1. General
Simplex Software & Internet Services Ltd. (collectively referred to as “Simplex”, “we”, “us”, “our” or “the Company” in this Privacy Policy) is a company incorporated under the laws of the Republic of Cyprus with registration number HE 165621, having its headquarters at 4th Floor, Zenios Center, 72 Thessalonikis Street, Limassol 3025, Cyprus.
Simplex as a data controller is committed to protecting the privacy of your Personal Data/Information and comply with the new legislation on the protection of personal data (EU Regulation 2016/679) and directive 95/46/EC (General Data Protection Regulation, GDPR). The purpose of this Privacy Policy is to describe how Simplex collects, treats, uses and protects your Personal Data/Information and how you may change and/or request its amendment and/or deletion.
2. Personal Data/Information
Personal Data/Information is any information relating to a live identified natural person or an identifiable natural person that can be identified, directly or indirectly, in particular by reference to an identification number or to one or more factors specific to this person’s identity.
Personal Data/Information may be supplied to Simplex and/or collected by Simplex in a number of ways including but not limited to the use of its website, through a business relationship in which Simplex may be the supplier or purchaser of products and/or services to/from the other party, through a recruitment process and potential subsequent employment of an individual by Simplex, etc.
More specifically, with regard to Simplex's operations, Personal Data are:
a) The details provided by a customer as part his/her/its engagement with Simplex including but not limited to name, surname, address and identity number.
b) Any data pertaining to the client's operation which is kept for billing purposes.
c) The client's access codes which are given by Simplex for the provision of various services.
Even though data relating to legal entities are not protected as personal data by the law, Simplex equally protects the data of all the legal entities, which are Simplex's customers.
3. Information Security
We intend to protect your Personal Information and to maintain its accuracy. Personal Information is treated in all respects as Simplex’s most highly confidential data. As such, Simplex implements physical, administrative and technical safeguards to protect your Personal Information from unauthorized access, use and/or disclosure.
Personal Information is securely stored and while it may be shared within the Company as necessary, we use controlled and secure access, encryption, passwords and firewalls to ensure that the information is accessible only to those who need to know it for the uses described in this document. For example, information obtained in the recruitment process is only made available to Simplex Human Resources personnel and the persons responsible for the position the applicant is being considered for.
We contractually obligate our suppliers and business partners to protect Personal Information from unauthorized access, use and disclosure as well. Suppliers and business partners are only provided with the Personal Information they need to carry out their functions. For example, payroll providers are given the minimum amount of employee Personal Information to be able to make salary payments to them and prepare legally required payroll reports while third party business partners are only given the Personal Information required to fulfil a customer request for products and/or services.
Except as described in this Privacy Policy, Simplex will not, without your consent, provide access to and/or transmit to any third party any of your Personal Data/Information.
In the case that Simplex needs to process Personal Data/Information for which the owner’s consent and/or the authorisation of the Commissioner of Data Protection is required, Simplex shall seek such consent and/or authorization in writing before any processing takes place.
4. Retention
Personal Data/Information is retained only for the period necessary for completing the activity for which it was collected unless otherwise explicitly mentioned in this Privacy Policy.
In certain circumstances we may not be able, may not be required or may not even be permitted to accept a request to delete Personal Information, to restrict and/or stop its use altogether or not to transmit it to another company. Such circumstances may include but are not limited to:
In cases such as the above, Personal Information will be retained till the special circumstances requiring us to keep your Personal Information cease to exist.
5. Websites/Cookies & Social Media
Simplex collects certain Personal Information through its websites and social media (the term “website” is used in this document to refer collectively to all websites and social media maintained by the company) when you choose to submit such information to it through email, an online form or otherwise. This includes Personal Information you provide to Simplex in order to request additional information about products, services and/or other matters. Information collected is used to respond to your specific request. You do not need to provide your Personal Information to us but if you don't we might not be able to respond to your communication.
Simplex also obtains certain information concerning visitors to its website including but not limited to a visitor's IP address (a computer's numerical Internet address), the websites from which visitors reached our website, the type of web browsers used to access our website, the device used and the pages viewed. Such information may be treated as Personal Information about the visitor in accordance with applicable law. We use this information to monitor the way our website is used, identify issues and evaluate the overall user experience in order to improve our web and social media presence and respond to each visitor’s needs by providing relevant content and making navigation easier.
Simplex’s website uses cookies to improve the user experience. Upon their first visit to the website users are notified for the use of cookies and in case, they do not accept it they can leave the website without further browsing.
Cookies are small files saved to a user's computer or other device that track, save and store information about the user's interactions and usage of the website. This allows the website, to provide users with a tailored experience.
Other cookies may be stored on your computer’s hard drive by external vendors when this website uses referral programs, sponsored links or adverts. Such cookies are used for conversion and referral tracking and typically expire after 30 days, though some may take longer. No Personal Information is stored, saved or collected in such cases.
Users wishing to deny the use of cookies should take the necessary steps within their web browsers’ security settings to block all cookies from Simplex’s website and its external serving vendors.
Simplex’s website includes hyperlinks to other websites neither owned nor managed by Simplex. Similarly, posts on our social media may contain links to websites and/or social media of other companies and/or individuals that are beyond our control. Simplex is not associated with these third-party websites and/or social media and does not review their privacy policies. Thus, it cannot guarantee the privacy of any information that may be obtained by third parties through such “linked” websites and/or social media. We strongly encourage you to review the respective privacy policies of any website and/or social media you visit before supplying your Personal Information.
6. Communications
When you visit our website you may subscribe to our mailing list to receive regular communication including but not limited to newsletters, surveys and invitations. Similarly, you may choose to “like” and/or “follow” Simplex on one or more social media and as a result receive notifications from Simplex through the specific(s) social media.
