Simoco Wireless Solutions Privacy Policy

Simoco Wireless Solutions Pty Ltd ABN 29 095 068 429 and its related entities (collectively referred to as “Simoco Wireless Solutions”, “we”, “us” or “our”) recognise the importance of data privacy and are committed to the protection of Personal Information in accordance with the Privacy Act 1988 (Cth) as updated or amended from time to time (“Privacy Act”) and the Australian Privacy Principles set out in the Privacy Act.

The key sections of this Privacy Policy are listed below:

  1. Application of our Privacy Policy
  2. What is Personal Information?
  3. Collecting Personal Information
  4. Use of Personal Information
  5. Disclosure of Personal Information
  6. Access to Personal Information
  7. Security of Personal Information
  8. “Push” Application
  9. Contact us
  10. Data breaches or complaints
  11. Changes to our Privacy Policy
  1. Application of our Privacy Policy
    This Privacy Policy describes the manner in which Simoco Wireless Solutions collects, holds, uses and discloses Personal Information. This Privacy Policy also covers how Simoco Wireless Solutions makes the Personal Information it holds available for access and correction and how you can make a complaint.

    This Privacy Policy must be read in conjunction with any other privacy statement that Simoco Wireless Solutions may provide when it collects Personal Information or provides a particular product or service (“Privacy Statement”). To the extent of any inconsistency between this Privacy Policy and a Privacy Statement, the terms of the Privacy Statement will prevail.

    By using or accessing our website at https:// www.simocowirelesssolutions.com (“Website”) and any other software applications, products or services owned, operated or made available by Simoco Wireless Solutions (together the “Simoco Wireless Solutions Systems”), whether using your mobile phone, personal computer, or any other means, or by otherwise providing Personal Information to us, you are taken to have agreed to the provisions of this Privacy Policy and you consent to the collection, use and disclosure of Personal Information in accordance with this Privacy Policy and any Privacy Statement we may give to you.

    To avoid doubt, this Privacy Policy does not apply to information about or relating to a company or other entity that is not an individual.
  2. What is Personal Information?

    Personal Information” is defined in section 6 of the Privacy Act and means information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information is true or not, and whether recorded in a material form or not.

  3. Collecting Personal Information

    The information we collect

    We only collect Personal Information that is necessary to provide our products and services and to perform our functions and activities.

    The categories of Personal Information which Simoco Wireless Solutions may collect and hold will depend on the type of products or services that we provide. We may collect the following types of Personal Information:
    • contact information of users of any Simoco Wireless Solutions System (including full name, email address, mailing address and telephone/mobile phone number);
    • information provided in connection with the use or purchase of any products or services supplied by Simoco Wireless Solutions (e.g. user account and/or log in information and other user details etc);
    • information about transactions with us and use of our products and services (e.g. usage history, payment history); and
    • information provided by you through Simoco Wireless Solutions related communication channels such as social networking sites managed or owned by Simoco Wireless Solutions, telephone and/or email support, customer service, customer surveys, promotions, special events or other offers.

    When and how we collect information

    We may collect Personal Information in a number of ways, including:
    • directly from you/your employer, including when you/your employer:
      • buy or use products or services from us;
      • upload information via a Simoco Wireless Solutions System;
      • provide information online, by phone, by email, in application forms or in agreements;
      • request information about us or our products or services or provide feedback;
      • contract with us; or
      • contact us by our Website, telephone, facsimile, email, post or in person;
    • from an associated entity of Simoco Wireless Solutions; and
    • from social networking sites managed, used or owned by Simoco Wireless Solutions.

    In some circumstances we may receive Personal Information that we have not requested. If this occurs, we will comply with our obligations under the Privacy Act. If we retain any Personal Information we have not requested, we will treat it in accordance with this Privacy Policy and the Privacy Act.

    If a customer, user or individual chooses not to provide any requested Personal Information to Simoco Wireless Solutions, we may not be able to undertake certain activities such as providing the relevant customer, user or individual with requested information, products or services.

