General Data Protection Regulation (GDPR) was enforced in Europe and the UK as an EU regulation from 25 May 2018. It intends to strengthen and unify data protection for individuals within the EU.
In response to this, leading cloud providers are adapting themselves accordingly, and looking beyond technological capacity. In addition to provide high performance and secure services, OPTIMOGOV ensures that these solutions comply with all applicable data protection regulations, and maintains transparency in terms of how the solutions work.
By complying with GDPR, end customers will have confidence purchasing from our clients and submitting their details. We, at OPTIMOGOV, implemented measures in order to help our clients comply with GDPR as data controllers and Programus to comply as a data processor.
OPTIMOGOV is focused on giving creative arrangements that adhere to best practice guidelines and, regarding information, follow the Privacy by Design technique. Our Data Privacy is a piece of the Core Software and CRM module. It empowers your association to name a Data Protection Officer who will have the option to decide how contacts are put away and overseen in your database dependent on predefined Automation.
OPTIMOGOV AND ITS COMMITMENTS ON PERSONAL DATA
OPTIMOGOV processes its customers’ personal data solely for the purpose of fulfilling its services, and always follows the customer’s instructions when doing so. The data hosted within our services remains the property of the customer.
OPTIMOGOV maintains strict security measures to avoid data breaches. If OPTIMOGOV ever experience a data breach, we will ensure that the clients concerned are informed as soon as possible. The Client will receive a notification describing the nature of the incident and its potential consequences, as well as the measures taken to resolve or minimise the breach.
We take every precaution to ensure that the personal data we process stays secure and confidential in OPTIMOGOV. More specifically, our objective is to stop it from being altered or accessed by non-authorised third parties.
OPTIMOGOV controls the entire hosting chain, from maintaining its servers to controlling its datacenters. With the exception of our subsidiaries, and unless otherwise stipulated in the specific terms and conditions of the service in question, no other users will be able to view or access our customers’ data.
Programus (UK) Ltd (Software and service branded as OPTIMOGOV Software) UK REG 03923052 and our Related Companies (together referred to as Programus, OPTIMOGOV, us or we) recognise the importance of privacy protection. Accordingly, Programus (UK) Ltd (Software and service branded as OPTIMOGOV Software) complies with the Privacy Act 1988 (Cth) (the Privacy Act).
Some of the information you provide us as part of your dealings with us is “Personal Information” under the Privacy Act. This Privacy Policy sets out how we collect, handle, use, transmit and disclose your Personal Information and applies to you unless you give us explicit consent to act otherwise. By providing us with Personal Information, registering Account or otherwise using the Website or OPTIMOGOV Service, you acknowledge that you have read, understood and agree to be bound by this Privacy Policy and consent to us collecting, handling, using, transmitting and disclosing your Personal Information as set out in this Privacy Policy.
If you would like to know more about data protection generally in Australia and the European Union, there is information available from the: (a) Australian Information Commissioner (at www.privacy.gov.au); (b) UK Information Commissioner’s Office (at www.ico.org.uk); and (c) European Commission Data Protection Officer (at www.ec.europa.eu/dataprotectionofficer/).
WHAT TYPES OF PERSONAL INFORMATION DO WE COLLECT?
Personal Information we collect from you will depend on how you use the Website, whether you have registered an Account for the Website or are just a visitor to the Website. Personal Information we collect from you may include your name, postal address, email address, telephone number/s, Website Log-In-Details, billing information, credit card number and expiry date and other information required for payment for products and services provided by us through the Website and information necessary for us to provide the OPTIMOGOV Service to you.
HOW DO WE USE YOUR PERSONAL INFORMATION?
We will use your Personal Information for the purpose disclosed at the time of collection, or otherwise as set out in this Privacy Policy or the OPTIMOGOV User Agreement. Except as specifically set out in this Privacy Policy and the OPTIMOGOV User Agreement, we will not sell or disclose your Personal Information to any person located in Australia, the European Union or overseas or use your Personal Information for any other purpose without your prior consent, unless authorised or required by law. Generally, we will only collect, use and disclose your Personal Information for the following purposes:
- to register your Account or otherwise register you to use the Website;
- to provide you with information you request about us or the products or services we offer through the Website;
- to manage the Website (including your Account);
- to provide products or services you request from time to time, including the OPTIMOGOV Service;
- to process and obtain payment for any products or services you order from us through the Website;
- to understand your needs and Website usage to help us improve the Website, our marketing or the way we do business;
- if necessary, to verify your identity or age (i.e. over 18); and
- to contact you for direct marketing and promotional purposes including providing you with information about new products or services, events and special offers, unless you tell us that you do not wish to receive this type of information.