In addition to the above, Simplex may obtain your Personal Information through third party channels/sources, for example through an event that you registered for. When we do so, we ask the third party source to confirm that your Personal Information was legally acquired and that you have given them the right to use your Personal Information including transferring it to interested parties such as Simplex.
Simplex may use the information collected directly or indirectly as per above, to send via post, email or other means marketing and other communications related to our business and/or the businesses of carefully selected third parties in related fields which we think may be of interest to you. You may at any time choose not to receive such communications by following the unsubscribe instructions included in each email or other communication you may receive, by indicating so when we call you, or by contacting us directly.
7. Customers
This section applies to customers of Simplex and their respective users/personnel.
If you, your employer or a third party decides to purchase any products and/or services from Simplex, the company may use your Personal Information for purposes of providing these products and/or services. Simplex may provide your Personal Information to selected business partners as required for fulfilment of your purchase; for example, it may provide your Personal Information to a partner vendor for establishment of a vendor service contract for equipment you have purchased. Simplex will have obtained in advanced contractual assurances from such fulfilment partners that your Personal Data will be treated in accordance with this Policy.
Simplex may use your Personal Information to support products and/or services you have purchased such as notifying you of a product/service update or fix, planned maintenance work, etc. When a customer engages with the company’s technical support department, Simplex’s staff will collect Personal Information of yours such as your name and contact data, information about your organization and any relevant system and usage data or error reports. This information is used to diagnose and resolve problems and to communicate with the customer as needed as part of the troubleshooting effort.
In the course of providing data center and/or other IT (information technology) services including but not limited to installations and technical support, Simplex’s staff may sometimes have incidental access to data stored on your systems. This data may contain Personal Information. We will never copy or otherwise retain any such data, whether or not it contains Personal Information, unless it is necessary for the provision of services you have requested, for example as part of a troubleshooting effort in order to recreate an issue in Simplex’s environment. In such case, Personal Information/Data will be deleted from Simplex’s systems/environment when it is no longer necessary, for example when troubleshooting has been completed and the relevant issue has been resolved.
Simplex collects and processes payment information when you order products and/or services. When credit card numbers are involved, processing takes place through third-party PCI-compliant payment providers. Even though this information may not qualify as Personal Information in the great majority of cases, Simplex will treat it with the same care and security given for Personal Information.
Simplex's clients reserve the right to be informed in writing about the purposes of processing of their Personal Data at any time by requesting so in writing or via email.
Clients are obliged to protect all the confidential data granted to them. Access codes and secret codes are strictly personal and Simplex cannot be held responsible in case of loss or theft after these have been provided to the Client. In case of loss or theft of such codes, the Clients are obliged to inform Simplex as soon as possible.
8. Business Associates
If you are a business partner, a reseller, a supplier or a distributor of Simplex’s products and/or services, you may use information from the company’s websites, social media, newsletters, brochures and other collateral and informational material to administer and develop our business relationship.
You may not copy and/or present as if it is yours any such information/material. In addition, the use of the Company’s name in any form and/or of its logo without prior written consent by Simplex’s management is prohibited.
Simplex may use your Personal Information in connection with a particular transaction or program and may contact you for market research purposes and/or for evaluating customer satisfaction. Your Personal Information may also be used to administer and develop our relationship with you and/or the entity you represent.
We will retain information that you provide to us in connection with a business relationship or potential business relationship between you and/or the company/organization you represent and Simplex for as long as your account is active or as needed to provide you products and/or services.
9. Recruitment
Simplex collects a range of information from job applicants whether an application is received directly by Simplex or via a recruitment agency. This includes but is not limited to: name, address and contact details such as email address and telephone number, details of your qualifications, skills, experience and employment history, whether or not you have a disability for which the organization needs to make reasonable adjustments during the recruitment process, etc.
Simplex may collect this information in a variety of ways. For example, data might be contained in application forms, CVs/resumes, obtained from your passport or other identity documents or collected through interviews and/or other forms of assessment. Simplex may also collect information about an applicant from third parties, for example references by former employers. Should Simplex wish to seek information from third parties, it will inform you and get your consent before doing so.
Data collected during recruitment process will be stored in your application record, in HR management systems and on other IT systems (including email). You are under no statutory or contractual obligation to provide data to Simplex during the recruitment process. However, if you do not provide the requested information, Simplex may not be able to process your application properly or at all.
In case your employment application is unsuccessful, Personal Information obtained during the recruitment process may be kept on file in case there are future employment opportunities for which you may be suitable.
10. Contractual Obligations
Certain customers, business partners and/or other third parties may have a contract and/or other agreement with Simplex that has provisions related to the treatment of confidential information, including Personal Information. To the extent that such contracts and agreements have terms and conditions that are more restrictive than or provide data subjects with greater rights than this Privacy Policy, the terms of such contracts and agreements shall govern and control the relationship between Simplex and the other contracting party.
In case of conflict between any provision of this Privacy Policy or any term of a contract between Simplex and a third party as per above and the Law, the Law will prevail and such conflicting provisions/terms will be amended or deleted as necessary in order to comply with the Law.
11. Contact
According to the EU Regulation 2016/679 Simplex has appointed a Data Protection Officer (DPO) who may be contacted as follows regarding questions, comments and/or complaints regarding this Privacy Policy as well as data collection and processing policies and practices:
Mailing Address:
Simplex Software & Internet Services Ltd.
P.O.Box 58058
Limassol 3730
Cyprus
E-Mail: gdpr@simplex.com.cy
12. Changes to Privacy Policy
In cases of changes to Simplex’s Privacy Policy, these will be posted on this page.
This policy was last modified on 7 August 2018
