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.
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
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.
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.
If you wish to access other personal information please contact us at firstname.lastname@example.org. 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.
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
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).