From time to time we may also ask you to participate in surveys or questionnaires. These help us to improve our levels of service and to maximize the opportunities and benefits you can enjoy.
We may send you electronic messages updating you about products, services, free trials and other offers. We will only send you such electronic messages if you have consented to receive them or it can be inferred from your existing business or other relationship with us, that there is a reasonable expectation of receiving those electronic messages. All electronic messages will identify us.
HOW DO WE USE INFORMATION THAT IS NOT PERSONAL INFORMATION?
From time to time we may sell or disclose information you provide us that is not Personal Information or does not disclose your identity or the identity of any individual to any person for any purpose at our sole discretion, including to people or companies located outside of Australia. For example, we may sell, disclose or use information you provide us that is not Personal Information to determine what advertising, promotional materials, products or services are likely to be of most interest to you or other Website visitors and to assist merchants and other third parties to monitor general consumer trends in various areas.
HOW DO WE COLLECT YOUR PERSONAL INFORMATION?
We collect Personal Information from information you provide directly to us when you set up an Account and register to use the Website, use the Website or the OPTIMOGOV Service, pay for a service provided by the Website, contact us, participate in surveys or questionnaires and from information you upload to the Website from time to time.
WHAT HAPPENS IF YOU DON’T PROVIDE US WITH THE INFORMATION WE REQUIRE?
If you don’t provide us with certain information, we may be unable to provide you the information, products or services you wish to buy or receive, including the OPTIMOGOV Service.
PERSONAL INFORMATION SECURITY
We will take commercially reasonable and appropriate steps to ensure your Personal Information is protected from risks such as loss, unauthorised access or use, destruction, modification or disclosure. Aside from the disclosure or transfer of your Personal Information to OVH, Azure and AWS and between our Related Companies (see “Where your information is stored” below), we only permit our authorised personnel to access your Personal Information.
The Internet is not a secure method of transmitting information. Accordingly, we cannot accept responsibility for the security of information you send to or receive from us over the Internet or for any unauthorized access, use or modification of that information.
The Website may provide links or references to other 3rd party websites and resources. These websites and resources are not subject to this Privacy Policy. You should review the privacy policy of each 3rd party website and resource accessed via links from our Website, and assess whether the policy of each website and resource is satisfactory to you before you use the website or resource. You acknowledge and agree that we are not responsible for any Personal Information you choose to disclose to a 3rd party through a 3rd party website referred to by or linked to our Website and that such 3rd parties may store your Personal Information in any location in accordance with their own security standards.
PAYMENT CARD INFORMATION
We may keep a record of your credit or debit card number if you choose to pay us directly for the OPTIMOGOV Service or any other products or services offered by us through the Website, particularly if you wish to have payments automatically debited from your nominated bank account at fixed intervals. We may keep details of your credit or debit card expiry dates and credit limit in order to provide you with products and services we offer through the Website.
USING 3RD PARTIES TO PROCESS YOUR INFORMATION
We may occasionally use third party companies (third party service providers) to manage information that you provide in order for us to provide the OPTIMOGOV Service. Aside from the disclosure or transfer of your Personal Information to OVH, Azure and AWS or between our Related Companies (see “Where your information is stored” below), when we use third party service providers, we keep the amount of Personal Information they hold to a minimum, have contracts in place to stop them using your information except on our behalf and obviously use commercially reasonable efforts to make sure they are as careful with your Personal Information as we are.