    Information collected via our Website

    Simoco Wireless Solutions will not collect any Personal Information from you when you use our Website except when you knowingly provide it or as otherwise described below. For example, Simoco Wireless Solutions may collect Personal Information from you when you:

    • login to your account you have created to use a Simoco Wireless Solutions System;
    • complete an online form on our Website; and/or
    • otherwise correspond with Simoco Wireless Solutions.

    Click Stream Data

    When you visit and browse our Website, our Website host may collect information (which may or may not include Personal Information) for statistical, reporting and maintenance purposes. The information collected by our Website host will not be used to identify any individual. The information may include:
    • the number of users visiting our Website and the number of pages viewed;
    • the date, time and duration of a visit;
    • the IP address of your computer;
    • any search items entered; and
    • the path taken through our Website.

    Our Website host may use this information to administer and improve the performance of our Website.

    Cookies

    When you use our Website, the relevant server may cause a small data file called a “cookie” to be saved to your computer’s memory.

    Cookies are pieces of information that may be transferred to your computer’s memory when you visit a website. Most web browsers are configured to accept cookies, however you may configure your browser to reject cookies or notify you when a cookie is sent. If you reject all cookies, you may not be able to access our Website. The use of cookies on its own does not identify an individual but it does provide us with statistics on how people use our Website and helps us to know what they find interesting and useful on our Website.

    For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.

    Web Beacons

    Web beacons are images that originate from a third-party site to track visitor activities. Simoco Wireless Solutions may use web beacons to collect aggregate data and provide this information to our Website host to administer and improve the performance of our Website, or to our customers if they request this type of data.

    Sensitive Information

    Sensitive information is a specific type of personal information that includes health information and information about an individual’s race, ethnic origin, political opinions, membership of political, professional or trade associations, religious or philosophical beliefs, sexual preferences and criminal history.

    The privacy principles under the Privacy Act impose greater obligations on us regarding any collection, use or disclosure we make of sensitive information. We will only collect sensitive information where it is reasonably necessary for or directly relates to our functions or activities and if:
    • the relevant individual has expressly consented to us doing so; or
    • we are required to do so by law.

  4. Use of Personal Information

    Simoco Wireless Solutions uses the Personal Information it collects to provide services and for our business functions and activities, including for the following purposes (each a “Primary Purpose”):

    • to provide you with information, products or services you have requested;
    • to communicate with you;
    • to operate, protect, administer, maintain and manage the Simoco Wireless Solutions Systems (including processing payments);
    • to provide training on how to use the Simoco Wireless Solutions Systems;
    • to respond to any queries, requests or actions from or of our customers in connection with the use of the Simoco Wireless Solutions Systems;
    • to personalise and customise your or our customers’ experiences on our Website or any Simoco Wireless Solutions System;
    • to screen for potential risk or fraud;
    • to help Simoco Wireless Solutions research the needs of its customers;
    • to conduct research for the purposes of improving existing products or services or creating new products or services;
    • to provide you or our customers with information, marketing or promotional messages or advertising which we believe may be of interest to you or the relevant customer, including information on our products, services or activities and information on third parties (who may or may not have a relationship with us);
    • to comply with regulatory or other legal requirements;
    • for purposes related to the employment of our personnel and providing internal services to our staff; and
    • for any other purpose communicated at the time that the Personal Information was collected or for which Simoco Wireless Solutions has received consent.

    Simoco Wireless Solutions may use Personal Information for a secondary purpose (“Secondary Purpose”) if that secondary purpose is related to any the Primary Purposes listed in the previous paragraph, and it would reasonably be expected for us to use it for that secondary purpose, or if we have the consent of the individual to whom the Personal Information relates or if otherwise provided for under the Privacy Act.

