April 18, 2023
Simpu takes your right to privacy seriously. You have a right to know what we do with your personal information so that you can make informed choices while visiting our website.
Our Services are intended for use by businesses. Where our Services are made available to you as an End User of Simpu through a Simpu Customer, that Customer is the data controller of your personal data and you should contact that Customer with questions or requests regarding your personal data. Simpu is not responsible for our Customers’ privacy or security practices which may be different from this Policy.
If you do not agree with or you are not comfortable with any aspect of this Policy, you should immediately discontinue access or use of our Services.
We may modify this Policy from time to time which will be indicated by changing the date at the top of this page. If we make any material changes, we will notify you by email (sent to the email address specified in your account), by means of a notice on our Services prior to the change becoming effective, or as otherwise required by law.
This Notice applies to personal data that Simpu is the controller of, which may include: (i) data collected through the Websites, our branded social media pages, and other websites which we operate (collectively, our “Digital Properties”); (ii) data collected in connection with digital communications, paper forms, in person interactions which may include marketing and outreach activities, like surveys, contests, promotions, sweepstakes, conferences, webinars, and events where we post a direct link to this Notice; (iii) Customer contact information; (iv) data collected about individuals who visit our offices or engage in commercial transactions with us; and (v) data collected through Simpu’s corporate activities..
We may collect the following types of information from you:
a. Information you provide to us directly. We collect the information you provide to us directly. This includes instances when you register and communicate with us directly through our Digital Properties, when you visit our offices, when you participate in our events, or when you participate in our marketing and outreach activities including surveys, contests, promotions, sweepstakes, conferences, webinars, and events.
b. Information collected from your Employer, Coworkers, or Friends. We may collect and process personal data concerning representatives (e.g., employees) of our current, past and prospective customers, suppliers, investors and business partners from such companies or other employees of such companies. We may also receive your name, address, phone number, and company name from a friend as part of a referral.
Personal Identification Information: these are Full name, date of birth, nationality, gender, signature, utility bills, photographs, phone number, home address, and/or email. Information you provide to us by filling in the forms on the website or any other information you submit to us via the website or email. Formal Identification Information: Government issued identity document such as Passport, Driver's License, National Identity Card, Tax ID number, passport number, driver’s license details, national identity card details, visa information, and/or any other information deemed necessary to comply with our legal obligations under Financial or Anti-Money Laundering Laws.
Financial Information: Bank account information, Payment card details, Transaction history, trading data, and/or tax identification. Details of the transactions you carry out with us via the Site, including details of payment methods used.
Business Information: Full name of your business with registration details, incorporation documents, Tax ID number, country of operations, details of Directors and shareholder with valid means of identification, signature, utility bills, photographs of promoters their phone numbers, emails, and home addresses. These Information are required to be provide to us by filling in the forms on the website or any other information you submit to us via the website or email.
c. Information we may collect from you automatically: To the extent permitted under the applicable law, we may collect certain types of information automatically, such as whenever you interact with the Sites or use the Services. This information helps us address customer support issues, improve the performance of our Sites and Services, provide you with a streamlined and personalized experience, and protect your account from fraud by detecting unauthorized access. Information collected automatically includes:
· Online Identifiers: Geo location/tracking details, browser fingerprint, operating system, browser name and version, and/or personal IP addresses.
· Usage Data: Authentication data, security questions, click-stream data, public social networking posts, and other data collected via cookies and similar technologies. Details of your visits to the website including, but not limited to, location data, weblogs and other communication data.
Other information and data about you which we may collect, use, and process include the following:
i. Records of correspondence received via the website, email and telephone.
ii. Your responses to surveys or customer research that we carry out from time to time.
iii. Details of the transactions you carry out with us via the website, telephone or other means, including details of payment methods used.
We collect and process personal information and sometimes personal information to comply with our Know Your Customer (“KYC”) and Know Your Business (“KYB”) obligations under applicable laws and regulations, and Anti-Money Laundering Laws and regulations.
Legal Basis for our use of Personal Information.
We use your Personal Information to furnish our contract with you, thus when we provide you with products or services or communicate with you about them. This includes when we use your personal information to process your Order Form, to contact you for any feedback.
Simpu uses the information collected for the following purposes:
i. We may use your personal information and data together with other information for the purposes of processing, operating and managing your access to our Site.
ii. To maintain legal and regulatory compliance; Most of our core Services are subject to laws and regulations requiring us to collect, use, and store your personal information in certain ways. For example, Simpu must identify and verify customers Order Form for any requested services.
iii. Regularly providing you with information about promotional offers, products and services.
iv. To provide customer service; We process your personal information when you contact us to resolve any questions, disputes, collect fees, or to troubleshoot problems. Without processing your personal information for such purposes, we cannot respond to your requests and ensure your uninterrupted use of the Services.
v. To ensure quality control; We process your information for quality control and staff training to make sure we continue to provide you with accurate information.
vi. For any purpose that you provide consent; We will not use your information for purposes other than those purposes we have disclosed to you, without your permission. From time to time, and as required under the applicable law, we may request your permission to allow us to share your personal information with third parties. In such instances, you may opt out of having your personal information shared with third parties, or allowing us to use your personal information for any purpose that is incompatible with the purposes for which we originally collected it or subsequently obtained your authorization. If you choose to limit the use of your personal information, certain features or Simpu Services may not be available to you.