WHERE YOUR INFORMATION IS STORED
We engage OVH Web Services (OWH), Amazon Web Services (AWS) and Microsoft Azure to provide data storage services, cloud computing services, to host the OPTIMOGOV Service and to store Your Content, data and information submitted by you through your use of the OPTIMOGOV Service and our Website. OVH, Azure and AWS may transmit, maintain and store all or parts of Your Content, data and information (including Personal Information) on multiple servers across various jurisdictions in addition to servers in the United States. Your Content (including Personal Information) may also be transferred between Related Companies of OPTIMOGOV that are located in different jurisdictions, including the European Union, Australia and the United States. Servers in which your information (including Personal Information) may be stored by OVH, Azure and AWS are likely to be located in the United States, South America (Sao Paulo), Europe (Ireland, The Netherlands, Germany, England, Spain, Italy, France and Sweden) and the Asia Pacific (Singapore, Japan, China, Korea and Australia), although additional or other locations may be used by OVH, Azure and AWS in the future. Personal Information that you provide to us may be processed by Related Companies of OPTIMOGOV that are located in the European Union (Programus (UK) Ltd (Software and service branded as OPTIMOGOV Software)), which may transmit your Personal Information from the European Union to OPTIMOGOV or OVH, Azure and AWS outside of the European Union. The Programus (UK) Ltd (Software and service branded as OPTIMOGOV Software) and OVH, Azure and AWS are subject to domestic European privacy laws enacted under the EU Data Directive, including the Data Protection Act 1998 (UK) (together the EU Privacy Laws). EU Privacy Laws permit the Programus (UK) Ltd (Software and service branded as OPTIMOGOV Software) and OVH, Azure and AWS to transfer your Personal Information from the European Union to countries and territories outside of the European Union with your consent. In addition, the Privacy Act requires Programus (UK) Ltd (Software and service branded as OPTIMOGOV Software) to ensure that OVH, Azure and AWS, Programus (UK) Ltd (Software and service branded as OPTIMOGOV Software)’s Related Companies located in the United States or any other third party provider we may use from time to time, comply with applicable Australian privacy laws unless you agree otherwise. Acknowledging all of the above, by providing us with information (including Personal Information), using the OPTIMOGOV Service or our Website or registering an Account, you: (a) consent to OPTIMOGOV and the EU Programus (UK) Ltd (Software and service branded as OPTIMOGOV Software) disclosing and transferring Your Content, data and information (including the categories of Personal Information listed in this Privacy Policy) to OVH, Azure and AWS and Programus (UK) Ltd (Software and service branded as OPTIMOGOV Software)’s Related Companies located in the United States for the purpose of allowing OVH, Azure and AWS to host all data necessary to support the Website and for us to provide the OPTIMOGOV Service to you; (b) consent to OPTIMOGOV, the Programus (UK) Ltd (Software and service branded as OPTIMOGOV Software) and OVH, Azure and AWS transmitting, maintaining and storing Your Content, data and information (including the categories of Personal Information listed in this Privacy Policy) between and on servers located outside of Australia and the EU, including in the regions referred to above, and exchanging such information between our Related Companies in those regions to assist us to perform the OPTIMOGOV User Agreement and otherwise provide the OPTIMOGOV Service to you; and (c) agree that the requirement under the Privacy Act for us to ensure that OVH, Azure and AWS and Programus (UK) Ltd (Software and service branded as OPTIMOGOV Software)’s Related Companies located in the United States comply with applicable Australian privacy laws in respect of Your Content, data and information (including the categories of Personal Information listed in this Privacy Policy) does not apply. You acknowledge and agree that the transmission of your Personal Information between OPTIMOGOV, the Programus (UK) Ltd (Software and service branded as OPTIMOGOV Software) Companies and OVH, Azure and AWS, including the transfer of your Personal Information held by the Programus (UK) Ltd (Software and service branded as OPTIMOGOV Software) Companies and OVH, Azure and AWS to OPTIMOGOV, OVH, Azure and AWS and our other Related Companies located in countries and territories outside of the European Union, is necessary for us to maintain the Website, provide you with the OPTIMOGOV Service and for the performance of the OPTIMOGOV User Agreement generally. You also acknowledge that any data storage functionality associated with the OPTIMOGOV Service is not intended for the storage of social security numbers, credit or debit card numbers, financial account numbers, driver’s licence numbers, medical information, health insurance information, sensitive data about personal characteristics such as race, religion, or sexual orientation, personal data that may pose a risk of harm to the individual if improperly disclosed. We may engage other data storage providers or store your information on servers in other locations in the future and will update this Privacy Policy if that is the case. We suggest that you visit our Website regularly to keep up to date with any changes.
