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Effective Date: 28 July, 2017

This policy sets out how Encapto Holdings Pty Ltd and its subsidiaries (“Encapto”) collects, uses and enables access to personal information that it collects. Encapto is bound by the National Privacy Principles in Australia, the GDPR in Europe and the United Kingdom and other privacy legislation around the world.

In all the jurisdictions in which we operate, Encapto aims to uphold the highest privacy standards for its clients and end users. We aim to be transparent in what data we collect and in how that data is processed and we provide our clients with tools that enable them to do the same.

By accessing or using Encapto services you agree to the use of your personal information in the manner described in this policy.

Scope

This policy applies to the information we obtain through your use of Encapto services, which include:

  • Our websites;
  • The Encapto platform;
  • The Encapto partner portals; and
  • Interaction with Encapto staff.

What personal information is collected?

Encapto collects personal information from our clients and partners, and from end-users of our services. In each case, the information collected and the way in which we use information is different.

Client Account Information

We collect information about you and your company when you become a partner, modify information through our portals, and make purchases from us. Information we collect includes:

  • Contact information such as name, email address, mailing address, and phone number
  • Billing information such as credit card details and billing address
  • Contact information such as a username and job title
  • Preferences information such as notification and marketing preferences
  • User IDs and passwords for Encapto Services

Client Content

We collect and store Content that you create or upload in the process of using our SaaS Products or Websites. Such Content includes any Personal Information or other sensitive information that you may choose to include.

Client Usage Data

We collect information from our Clients when they use, access, or interact with Encapto Services. We collect and store information on how our clients use our products and services, records of transactions, and the content of communications between our clients and Encapto.

End User Data

We collect data from end-users when an end user logs into a WiFi service that is managed by the Encapto platform. In this instance, Encapto acts as a processor of end user data that is collected by our clients. Our clients decide what end-user data are collected, the purposes for which it is collected, and the length of time for which it will be stored.

The Encapto platform enables the collection of end user data that includes:

  • Information about the device that you use to access an Encapto managed service including OS and browser type;
  • Information about the location of your device while using an Encapto managed service;
  • Information about your use of the service including time stamps, data usage, website visits; and
  • Information that you provide when you login, including survey responses, email addresses, and social media account details.

The Encapto platform is built to ensure that our clients are able to gain explicit consent from end users as to the purpose of the data collection. Additional work is being carried out now that will allow the end user to access, modify, or erase data that is collected about them when enabled by our clients.

How we Use Information

Client Account Information

We use Client Account information (including Personally Identifiable Information) to:

  • Operate, maintain, improve, and promote Encapto Services;
  • Enable you to access and use Encapto Services, including uploading, downloading, and sharing Content;
  • Process and complete transactions, and send you related information, including purchase confirmations and invoices;
  • Send transactional messages, including responding to your comments, questions, and requests; providing customer service and support; and sending you technical notices, updates, security alerts, and support and administrative messages;
  • Send promotional communications, such as providing you with information about services, features, surveys, newsletters, offers, promotions, contests, and events and providing other news or information about us and our select partners. You have the ability to opt out of receiving any of these communications as described below;
  • Enable you to communicate, collaborate, and share Content with users you designate; and
  • For other purposes about which we obtain your consent.

Client Content

For the avoidance of doubt, client content is controlled by you. You warrant that you have the necessary permissions and licences to use client content when you agree to the Encapto Licence Agreement. Encapto may use client content to promote the Encapto platform.

Client Usage Data

We use your usage data to:

  • Monitor and analyze trends, usage, and activities in connection with Encapto Services; and
  • Investigate and prevent fraudulent transactions, unauthorized access to Encapto Services, and other illegal activities.

End User Data

When end-user data is collected by our clients, Encapto does not have access to unit record data that would enable identification of any individual end user except to the extent that it is necessary for maintaining our platform and providing helpdesk services to our clients.

We do not otherwise access, disclose, sell or otherwise use end user Personal Information for any purpose.

How to access your personal information

You have a right to access your Personal Information.

Encapto clients can access and update Personal Information by signing in to a service or portal.

Encapto is currently working on a self-service portal for end users, which will enable access to Personal Information held about them. This Privacy Policy will be updated when this work is completed.

If you wish to access other personal information please contact us at info@encapto.com. Encapto reserves the right to charge you an administration fee of $US25 for providing access to your personal information and will, of course, require some proof of your identify before providing information to you.

