website, respond to surveys, order certain additional services, or otherwise use the optional features and functionality of our website and or software applications.                                                 
                                                                            
  3. Purpose for collection                                                 
  1. We may use or process any software subscription or services information, or optional information that you provide to us for the purposes that you indicated when you agreed to provide it to us. Processing includes gathering your personal information, disclosing it, and combining it with other personal information. We generally collect and process your personal information for various purposes, including:                                                                 
  1. software or services purposes – such as collecting orders or requests for and providing access to our software or services;
  2. marketing purposes – such as pursuing lawful related marketing activities;
  3. business purposes – such as internal audit, accounting, business planning, and joint ventures, disposals of business, or other proposed and actual transactions;
  4. legal purposes – such as handling claims, complying with regulations, or pursuing good governance; and
  5. analytics purposes – such as creating derived data from your personal information to get insights into how you use ours software  or services, including through aggregation, de-identification, anonymisation and other data analytics operations.                        
  1. We may use your usage information for the purposes described above and to:                                                                 
  1. remember your information so that you will not have to re-enter it during your visit or the next time you access the website;
  2. monitor website usage metrics such as total number of visitors and pages accessed; and
  3. track your submissions or other activities in connection with your usage of the website.

                                                 

  1. Consent to collection
  1. We will obtain your consent to collect personal information:         
  1. in accordance with applicable law;
  2. when you provide us with any registration information or optional information.                                                                                                          
  1. USE
                                     
  1. Our obligations
    We may use your personal information to fulfil our obligations to you.                                         
  2. Messages and updates
    We may send administrative messages and email updates to you about the website and/or software subscribed to. We may wish to provide you with information about new services in which we think you may be interested. This means that in some cases, we may also send you promotional messages. We will not send you promotional messages unless you have chosen to opt-into them. But, we may send you one message asking you to opt-into promotional messages without you having opted-into promotional messages.                                                 

                                            
  1. DISCLOSURE
                                     
  1. Sharing
    We may share your personal information with:                                                 
  1. an affiliate, in which case we will seek to require the affiliates to honour this privacy policy;
  2. our services providers under contract who help provide certain software or services or help with parts of our business operations, including bill collection, technology services (our contracts dictate that these services providers only use your information in connection with the services they supply or services they perform for us and not for their own benefit);
  3. other third parties who provide us with relevant services where appropriate.
                                                                             
  1. Regulators                                                 

We may disclose your personal information as required by law or governmental audit.                                         

  1. Law enforcement                                                 
    We may disclose personal information if required:                                         
  1. by a subpoena or court order;
  2. to comply with any law;
  3. to protect the safety of any individual or the general public; and
  4. to prevent violation of our customer relationship terms.
                                                                                     
  1. No selling
    We will not sell personal information. No personal information will be disclosed to anyone except as provided in this privacy policy.                                                                 
  2. Employees
    We may need to disclose personal information to our employees that require the personal information to do their jobs or provide services, but we will not do so unnecessarily. These include our responsible management, human resources, accounting, audit, compliance, information technology, or other employees.                                         
  3. Change of ownership
    If we undergo a change in ownership, or a merger with, acquisition by, or sale of assets to another entity, we may assign our rights to the personal information we process to a successor, purchaser, or separate entity. We will disclose the transfer on the website. If you are concerned about your personal information migrating to a new owner, you may request us to delete your personal information.                                                                                                           
  1. SECURITY
    We take the security of personal information very seriously and always do our best to comply with applicable data protection laws. Our hosting company will host our website in a secure server environment that uses a firewall and other advanced security measures to prevent interference or access from outside intruders. We authorise access to personal information only for those employees who require it to fulfil their job responsibilities. We implement disaster recovery procedures where appropriate.
                                                            
  1. ACCESS
    You may ask us to provide you with a description of the personal information that we hold on you, correct or update it or delete it (provided that we do not need it to fulfil our obligations to you or applicable law does not require us to keep it). We will take all reasonable steps to verify your identity before doing so. Please contact us with your name and any other information needed to identify you correctly if you want access to information or want us to correct, update or delete it.                         
                    
  1. ACCURATE AND UP TO DATE
    We will try to keep the personal information we collect as accurate, complete and up to date as is necessary for the purposes defined in this policy. From time to time we may request you to update your personal information on our software application(s). You are able to review or update any personal information that we hold on you by accessing your account online, emailing us, or phoning us. Please note that in order to better protect you and safeguard your personal information, we take steps to verify your identity before granting you access to your account or making any corrections to your personal information.                                         
                    
  1. RETENTION
                                     
  1. We will only retain your personal information for as long as it is necessary to fulfil the purposes explicitly set out in this policy, unless:                                         
  1. retention of the record is required or authorised by law; or
  2. you have consented to the retention of the record.
  1. During the period of retention, we will continue to abide by our non-disclosure obligations and will not share or sell your personal information.
  2. We may retain your personal information in physical or electronic records at our discretion.                                                 
                                    
  1. TRANSFER TO ANOTHER COUNTRY
    We may transmit or transfer personal information outside of the country in which it was collected to a foreign country and process it in that country. Personal information may be stored on servers located outside the country in which it was collected in a foreign country whose laws protecting personal information may not be as stringent as the laws in the country in which it was collected. You consent to us processing your personal information in a foreign country whose laws regarding processing of personal information may be less stringent.                                         
  1. UPDATING OR REMOVING
    You may choose to correct or update the personal information you have submitted to us, by clicking the relevant menu in any of the pages on our software or contacting us by phone or email.                                 
  1. NOTIFICATION OF BREACH
    Where we have reasonable grounds to believe that an unauthorised third party has accessed your personal information and if required by law, we will notify the relevant Regulator and you of the breach. If the law requires us to notify you, we will provide you with sufficient information to allow you to take protective measures against the potential consequences of the breach.         
                    
  1. LIMITATION
    We are not responsible for, give no warranties, nor make any representations in respect of the privacy policies or practices of linked or any third-party websites.                         
  1. ENQUIRIES
    If you have any questions or concerns arising from this privacy policy or the way in which we handle personal information, please contact us at privacy@symmetric-delta.co.za