YOUR RIGHTS OF ACCESS AND CORRECTION
You have the right to access Personal Information which we have collected from you and ensure that it is correct and up to date, within the requirements of the Privacy Act.
If you wish to access your Personal Information, or believe that any of the Personal Information we hold about you is inaccurate, incomplete or out-of-date, please contact us at the email address shown at the bottom of this Privacy Policy. We will take reasonable steps to correct any inaccurate, incomplete or out of-date Personal Information if you request us to do so, where required by law.
We may withhold or refuse you access to your Personal Information if we are legally authorised to do so or where its disclosure to you is restricted by law, is the subject of legal action, or may compromise the privacy of another person.
We may charge you a reasonable fee to access your information if permitted by applicable law.
HOW CAN YOU STOP RECEIVING MARKETING INFORMATION?
Where marketing information is forwarded to you via electronic messages, there will be a functional ‘unsubscribe’ mechanism contained in the message.
If you no longer wish to be contacted by us or receive such marketing information, you can advise us:
- by emailing us at info@optimosoftware.co.uk; or
- by clicking the ‘unsubscribe function’ (where marketing information is sent electronically).
We will keep a record of your request to ensure you do not receive that information in the future.
You cannot refuse to receive information which we are required to provide you by law.
COOKIES
“Cookies” are small data files sent by a website and stored on your computer’s hard drive when you visit the website. A cookie can contain certain information that the website uses to track the pages you have visited. The only Personal Information a cookie can contain is information you personally supply. A cookie cannot read data off your hard disk or read cookie files created by other websites. Our Website uses cookies to assist with managing your account and to identify you on return visits. Most internet browsers automatically accept cookies, but you can usually change your browser to notify you when you receive a cookie or to reject cookies. However, while most of the content of our Website can be viewed without accepting cookies, full functionality for the Website requires the use of cookies.
CHANGES TO THIS PRIVACY POLICY
We may amend this Privacy Policy from time to time by posting the amended version on our Website at www.optimosoftware.co.uk. We suggest that you visit our Website regularly to keep up to date with any changes.
CONTACTING US
If you would like more information about this Privacy Policy or if you have any queries or complaints, please contact us by email at info@optimosoftware.co.uk. We will take reasonable steps try to resolve any complaints with you as quickly as practicable. Complaints may also be made directly to the office of the Australian Information Commissioner through its website located at www.privacy.gov.au/complaints.
DEFINITIONS
Unless otherwise defined in this Privacy Policy, words beginning with capital letters are defined in the OPTIMOGOV User Agreement.
For the purposes of this Privacy Policy:
Personal Information means any information or data which relates to a living individual who can be identified from, or whose identity is apparent or can reasonably be ascertained from, that information or data alone or in conjunction with other information already held by the recipient, controller or processor of such information or data and includes any expression of opinion about the individual and any indication of the intentions of the recipient or any other person in respect of that individual; and
OPTIMOGOV User Agreement means the OPTIMOGOV User Agreement available on the Website at www.optimosoftware.co.uk/terms as updated from time to time which you must read and accept as a condition of registering an Account and otherwise accessing and using the OPTIMOGOV Service.
Programus (UK) Ltd (Software and service branded as OPTIMOGOV Software) UK REG 03923052 and our Related Companies recognise the importance of privacy protection. Accordingly, Programus (UK) Ltd (Software and service branded as OPTIMOGOV Software) complies with the Data Protection Act 2018 UK (Data Protection Act). Programus (UK) Ltd (Software and service branded as OPTIMOGOV Software) is made up of different legal entities (our Related Companies), details of which can be found here [https://programus.co.uk/]. This Privacy Policy is issued on behalf of the Programus (UK) Ltd (Software and service branded as OPTIMOGOV Software) so when we mention “Programus” “OPTIMOGOV “ “we”, “us”, “our” in this Privacy Policy, we are referring to the relevant company in the Programus (UK) Ltd (Software and service branded as OPTIMOGOV Software) responsible for processing your Personal Information. Programus (UK) Ltd (Software and service branded as OPTIMOGOV Software) is the controller (as defined in the Data Protection Act) and is responsible for this Website.
