Last Modified January 31, 2023
For the purpose of this policy, the “Service(s)” include payment processing and billing services provided directly to Business Partners or to Customers purchasing products and services of our Business customers.
California Resident Notice: for California Residents please see our Privacy Notice available here: CPRA.
We have included below information about which data is collected, how we process and use your data, but before, we would like to explain the basis on which we do so:
- Where a Business Partner registers for any of our Services, we process a Business Partner’s Personal Information in order to perform our contract with the Business Partner, or to prepare for such contract;
- Where a Customer uses our Services to process payment to our Business Partners or purchase the good and services they offer, we process the Customer’s Personal Information in order to perform our contract with the Customer, and the Customer’s request (and consent) to process the payment;
- When visitors access our Website(s), we process certain online information which we have a legitimate interest in processing such data, for purposes of functionality, compatibility, anti fraud monitoring; or
- We will also process your Personal Information where you have provided us with consent to do so.
Depending on your interaction with us (meaning, if you are a Visitor that just browses our Website, or if you have registered to our Services and opened an account, etc.), we may collect one or two types of information you, as follows:
- Non-Personal Information: The first type of information is non-identifiable information which may be made available or gathered through your use of the Services. To clarify, we are not aware of your identity due to such information (“Non-Personal Information”). The Non-Personal Information which is being collected may include your aggregated usage information and technical information transmitted or automatically collected such as (but not limited to): the time and date you access our Website, your actions within our Services (e.g., registration, pages viewed, etc.), type of operating system, type of browser, language preference and approximate geo-location (country level).
- Personal Information: The second type of information is individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual (“Personal Information”). Personal Information includes either: (i) contact information such as your name, phone number, address, email address, etc., which you have submitted voluntarily; (ii) your Internet Protocol (“IP”) address and MAC address or other Online Identifiers. Note that, while IP and MAC address are considered personally identifiable information in many jurisdictions (such as the EEA), there are some jurisdictions in which such data is not considered as Personal Information. Therefore, we treat such information as Personal Information, in accordance with applicable laws; (iii) payment information such as, individual taxpayer number, BIN and last four digits of the credit card number. All payment information is handled through industry standard secure protocols and where appropriate in accordance with relevant Payment Card Industry (“PCI”) compliance standards.
How We Collect Information
Depending on the nature of your interaction with the Services, we may collect information as follows:
- Provided by you voluntarily – we will collect information if and when you choose to provide us with the information, such as through a registration process, contact us communications, payment process, etc.
- By third-parties – for example, our third party services providers who process your information on our behalf, such as support centres, credit vendors, and so forth.
You are not required by law to provide us with any information. You can always avoid providing us with certain Personal Information; however, you acknowledge that it may prevent us from providing you certain Services that rely on such information.
In the event we combine Personal Information with Non-Personal Information, the combined information will be treated as Personal Information for as long as it remains combined, or attributable to an individual person.
Information we collect from visitors of our Website
|Type of Information||Purpose|
|In the event you contact us for support or other inquiries, either through the online form available on the Website, by sending us an email or by other means of communications we make available, you will be requested to provide us your name and email address.||We will use this information solely for the purpose of responding to your inquiries and providing you with the support or information you have requested.|
|In the event you are interested in joining our team, and wish to submit your CV, you will be required to provide us with your name, email address, phone number, and to submit your CVs.||Your provision of personal information in connection with recruiting is voluntary, and you determine the extent of information you provide us. We will use the information you have provided solely to communicate with you, to manage our recruiting and hiring processes, and to comply with corporate governance, legal and regulatory requirements. If you are hired, the information may be used in connection with employment and corporate management.|
|If you voluntarily subscribe to our newsletter you will be asked to provide us with your email address. You can unsubscribe at any time using the unsubscribe option within the body of the newsletter or rather or by contacting customer support at firstname.lastname@example.org||We will use your email address as part of our mailing list, in order to send you information related to our Services and to keep you up to date regarding new Services, as well as provide you with Business-to-Business tips.|
|IP address, cookies, tags, pixels and similar online identifiers, including browser agents, device identifiers, and referrer URL are processed about Visitors and Customers. (“Online Identifiers”)||We either directly or indirectly may collect Visitors’ IP address, certain cookies information for session validation, anti-fraud and anti-spam purposes, so as for compatibility and website functionality. For these purposes, we use this information as part of our legitimate interests of (i) operating, providing, maintaining, protecting, managing, customizing and improving our Website and Services and the way in which we offer them; (ii) enhancing your experience with the Services; and (iii) fraud prevention and browsing protection.