    Simoco Wireless Solutions may use Personal Information to provide direct, targeted, or other marketing materials to you or our customers on an ongoing basis. Subject to and in accordance with applicable law, Simoco Wireless Solutions may provide these materials by telephone, electronic messages (e.g. email), our digital services and other means. Simoco Wireless Solutions will only provide direct marketing materials where it would reasonably be expected for us to so, or if we have the consent from the recipient to receive direct marketing materials. We will seek consent to provide direct marketing materials if we have obtained the relevant Personal Information from a third party. Direct marketing communications may include promotional material about Simoco Wireless Solutions or may relate to the products and services Simoco Wireless Solutions, and our related entities provide and other products and services which may be of interest to the recipient.

    Recipients may opt out of receiving direct marketing material by contacting us in any of the ways specified in the direct marketing materials or as set out in the “Contact us” section below.

    Generally, we will only collect and use Personal Information in accordance with this Privacy Policy. In the event that we collect or use Personal Information in ways other than as stated in this Privacy Policy, we will ensure that we do so in accordance with the Privacy Act.

  5. Disclosure of Personal Information

    Who we may disclose Personal Information to

    Depending on the nature of the engagement with Simoco Wireless Solutions, we may disclose the Personal Information we have collected to our shareholders, officers, employees, contractors, consultants, advisers, agents of Simoco Wireless Solutions, third parties that provide products and services to or through Simoco Wireless Solutions or our Website or Simoco Wireless Solutions Systems, directly to the individual to whom the Personal Information relates (at their request), suppliers and other third parties, or otherwise as required by law.

    Simoco Wireless Solutions may also disclose Personal Information to third parties who may support the operation of our products or services (e.g. our Website host or operators of the servers on which any Simoco Wireless Solutions Systems are hosted) in certain limited circumstances, for example when any Simoco Wireless Solutions System experiences a technical problem or to ensure that it operates in an effective and secure manner.

    We may also share non-personal, de-identified and aggregated information for research or promotional purposes. We will not sell your Personal Information to third parties for marketing purposes.

    We may also disclose Personal Information if we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request. Unless otherwise specified in this Privacy Policy, Simoco Wireless Solutions will not and it will ensure that no host of any of the Simoco Wireless Solutions Systems will disclose any Personal Information to any other organisation unless the disclosure is required by law or is otherwise permitted by the Australian Privacy Principles.

    Overseas disclosure

    We may disclose your Personal Information outside of Australia to our Website host, any other host of a Simoco Wireless Solutions System, cloud providers and other third party suppliers located in the United Kingdom, the USA.

    We will only consciously transfer Personal Information overseas if:
    • we reasonably believe that the recipient of the information is subject to a law or a contract which effectively upholds privacy principles substantially similar to the privacy principles set out in the Privacy Act;
    • we have received consent to the transfer; or
    • we are otherwise required or authorised by law.


    By consenting to provide us with Personal Information (whether by using the Simoco Wireless Solutions Systems, through a Privacy Statement or otherwise), you are consenting to the disclosure of your Personal Information to third parties who reside outside Australia.

  6. Access to Personal Information

    How you can access your Personal Information

    Individuals have a right to access their Personal Information. If you would like to access any Personal Information that you believe Simoco Wireless Solutions is holding, using or processing about you, please direct your request to Simoco Wireless Solutions by email or post using the contact details set out in the “Contact us” section below.

    Sometimes, we may not be able to provide you with access to all of your Personal Information or we may first need to check with a customer before providing you with that access. This may include where giving access would be unlawful or would have an unreasonable impact on the privacy of other individuals. If we refuse you access, we will tell you why.

    We reserve the right to charge a fee for searching for and providing access to your Personal Information (but not for the request itself). We may need to verify your identity as part of this process.

    Accuracy of Personal Information

    We will take reasonable steps to ensure that the Personal Information that we hold is accurate, up-to-date and complete. You have a right to request that your Personal Information be corrected. If you think that Personal Information we hold about you is not accurate, complete and up-to-date, please contact us using the contact details set out in the “Contact us” section below and we will take all reasonable steps to correct the information.

  7. Security of Personal Information

    Precautions taken

    We understand the importance of protecting your Personal Information. We take all reasonable precautions to protect the Personal Information we hold from misuse, interference and loss, and from unauthorised access, modification or disclosure.