Some of the information you provide us as part of your dealings with us is “Personal Information” or “Personal Data” under the Data Protection Act. This Privacy Policy sets out how we collect, handle, use, transmit and disclose your Personal Information and applies to you unless you give us explicit consent to act otherwise. By providing us with Personal Information, registering Account or otherwise using the Website or OPTIMOGOV Service, you acknowledge that you have read, understood and agree to be bound by this Privacy Policy and consent to us collecting, handling, using, transmitting and disclosing your Personal Information as set out in this Privacy Policy. Please use the “Definitions” section to understand the meaning of capitalised terms within this Privacy Policy.
If you would like to know more about data protection generally in the UK and European Economic Area, there is information available from the:
(a) UK Information Commissioner’s Office (at www.ico.org.uk); and (b) European Commission Data Protection Officer (at www.ec.europa.eu/ dataprotectionofficer/).
WHAT TYPES OF PERSONAL INFORMATION DO WE COLLECT?
Personal Information we gather from you will rely upon how you utilise the Website, regardless of whether you have enlisted an Account for the Website or are only a guest to the Website. The following is a list of the Personal Information we may gather, together with details of our support for preparing such Personal Information:
Customer Account Information: this is data about you which identifies with an Account you have enlisted with us, or which Your employer has enrolled with us where you are a contact related to that Account. This information may incorporate your name, your email address, and your telephone and/or mobile number. We will process this information to keep up and control your record with us thus that we can oversee our business properly (our legitimate interest). Where you have gone into an agreement with us, we will process your Personal Information so as to satisfy our agreement with you.
Registration information: When you register to utilise our Website and/or if you report an issue with our Website, we will process the Personal Information you give. This may incorporate your name, your contact details, and the Website sign in details you give. We will process this information so we can manage your enlistment, correspondence or to address your question or concern. The explanation we process this data is to guarantee the proper administration of your enrollment, correspondence or inquiry, and our business (our legitimate interest).
Transaction Data: If you buy the OPTIMOGOV Service or different items or services from us, you should give certain data to us. This may incorporate your name, charging data, Mastercard number and expiry date and other data required for installment of items and administrations given by us. We will process that information so as to play out our agreement with you and to satisfy the exchange (our legitimate interest).
Correspondence Data: If you speak with us, we may process the data contained in your correspondence, for example, your name and contact data, the substance of your correspondence, and any metadata our Website produces where you speak with us utilising the contact structure on our Website. We will process that data so we can relate with you and to guarantee we direct our business appropriately (our legitimate interest).
Regulatory Data: We may process your information if we need to do so in order to comply with our legal and/or regulatory obligations, with the goal that we can ensure the essential enthusiasm of you or another regular individual.
HOW DO WE USE YOUR PERSONAL INFORMATION?
We will use your Personal Information for the purpose disclosed at the time of collection, or otherwise as set out in this Privacy Policy or the OPTIMOGOV User Agreement. Except as specifically set out in this Privacy Policy and the OPTIMOGOV User Agreement, we will not sell or disclose your Personal Information to any person located in the UK, European Union or overseas or use your Personal Information for any other purpose without your prior consent, unless authorised or required by law. Generally, we will only collect, use and disclose your Personal Information for the following purposes:
- to register your Account or otherwise register you to use the Website;
- to provide you with information you request about us or the products or services we offer through the Website;
- to manage the Website (including your Account);
- to provide products or services you request from time to time, including the OPTIMOGOV Service;
- to process and obtain payment for any products or services you order from us through the Website;
- to understand your needs and Website usage to help us improve the Website, our marketing or the way we do business;
- if necessary, to verify your identity or age (i.e. over 18); and
- to contact you for direct marketing and promotional purposes including providing you with information about new products or services, events and special offers. You can tell us that you do not wish to receive this type of information at any time (see “How you can stop receiving marketing information” below).
From time to time we may also ask you to participate in surveys or questionnaires. These help us to improve our levels of service and to maximise the opportunities and benefits you can enjoy. Again, you can tell us you do not wish to be involved in such surveys or questionnaires at any time by using the contact details in this Privacy Policy.
We may send you electronic marketing messages updating you about products, services, free trials and other offers. We will only send you such electronic marketing messages if you have consented to receive them or it can be inferred from your existing business relationship with us, that there is a reasonable expectation of receiving those electronic marketing messages. All electronic marketing messages will identify us. You can unsubscribe from such electronic marketing messages at any time and/or tell us you no longer wish to receive such communications (see “How to stop receiving marketing information” below). We will get your express consent before we share your Personal Information with any third party for marketing purposes.