Additional use is based on your consent and includes auditing, analyzing and tracking usage and traffic flow (analytics and business intelligence).
|We also collect certain technical Non-Personal Information (as detailed above) which relates to your use of the Website. This includes user agents (namely, the browser you use, version, language).||We use this technical data in order to operate and manage our Website.|
Information We Collect from Business Partners
|Type of Information||How Do We Use It?|
|You can sign up as a Business Partner through our Website, during which you will be required to register and open an account. During the registration flow, you will be requested to provide us with certain information such as your full name, email address, phone number, company name and address. Further, during the registration process, you will be required to create a password, at which time you thereby represent and warrant that you are responsible for maintaining the confidentiality of your details and password. You represent and warrant that you will not provide us with inaccurate, misleading or false information.||We will use this information for the purpose of performing our contract with you, providing you with the Services you have requested, and designating your account. We will use your email address and phone number in order to send you needed information related to the Services and our business engagement (e.g., send you a Welcome message, to notify you regarding any updates to our Services, send applicable invoices, and additional occasional communications related to the Services) as well as verify your identity.|
|We also collect certain technical Non-Personal Information (as detailed above) as a Visitor to the Website and as detailed above.||see the table above.|
Information We Collect from Customers of the Service
|Type of Information||How Do We Use It?|
|When you purchase a product through our Service you will be requested to provide us with certain information that is related to your payment and billing, such as your full name, email address, postal code, address, country and payment information as per your selected payment method. You have the option of also providing us with your phone number.||We will use this information for the purpose of performing our contract with you, provide you with the Services you have requested and facilitate your payment of the goods, products or services you purchase, billing and tracking renewals. If a phone number is provided, support staff may contact you via a free call in order to provide assistance on use, functionality or installation of your purchased products.|
|We also collect certain technical Non-Personal Information (as detailed above) as a visitor to the Website and as detailed above.||see the table above.|
Sharing Personal Data
As a general principles, we do not share Personal Information collected from you with third parties unless required to provide, process or facilitate the Services, monitor them, protect or operate them, including with the following categories of third parties, in the respective circumstances:
- Third Party service providers – share your information with third parties that perform services on our behalf (e.g. API providers, payment process, tracking, servers, service functionality and support, marketing, etc.) these third parties may be located in different jurisdictions and include credit vendors, banks and other payment processing solutions;
- Law Requirement– we will share your information, solely to the extent needed to comply with any applicable law, regulation, legal process or governmental request (i.e., to comply with courts injunction, etc.);
- Policy Enforcement – we will share your information, solely to the extent needed to enforce our policies including investigations of potential violations thereof or to detect, prevent, or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues;
- Company’s Rights – we will share your information, solely to the extent needed to establish or exercise our rights to defend against legal claims;
- Third Party Rights – we will share your information, solely to the extent needed to prevent harm to the rights, property or safety of us, our users, yourself or any third party or for the purpose of collaborating with law enforcement agencies or in case we find it necessary in order to enforce intellectual property or other legal rights.
- Affiliated companies – certain marketing information, such as mailing address may be accessible to our affiliated companies, who operate in the same corporate group as ours.
- Business Partners – when we provide the Services to a Business Partner through which you encounter our Services, we will process information on their behalf and will share certain billing, order and invoicing information with such a Business Partner.
We may store Non-Personal and Personal Information on our servers or our cloud servers, use or share Non-Personal Information in any of the above circumstances, as well as for the purpose of providing and improving our Service as detailed above. Furthermore, we reserve the right to use, disclose or transfer (for business purposes or otherwise) aggregated and processed data to third parties, including, inter alia, affiliates, for various purposes including commercial use. This information may be collected, processed and analyzed by us and transferred in a combined, collectively and aggregated manner (i.e., your information is immediately aggregated with other users) to third parties.
We retain the information we collect as long as it remains necessary for the purposes set forth above, all in accordance with applicable laws, or until an individual expresses a preference to completely delete their information, as per data protection legislation, unless such information that is required by applicable local law to be further retained (for example, billing information for taxation purposes). We may at our sole discretion, delete or amend information from our systems, without notice to you, once we deem it is no longer necessary for such purposes.
We take great care in implementing and maintaining the security of our Website, Services and your information. We employ PCI compliance (all systems are PCI Level 1 Service Provider certified. Company is PCI-DSS level 1 requirements compliant), we have implemented technical organizational monitoring protections, and established an extensive information and cyber security program, all with regards to Personal Information processed by Company. For more information regarding our security measures please see https://www.simplelinknetwork.com/security.asp.