    Simoco Wireless Solutions aims to keep your Personal Information secure and up to date. We will comply with our obligations under the Privacy Act in relation to any Personal Information that we handle, including information which is held on any Simoco Wireless Solutions Systems.

    Personal Information that is held by Simoco Wireless Solutions in hard copy is stored securely on its premises and is only disclosed or used for the purposes described in this Privacy Policy.

    Links

    The Simoco Wireless Solutions Systems may link to other websites which are outside our control, and other websites outside our control may link to Simoco Wireless Solutions Systems. While we try to ensure that we link only to sites, online products or services which share our privacy and security standards, we do not have any control over those websites. Accordingly, we are not responsible for the protection and privacy of any Personal Information which you provide while you are visiting or using those other sites, online products or services. Those websites are not governed by this Privacy Policy. You should exercise caution and review the privacy policies applicable to those other sites, online products or services.

    How long we keep your Personal Information for

    Simoco Wireless Solutions will keep Personal Information only for as long as required for the purposes described in this Privacy Policy and otherwise as required by Australian law.

    Where we no longer need to keep Personal Information in accordance with this Privacy Policy, we will take reasonable steps to destroy or de-identify that Personal Information.

    If you wish to have your Personal Information destroyed or de-identified, please let us know and we will take reasonable steps to do so (unless we need to keep it for legal, auditing or internal risk management reasons).

  8. “Push” Application

    Introduction
    “Push” is a PTT-over-Cellular (PoC) client application for Android and iOS devices provided by Simoco Wireless Solutions that has the ability to integrate with digital mobile radio (DMR) systems. It is used to communicate with other “Push” application users, IP-connected dispatchers as well as DMR radio users using individual voice calls, group voice calls and text messages. It also provides registered user location mapping amongst “Push” users. Further information in relation to the “Push” application, including how we use and collect Personal Information, our retention of data and how you can opt out of information collection, is detailed below.

    Information Collected

    User Provided Information
    The “Push” application communicates the username and password you provide when you sign into the “Push” application. Registration with us is mandatory in order to be issued with a username and password. When you register with us and use the “Push” application, you generally provide: your name, email address, user name, phone number and other registration information. We store this information on our “Push” server in order to associate you with your username. We may use the information you provided us to contact you from time to time to provide you with important information and required notices regarding your use of the “Push” application. We will not use this information for marketing promotions.

    Automatically Collected Information
    In addition, the “Push” application may collect certain information automatically, such as the type of mobile device you use, your mobile devices unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browsers you use, your contacts, and other information to determine the platform and configuration in which the “Push” application is being used, thereby improving product installation success and subsequent use. We store this information on our “Push” server against your username. We may use this information in order to route calls, messages and location data to you during your use of the “Push” application. We may also use this information to determine whether you need to be contacted if we have information or notices regarding “Push” on your particular platform or configuration.

    User Preferences
    The “Push” application will retain user preferences across sessions. These preferences are retained in order to eliminate the need for the user to configure the “Push” application each time it is launched. These preferences are only stored on your mobile device, and is not communicated outside of the mobile device.

    Audio
    The principal purpose of the “Push” application is to communicate with other “Push” application users, IP-connected dispatchers as well as DMR radio users using individual voice calls, group voice calls and messages. Audio is collected using the mobile device’s microphone for transmission to the “Push” server when the app’s “Push-To-Talk” (PTT) button is being pressed. The “Push” server will distribute such audio to the intended recipient(s). No audio is collected when the PTT button is not pressed. You must opt-in for the “Push” application to be able to access your microphone. You can opt-out at any time. Neither the “Push” application nor the “Push” server permanently retains any audio routed between “Push” clients and other recipient devices such as dispatchers and connected DMR radios. Audio is only temporarily stored in volatile memory (also typically referred to as RAM) during routing (in the case of the server) and playback (in the case of the application), but none of this information persists.