HOW DO WE USE INFORMATION THAT IS NOT PERSONAL INFORMATION?
From time to time we may sell or disclose information you provide us that is not Personal Information or does not disclose your identity or the identity of any individual to any person for any purpose at our sole discretion, including to people or companies located outside of UK/European Union. For example, we may sell, disclose or use information you provide us that is not Personal Information to determine what advertising, promotional materials, products or services are likely to be of most interest to you or other Website visitors and to assist merchants and other third parties to monitor general consumer trends in various areas.
HOW DO WE COLLECT YOUR PERSONAL INFORMATION?
We collect Personal Information from information you provide directly to us when you set up an Account and register to use the Website, use the Website or the OPTIMOGOV Service, pay for a service provided by the Website, contact us, participate in surveys or questionnaires and from information you upload to the Website from time to time.
WHAT HAPPENS IF YOU DON’T PROVIDE US WITH THE INFORMATION WE REQUIRE?
If you don’t provide us with certain information, we may be unable to provide you the information, products or services you wish to buy or receive, including the OPTIMOGOV Service.
INTERNATIONAL TRANSFERS
We share your Personal Information with Our Related Companies within the Programus (UK) Ltd (Software and service branded as OPTIMOGOV Software). This involves transferring your Personal Information outside the UK and the European Economic Area (EEA). We ensure your Personal Information is protected by requiring our Related Companies to conform to the same rules when processing your Personal Information. These rules are called “binding corporate rules”.
Wherever we transfer your Personal Information out of the UK and the EEA we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your Personal Information to countries that have been deemed to provide an adequate level of protection for your Personal Information by the European Commission.
- Where we use certain service providers we may use specific contracts approved by the European Commission which give Personal Information the same protection as it has in Europe.
- Where we use providers based in the US, we may transfer Personal Information to them if they are part of the Privacy Shield which requires them to provide similar protection to Personal Information shared between the EEA and the US.
PERSONAL INFORMATION SECURITY
We will take commercially reasonable and appropriate steps to ensure your Personal Information is protected from risks such as loss, unauthorised access or use, destruction, modification or disclosure. Aside from the disclosure or transfer of your Personal Information to OVH, Azure and AWS and between our Related Companies (see “Where your information is stored” below), we only permit our authorised personnel to access your Personal Information. They will only process your Personal Information on our instructions and they are subject to a duty of confidentiality.
The Internet is not a secure method of transmitting information. Accordingly, we cannot accept responsibility for the security of information you send to or receive from us over the Internet or for any unauthorised access, use or modification of that information.
The Website may provide links or references to other 3rd party websites and resources. These websites and resources are not subject to this Privacy Policy. You should review the privacy policy of each 3rd party website and resource accessed via links from our Website, and assess whether the policy of each website and resource is satisfactory to you before you use the website or resource. You acknowledge and agree that we are not responsible for any Personal Information you choose to disclose to a 3rd party through a 3rd party website referred to by or linked to our Website and that such 3rd parties may store your Personal Information in any location in accordance with their own security standards.
PAYMENT CARD INFORMATION
We may keep a record of your credit or debit card number if you choose to pay us directly for the OPTIMOGOV Service or any other products or services offered by us through the Website, particularly if you wish to have payments automatically debited from your nominated bank account at fixed intervals. We may keep details of your credit or debit card expiry dates and credit limit in order to provide you with products and services we offer through the Website.
USING 3RD PARTIES TO PROCESS YOUR INFORMATION
We may occasionally use third party companies (third party service providers) to manage information that you provide in order for us to provide the OPTIMOGOV Service. Aside from the disclosure or transfer of your Personal Information to OVH, Azure and AWS or between our Related Companies (see “Where your information is stored” below), when we use third party service providers, we keep the amount of Personal Information they hold to a minimum, have contracts in place to stop them using your information except on our behalf and obviously use commercially reasonable efforts to make sure they are as careful with your Personal Information as we are. Where such third party service providers are based outside the UK and/or the EEA we will ensure such third party service providers have adequate levels of protection in place as described above (see “International Transfers”).