Cookies

If you visit Encapto websites, including encapto.com or any other Encapto website (“Websites”) we may use "cookies". Cookies are small text files that we save to your computer's hard drive to enable our systems to recognise your browser and your login status. Cookies may also be used to record non-personal information such as the date, time or duration of your visit and the pages accessed, for statistical, maintenance, and website administrative purposes. Most browsers allow cookies by default, but you can easily erase, block, or receive a warning before a cookie is stored. Please note that some parts of our Websites may not function fully for users that block cookies.

Changes to this Policy

We may update this Privacy Policy from time to time.

If we make any changes, we will revise the date at the top of this Privacy Policy.

If we make any material changes, we will provide you with additional notice (such as by adding a notice on the Encapto platform login screen, or by sending you an email notification).

We encourage you to review our Privacy Policy whenever you use Encapto Services to stay informed about our information practices and the ways you can help protect your privacy.

If you disagree with any changes to this Privacy Policy, you will need to stop using Encapto Services and deactivate your accounts.


Previous version: 04.03.2017

This policy sets out how Encapto Holdings Pty Ltd and its subsidiaries (“Encapto”) collects, uses and discloses your personal information. Encapto is bound by the National Privacy Principles as set out in the Privacy Act 1988 (Cth).

By accessing or using Encapto services you agree to the use and disclosure of your personal information in the manner described in this policy.

What personal information is collected?

Encapto collects personal information that is necessary to provide the range of services we offer.
Personal information collected by Encapto may include:

  • Your name, address and contact details
  • Your date of birth
  • User IDs and passwords for Encapto services
  • Information on how you use our products and services
  • Records of transactions between you and Encapto
  • Records and content of communications between you and Encapto
  • Your IP address, server address, domain name and information on your browsing activity when visiting one of our websites
  • Your User Name for social networking sites that you use, or refer to, in conjunction with our products and services

How is personal information collected?

Encapto collects personal information in a number of ways, including:

  • directly from you when you:
    • provide information directly to Encapto in person, by phone or in writing (whether electronic or otherwise)
    • communicate with Encapto or any other person using Encapto services
  • from third parties such as:
    • Encapto related companies; resellers of Encapto services and service providers to Encapto
  • from organisations identified or described under the heading "How is personal information disclosed"

How is personal information used?

Your personal Information may used for the following purposes:

  • to provide the services requested by you
  • to manage those services, including customer service and billing
  • to research, develop and improve Encapto services
  • to conduct surveys to determine use and satisfaction with Encapto services
  • to promote and market special offers and other services to you. If you do not want to receive these, please let us know.

How is personal information disclosed?

Encapto may disclose personal information to third party individuals and organisations, including:

  • Encapto staff
  • The public if you advertise with Encapto or use publicly available Encapto communication services
  • Outsourced service providers who assist Encapto to provide its services
  • Resellers of Encapto services
  • Organisations involved in a sale/transfer of Encapto assets, business or shares
  • Government and regulatory authorities as required by law

Cookies

If you visit Encapto websites, including encapto.com or any other Encapto website (“Websites”) we may use "cookies". Cookies are small text files that we save to your computer's hard drive to enable our systems to recognise your browser and your login status. Cookies may also be used to record non-personal information such as the date, time or duration of your visit and the pages accessed, for statistical, maintenance, and website administrative purposes. Most browsers allow cookies by default, but you can easily erase, block, or receive a warning before a cookie is stored. Please note that some parts of our Websites may not function fully for users that block cookies.

How to access your personal information

You have a right to access your Personal Information. Most Encapto services will allow you to access and update your Personal Information by signing in to that service.
If you wish to access other personal information please click on the "contact us" link at the bottom of any page of an Encapto website.
Encapto reserves the right to charge you an administration fee of $US25 for providing access to your personal information and will, of course, require some proof of your identify before providing information to you.

What if you don't provide personal information?

If you choose not to provide personal information when requested, Encapto may not be able to provide you with the full range of Encapto services.

Security of your Personal Information

Encapto will take reasonable steps to ensure that the personal information that we collect, use or disclose is accurate, complete, up-to-date and stored in a secure environment protected from unauthorised access, modification or disclosure.

Changes to this Policy

This policy may change over time. All changes will be published on this website. Encapto Customers are encouraged to review this policy on a regular basis.

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