    Messages
    Messages are composed using the mobile device’s keyboard, but only sent to the “Push” server when the “Send” button is pressed. The “Push” server will distribute such messages to the intended recipient(s). Messages can contain images, but you must opt-in for the “Push” application to be able to access your camera and/or photos for inclusion in “Push” messages. You can opt-out at any time. The “Push” application stores messages sent, received and being composed in a folder that is accessible to the user. Messages are retained for user convenience and reference. You can opt-out of a message being retained by deleting the message. The “Push” server does not permanently retain any messages routed between “Push” clients and other recipient devices such as dispatchers and connected DMR radios. Messages are only temporarily stored in the server’s volatile memory (also typically referred to as RAM) during routing, but none of this information persists.

    Location Information
    The “Push” application will automatically access your location and send it to the “Push” server when location sharing is enabled. You must opt-in to share your location using your mobile device’s operating system settings for the “Push” application. You can opt-out at any time. The “Push” server distributes any location data it receives amongst the users that share your talk groups such that all members of a talk group can see the location of all other members of the same talk group (provided such other members opted-in to sharing their location information).The administrator of your organisation’s “Push” subscription can also enable historical tracking on the “Push” server, which will cause the “Push” server to retain location data transactions in a secure database. This database can be viewed on a map by your organisation’s management users and administrators, and exported as a “csv” file. Historical tracking is also accessible via a webservice API for use in your organisation’s third party applications (if any). Please contact the administrator of your organisation’s “Push” subscription for information whether historical tracking has been enabled for your organisation.

    Opting out
    You may opt out of all information collection by uninstalling the “Push” application. You may use the standard uninstall processes as may be available as part of your mobile device or via the mobile application marketplace or network. You can opt-out of sharing the following information using your mobile device’s operating system settings for the “Push” application:
    • Microphone – which will prevent the application from making voice calls;
    • Location Data – which will prevent your location data being sent to the “Push” server; and/or
    • Camera and/or Photos – which will prevent images from being included in your messages.

    Data Retention
    We will retain data for as long as you use the “Push” application and for a reasonable time thereafter. If you’d like us to delete data that you have provided via the application, please contact us via email and we will respond in a reasonable time. Please note that some data may be required in order for the “Push” application to function properly, and we may be required to retain certain information by law – we will inform you accordingly if this is the case.

    Mobile Phone Call Interaction
    If a mobile phone call is made or received while you are signed into the “Push” application, no “Push” audio will be transmitted or received as your mobile device’s microphone and speaker will be routed to the mobile phone call instead. However, you will continue to be signed into the “Push” application, will receive events and can send messages, provided that you are on a mobile network and plan allowing for data and voice calls to run concurrently.

  9. Contact us

    If you have any questions or would like further information about our privacy policies or practices, please contact us by any one of the following means:
    • Email: inquiry.aus@simocowireless.com
    • Post: ATT: Privacy Officer, Simoco Wireless Solutions Pty Ltd, 1270 Ferntree Gully Rd Scoresby, VIC 3179, Australia

  10. Data breaches or complaints

    If you wish to report a data breach or make a complaint about the way we have collected, used, held or disclosed any Personal Information, please contact us using the contact details listed in the “Contact us” section above.

    To assist us in helping you, please gather all supporting documents about the matter of complaint, think about the questions you want answered and decide on what you want us to do.

    We will use the information you provide to investigate and respond to your data breach report or privacy complaint. We aim to resolve all complaints as quickly as possible. Some complaints are resolved within weeks, but more complex complaints may take longer. You may withdraw your complaint at any time.

    If we do not resolve your complaint to your satisfaction and no other complaint resolution procedures are agreed or required by law, we will inform you that your complaint may be referred to the Privacy Commissioner for further investigation and will provide you with the Commissioner’s contact details.

  11. Changes to our Privacy Policy

    We reserve the right to change our Privacy Policy at any time. We will provide notification about changes to this Privacy Policy by posting an updated version on our website at: https://www.simocowirelesssolutions.com. Our most recent Privacy Policy will apply to our collection, use and disclosure of Personal Information.
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