WHERE YOUR INFORMATION IS STORED
We engage OVH Web Services (OVH), Microsoft Azure, and Amazon Web Services (AWS) to provide data storage services, cloud computing services, to host the OPTIMOGOV Service and to store Your Content, data and information submitted by you through your use of the OPTIMOGOV Service and our Website. OVH, Azure and AWS may transmit, maintain and store all or parts of Your Content, data and information (including Personal Information) on multiple servers across various jurisdictions in addition to servers in the United States. Your Content (including Personal Information) may also be transferred between Related Companies of Programus (UK) Ltd (Software and service branded as OPTIMOGOV Software) that are located in different jurisdictions, including the UK, the EEA, Australia and the United States. Servers in which your information (including Personal Information) may be stored by OVH, Azure and AWS are likely to be located in the United States, South America (Sao Paulo), Europe (Ireland, The Netherlands, Germany, England, Spain, Italy, France and Sweden) and the Asia Pacific (Singapore, Japan, China, Korea and Australia), although additional or other locations may be used by OVH, Azure and AWS in the future. Personal Information that you provide to us will be processed by us or other Related Companies located in the UK and/or the EEA (Programus (UK) Ltd (Software and service branded as OPTIMOGOV Software) Companies), and we and the other Programus (UK) Ltd (Software and service branded as OPTIMOGOV Software) may transmit your Personal Information from the UK and/or the EEA to other Programus (UK) Ltd (Software and service branded as OPTIMOGOV Software) Related Companies or OVH, Azure and AWS outside of the UK and/or EEA, including in Australia and the United States. We, the other Programus (UK) Ltd (Software and service branded as OPTIMOGOV Software) Companies and OVH, Azure and AWS are subject to domestic European privacy laws enacted under the EU Data Directive, including the General Data Protection Regulation EU 2016/679 and the Data Protection Act 2018 (UK) (together the EU Privacy Laws). EU Privacy Laws permit us, the other Programus (UK) Ltd (Software and service branded as OPTIMOGOV Software) Companies and OVH, Azure and AWS to transfer your Personal Information from the UK and/or the EEA to countries and territories outside of the UK and/or the EEA with your consent provided that we process your Personal Information in accordance with the requirements of EU Privacy Laws. Acknowledging the above, by providing us with information (including Personal Information), using the OPTIMOGOV Service or our Website or registering an Account, you: (a) consent to us and the other Programus (UK) Ltd (Software and service branded as OPTIMOGOV Software) Companies disclosing and transferring Your Content, data and information (including the categories of Personal Information listed in this Privacy Policy) to OVH, Azure and AWS and our Related Companies located in the United States for the purpose of allowing OVH, Azure and AWS to host all data necessary to support the Website and for us to provide the OPTIMOGOV Service to you; (b) consent to us, the other Programus (UK) Ltd (Software and service branded as OPTIMOGOV Software) Companies and OVH, Azure and AWS transmitting, Your Content (including the categories of Personal Information listed in this Privacy Policy) from the UK and/or EEA, to servers, OVH, Azure and AWS and our Related Companies located outside of the UK and/or the EEA, to maintaining and storing Your Content, data and information (including the categories of Personal Information listed in this Privacy Policy) between and on servers located outside of the UK and/or EEA, including in the regions referred to above; and exchanging such information between our Related Companies in those regions to assist us to perform the User Agreement and otherwise provide the OPTIMOGOV Service to you. You acknowledge and agree that the transmission of your Personal Information disclosed by you to us between us, the other Programus (UK) Ltd (Software and service branded as OPTIMOGOV Software) Companies, OVH, Azure and AWS and our Related Companies located outside of the UK and/or EEA (including Australia and the United States), is necessary for us to maintain the Website, provide you with the OPTIMOGOV Service and for the performance of the User Agreement generally. You also acknowledge that any data storage functionality associated with the OPTIMOGOV Service is not intended for the storage of national insurance numbers, credit or debit card numbers, financial account numbers, driver’s licence numbers, medical information, health insurance information, sensitive data about personal characteristics such as race, religion, or sexual orientation, personal data that may pose a risk of harm to the individual if improperly disclosed. We may engage other data storage providers or store your information on servers in other locations in the future and will update this Privacy Policy if that is the case. We suggest that you visit our Website regularly to keep up to date with any changes.