Further, in the event of a data incident, in which we discover your Personal Information may be at risk, then we will take reasonable efforts to notify you and the applicable authority (if required, subject to applicable laws).
Depending on your place of residence, you may be eligible to certain right as follows:
- the right to access any information which is provided to us;
- the right to rectification;
- the right to erasure;
- the right to restrict processing;
- the right to object to processing;
- the right to data portability;
- the right to complain to a supervisory authority; and
- the right to withdraw consent (to the extent applicable).
We provide you with the ability to exercise certain choices and controls in connection with our treatment of your Personal Information, depending on your relationship with us. For more information, please review our user right policy available at: https://www.simplelinknetwork.com/users.asp.
If you wish to exercise any or all of the above rights, please either use the dashboard of your account or please contact our Data Protection Officer at: email@example.com and provide sufficient information about your request, and order, so we will be able to validate it.
Where we are not able to provide you with the information for which you have asked, we will endeavor to explain the reasoning for this and inform you of your rights, including the right to complain to the supervisor authority. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any such information in accordance with applicable law. In addition, the process of locating and deleting the data may take up to one (1) month (following the receipt of the validation proof we require) in accordance with applicable law.
Data privacy and related laws in your jurisdiction may provide you with different or additional rights related to the data we collect from you, which may also apply.
Cookies and web technologies
|Facebook Analytics||Enable use of the Service and analytics purposes||https://www.facebook.com/policies/cookies/|
|Analytics purposes||https://www.google.com/policies/privacy/partners||United States based on Standard contractual Clauses and security measures|
|Yahoo Analytics||Analytics purposes||https://legal.yahoo.com/us/en/yahoo/privacy/index.html|
|Simple Link Network Cookies||Enable the use of the site and service and analytics purposes||Canada (For EEA, an adequate location)|
For more information about cookies and your controls via your browser’s settings, you may review the following links:
- Google Chrome – https://support.google.com/chrome/answer/95647?hl=en;
- Mozilla Firefox – https://support.mozilla.org/en-US/kb/enhanced-tracking-protection-firefox-desktop;
- Opera – https://www.opera.com/help/tutorials/security/cookies/;
- Safari – https://support.apple.com/en-ca/guide/safari/sfri11471/mac; and
- Edge – https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy.
Most browsers will allow you to erase cookies from your computer’s hard drive, block acceptance of cookies, or receive a warning before a cookie is stored. However, if you block or erase cookies some features of the Services may not operate properly and your online experience may be limited.
Occasionally, Simple Link Network receives information from third parties to compare it to information that you had provided to Simple Link Network for fraud prevention purposes.
Any websites displayed to you by our Website as Internet search results or linked to Internet search results pages provided to you by our Website, including websites owned or operated by our clients, have been developed by third parties over which Simple Link Network exercises no control. Simple Link Network is not responsible for the privacy practices or the content of such websites, including such websites’ use of any information collected when you are directed to or click through to such websites. Even though such information might not identify you personally, we strongly encourage you to become familiar with the privacy practices of those websites.
We may send our Business Partners and Customers an email or other messages about us or our Services. We may also send our updates or newsletter to individuals who have registered to the newsletter or used our Services. You can remove your Personal Information from our mailing list and stop receiving promotional communications from us by following the unsubscribe link located at the bottom of each communication or by emailing us at firstname.lastname@example.org.
Please note that in the event you are our Business Partner, even if you unsubscribe, we reserve the right to send you service-related communications, including service announcements and administrative messages, relating either to your account or to your transactions the Services, without offering you the opportunity to opt out of receiving them unless you terminate and delete your account. If you wish to delete your Account, please contact us at: email@example.com. Note that, even if we will delete your account, we will not delete certain information required under applicable law or otherwise, required for the legitimate purposes of our business. For example, we will not delete any invoices sent to you as we need it for the purpose of managing our financials.
Do Not Track Disclosure
The Service does not respond to Do Not Track signals. For more information about Do Not Track signals, please see: https://www.allaboutdnt.com/.
Data Transfer Outside of the EEA
We are committed to privacy and are actively involved in and support current industry initiatives to preserve individual privacy rights on the Internet. Protecting your privacy online is an evolving area, and Simple Link Network Website is constantly evolving to meet these demands.
Simple Link Network Ltd
28, Triq Hal Dwieli, Sliema, Zebbug ZBG 3250, Malta.
Data Protection Officer
Please include your name, address and email address in any correspondence so that we can respond to your inquiry or request.