Simpu will also process your personal data for the purposes of carrying out the services provided on the Site. We may also use your information to improve our products and services and track/target the interest of our users so that we can enhance user experience.
Your rights to personal information are not absolute. Nonetheless, you have the right to the following:
a. Right to be informed – to know what personal data is collected about, and how long it is kept;
b. Right to Access; You may have the right to obtain confirmation from us if personal data is being processed
c. Right to Rectification - you can request the rectification of your Data which are inaccurate, and also add to it.;
d. Right to object to processing; ou may have the right to object to the processing of your personal data for compelling and legitimate reasons relating to your particular situation, except in cases where legal provisions expressly provide for that processing.
e. Right to Restrict processing - in certain circumstances, you have the right to limit the processing of your data;
f. Right to Data Portability;
g. Right to be Forgotten or Deletion.
5.1. Simpu secures your personal information from unauthorized access, use or disclosure. We secure the personally identifiable information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure. When personal information (such as a credit card number) is transmitted to other Web sites, it is protected through the use of encryption through a security protocol on the Website.
5.2. Information Storage and Protection
Simpu will take all reasonable steps to ensure that your information is secured and protected. We will only disclose personal information to other companies within associated or subsidiary companies and to business partners; successors in title to our business and suppliers that are engaged to process such information on our behalf. If you apply for an account with us then to help us make credit decisions about you, to prevent fraud, to check your age and identity and to prevent money laundering, we may use third parties including credit reference agencies who will record any searches on your file.
However, we cannot guarantee that loss, misuse, unauthorized acquisition, or alteration of your data will not occur. Please recognize that you play a vital role in protecting your own personal information. When registering with our Services, it is important to choose a password of sufficient length and complexity, to not reveal this password to any third-parties, and to immediately notify us if you become aware of any unauthorized access to or use of your account.
Furthermore, we cannot ensure or warrant the security or confidentiality of information you transmit to us or receive from us by Internet or wireless connection, including email, phone, or SMS, since we have no way of protecting that information once it leaves and until it reaches us. If you have reason to believe that your data is no longer secure, please contact us using the contact information provided in the “Contact Us” section below.
Simpu will disclose your personal information, without notice, only if required to do so by applicable law, regulation, operating agreement, legal process or in the good faith or belief that such action is appropriate and necessary to:
i. Conform to the law or comply with legal processes served on Simpu or the site;
ii. Protect and defend the rights or property of Simpu and,
iii. Act under exigent circumstances to protect the personal safety or property of users of Simpu, or the public in the event of a claim or dispute to your use of our services.
We store your personal information and Business Information securely throughout the extant tenure of the Order Form and any other pending obligation in that regard. We will only retain your Information for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting obligations or to resolve disputes. While retention requirements vary by jurisdiction, information about our typical retention periods for different aspects of your personal information are described below: Information collected to comply with our legal obligations under financial or anti-money laundering laws may be retained after account closure for as long as required under such laws.
Once you or your company has terminated the contractual relationship with us or otherwise ended your relationship with us, we may retain your personal data in our systems and records in order to: ensure adequate fulfillment of surviving provisions in terminated contracts, or for other legitimate business purposes, such as in order to evidence our business practices and contractual obligations, to provide you with information about our products and services, or to comply with the applicable legal, tax or accounting requirements. Likewise, we will retain your personal data during the applicable statute of limitation period for the establishment, exercise or defense of potential legal claims..
Recording of our telephone calls with you may be kept for a period of up to six years. Information collected via technical means such as cookies, webpage counters and other analytics tools is kept for a period of up to one year from the expiry of the cookie.
If you authorize one or more third-party applications to access your Services, then information you have provided to Simpu may be shared with those third parties. A connection you authorize or enable between your Simpu account and a third-party account, payment instrument, or platform is considered an “account connection.” Unless you provide further permissions, Simpu will not authorize these third parties to use this information for any purpose other than to facilitate your transactions using Simpu Services.
Please note that third parties you interact with may have their own privacy policies, and Simpu is not responsible for their operations or their use of data they collect. Information collected by third parties, which may include such things as contact details, financial information, or location data, is governed by their privacy practices and Simpu is not responsible for unauthorized third-party conduct. We encourage you to learn about the privacy practices of those third parties.
Information that we share with a third party based on an account connection will be used and disclosed in accordance with the third party’s privacy practices. Please review the privacy notice of any third party that will gain access to your personal information. Simpu is not responsible for such third-party conduct.
Telephone calls to and from our Customer Contact Centre may be recorded for training and security purposes along with the resolution of any queries arising from the service you receive.