HOW LONG DO WE USE YOUR PERSONAL INFORMATION FOR?
We will only retain your Personal Information for as long as reasonably necessary for the purposes we collected it, including the purpose of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your Personal Information for a longer period if there is a complaint or if we reasonably believe there is a prospect of litigation in respect of our relationship with you. To determine the appropriate retention period for Personal Information we consider the amount and sensitivity of the Personal Information, the potential risk of harm from unauthorised use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means and the applicable legal, regulatory, tax, accounting or other requirements.
YOUR LEGAL RIGHTS
You have the privilege to get to Personal Information which we have gathered from you and guarantee that it is correct and up to date, within the requirements of the Data Protection Act. If you wish to get to your Personal Information or accept that any of the Personal Information we hold about you is wrong, fragmented, or outdated, please get in touch with us at the email address that appeared at the base of this Privacy Policy. We will find a way to address any off base, inadequate or obsolete Personal Information on the off chance that you demand us to do as such, where legally necessary. We may retain or deny you access to your Personal Information in the event that we are lawfully approved to do as such or where its exposure to you is limited by law, is the subject of lawful activity or may bargain the security of someone else.
You will not need to pay an expense to get to your Personal Information (or to practice any of the different rights). Be that as it may, we may charge a sensible expense if your solicitation is obviously unwarranted, tedious or unnecessary. Then again, we could decline to follow your solicitation in these conditions.
Notwithstanding the above mentioned, you additionally have lawful rights to:
- request that we erase your Personal Information;
- object to the preparing of your Personal Information;
- request that we confine the handling of your Personal Information;
- request that we move your Personal Information to you;
- withdraw your consent to our processing of your Personal Information;
Where marketing information is sent to you via electronic messages, there will be a functional ‘unsubscribe’ mechanism contained in the message.
HOW CAN YOU STOP RECEIVING MARKETING INFORMATION?
Where marketing information is forwarded to you via electronic messages, there will be a functional ‘unsubscribe’ mechanism contained in the message.
If you no longer wish to be reached by us or get such marketing information, you can exhort us:
- by emailing us at info@optimosoftware.co.uk; or
- by clicking the ‘unsubscribe function’ (where marketing information is sent electronically).
We will track your record to guarantee you don’t get that information in the future. You can’t decline to get information which we are required to give you by law.
COOKIES
“Cookies” are small data files sent by a website and stored on your computer’s hard drive when you visit the website. A cookie can contain certain information that the website uses to track the pages you have visited. The only Personal Information a cookie can contain is information you personally supply. A cookie cannot read data off your hard disk or read cookie files created by other websites. Our Website uses cookies to assist with managing your account and to identify you on return visits. Most internet browsers automatically accept cookies, but you can usually change your browser to notify you when you receive a cookie or to reject cookies. However, while most of the content of our Website can be viewed without accepting cookies, full functionality for the Website requires the use of cookies.
CHANGES TO THIS PRIVACY POLICY
We may amend this Privacy Policy from time to time by posting the amended version on our Website at www.optimosoftware.co.uk. We suggest that you visit our Website regularly to keep up to date with any changes.
CONTACTING US
If you would like more information about this Privacy Policy or if you have any queries or complaints, please contact us by email at info@optimosoftware.co.uk. We will take reasonable steps try to resolve any complaints with you as quickly as practicable. Complaints may also be made directly to the office of the UK Information Commissioner’s Office through its website located at www.privacy.gov.au/complaints.
DEFINITIONS
Unless otherwise defined in this Privacy Policy, words beginning with capital letters are defined in the OPTIMOGOV User Agreement.
For the purposes of this Privacy Policy:
Personal Information implies any data or information which identifies with a living person who can be recognised from, or whose character is evident or reasonably be ascertained from, that data or information alone or related to other data previously held by the beneficiary, controller or processor of such data or information and incorporates any declaration of supposition about the individual and any sign of the expectations of the beneficiary or some other individual in regard of that individual; and
OPTIMOGOV User Agreement implies the OPTIMOGOV User Agreement accessible on the Website at www.optimosoftware.co.uk as refreshed now and again which you should peruse and acknowledge as a state of enrolling an Account and in any case getting to and utilising the OPTIMOGOV Service.