Privacy Policy | Simplifi

We care about your privacy

Your privacy is important to us at Simplifi. We respect your privacy regarding any information we may collect from you across our website.

Foreword

As a good corporate citizen and data management specialist, Simplifi recognises and respects your right to data privacy and transparency, and to be able to control your data and how we interact with it. We believe that making you aware of how we use your personal information will form the basis a trustworthy and valuable relationship.

Privacy Notice

Introduction

The simplifidm.com/ website (the “Website”) is operated by Simplifi Data Management Limited. This notice sets out details of how and why we (“Simplifi”, “we”, “us”, “our”) and third parties collect and process personal information in connection with your relationship or interactions with us, including your use of the Website. We do this in compliance with our obligations under applicable data protection law.

This notice explains what personal data is collected, the purposes for which it is used, the third parties to whom it may be disclosed and how individuals can exercise their rights in relation to their personal data.

Why do we collect and store your personal data?

We safeguard your privacy rights with respect to any data or information we receive that identifies you or is identifiable to you. For purposes of this notice, we will call such data or information “personal data” or “data”. Personal data will always be collected, used, and disclosed by Simplifi in accordance with the requirements and prohibitions of applicable laws or regulations.

The reasons that Simplifi collects and stores your personal information include:

to ensure that content from the Website is presented in the most effective manner for you and your computer
where applicable, to provide you access to certain sections of the Website
to respond to any queries you submit to us from time to time
to inform you about any changes to the Website
to help us improve, administer and diagnose problems with the Website
to help us understand which parts of the Website are most popular, user behaviour, and characteristics to measure interest in and use of the various areas of the Website
to process any requests we receive from you
to send you information on the latest news, information and general direct marketing which we feel may be of interest to you

We will always give you the opportunity to unsubscribe in the future from any e-mails we may occasionally send. This option will be provided in the e-mail you receive or can be done by contacting us directly at info@simplifidm.com.

Where applicable, we will also use your personal data to:
comply with our legislative and regulatory obligations in connection with our dealings with you, including under applicable law regarding anti-money laundering and counter terrorist financing, taxation, the regulation of collective investment schemes, or the provision of financial services, crime-detection, prevention, investigation and prosecution, the prevention of fraud, bribery, anti-corruption, tax evasion, to prevent the provision of financial and other services to those who may be subject to economic or trade sanctions, in response to legal or court requests or requests from regulatory authorities or where it is in the public interest;

process your application to become a client of Simplifi
to manage or administer your relationship with Simplifi
if applicable, process the fact that you are a politically exposed person, to comply with applicable legal obligations
conduct our business in a responsible and commercially prudent manner and dealing with any disputes that may arise
prevent, investigate or detect theft, fraud or other criminal activity
pursue our corporate and social responsibility objectives

What is the lawful basis for processing your data?

Simplifi collects, uses, stores and otherwise processes personal data where necessary to provide a service which you request, where necessary to comply with a legal obligation, and where necessary pursuant to Simplifi’s legitimate interests and where these interests are not overridden by your data protection rights.

For example, Simplifi has a legitimate interest in ensuring the security and integrity of its systems and facilities and in ensuring that relevant information for the conduct of our business is available across the Simplifi group.

Simplifi may also process your personal data where you have given consent or provided your “opt-in”. For example, when you fill in an online form or request more information about Simplifi products or services, you consent to Simplifi using your personal data as requested.‍ Where Simplifi asks for consent, you are free to withhold or revoke it by contacting us using the details given below.

What type of data is collected?

Simplifi may collect and process the following personal data about you:

information that you provide to us when requesting a demonstration of our products or requesting subscription to the Simplifi mailing list, such as your first name, last name, company name, e-mail address and telephone number;
information that you may provide by using the Website or availing of our services on the Website;
if you contact us for any reason, we may keep a record of that correspondence;
statistical and other analytical information collected on an aggregate basis about your visits to the Website; and
details of your visits to the Website including, but not limited to, traffic data, location data, IP address, logical address of the server you are using, communication data, the resources and linked sites that you access, the top level domain name from which you access the Internet (for example, .ie, .com, etc.), the type of browser you are using, the date and time you access our Website and the internet address linking to our Website.
For the purposes of meeting our legal obligations or carrying out due diligence, we may also collect information relating to your status as an ultimate beneficial owner of an entity, or as a politically exposed person.
In addition, we may collect personal data relating to you from third party sources in connection with complying with requirements relating to anti-money laundering, taxation, and other legislation applicable to the financial services industry or for vetting or screening purposes or fitness and probity assessments or references from previous employers.

How is the data collected?

Simplifi may collect your personal data when you use or subscribe to newsletters either via email or the Website. We also collect information from you as part of our client on-boarding take on processes as necessary in the course of establishing a relationship with you. We gather information about you when you provide it to us, or interact with us directly, for instance engaging with our staff, providing a business card or registering on one of our digital platforms or applications. We may also collect or receive information about you from other sources, such as keeping the contact details we already hold for you accurate and up to date using publicly available sources.

How is the data used?

We use any non-personally identifiable data gathered from visitors to the Website in an aggregate form to get a better understanding of where our visitors come from and to help us better design and organise the Website. We also use this information to help design, create, amend, or discontinue our products and services

We do not, without your consent, disclose information about identifiable individuals to third parties, but we may provide anonymised statistical data to them for research and survey purposes.

The statistical and analytical information provides general and not individually specific information about the number of people who visit the Website, the number of people who return to the Website, the pages that they visit, where they were before they came to this Website and the page(s) in the Website at which they exited.

Where is the data stored?

The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Notice.

All information you provide to us is stored on secure servers. Where we have given you (or where you have chosen) a password or username which enables you to access the Website, you are responsible for keeping this password or username confidential. We ask you not to share this information with anyone.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to the Website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access. We have security in place such as firewalls, backup and other appropriate technical security measures.

Data Security

Your rights

Subject to applicable law you have a number of important rights free of charge. In summary, those include rights to:
•‍access to your personal information and to certain other supplementary information that this Privacy Notice is already designed to address

require us to correct any mistakes in your information which we hold
require the erasure of personal information concerning you in certain situations
receive the personal information concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
object at any time to processing of personal information concerning you for direct marketing
object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
object in certain other situations to our continued processing of your personal information
otherwise restrict our processing of your personal information in certain circumstances

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The above rights are not absolute rights and may be limited where it is necessary to protect the fundamental rights, human rights, or public and private interests of others. Simplifi reserves the right, where permitted by law, to verify your identity. In some circumstances, Simplifi processes personal data on behalf of its clients and subject to the control and instructions of its clients.

‍If you believe Simplifi may have personal data about you due to services Simplifi is providing or has provided to a Simplifi client with whom you have a relationship, it may not be possible for Simplifi to respond to your request. In that circumstance, it would be more appropriate for you to direct your request to the Simplifi client with whom you have the relationship.

To exercise any of these rights, please contact us at info@simplifidm.com.

Use of cookies

A cookie is a small text file which is placed onto your device (e.g. computer, smartphone or other electronic device) when you use our Website. We use cookies on our Website. These help us recognise you and your device and store some information about your preferences or past actions.

‍For example, we may monitor how many times you visit the website, which pages you go to, traffic data, location data and the originating domain name of your internet service provider. This information helps us to build a profile of our users. Some of this data will be aggregated or statistical, which means that we will not be able to identify you individually.

‍For further information on cookies generally, including how to control and manage them, visit the guidance on cookies published by the Irish Data Protection Commission, www.aboutcookies.org or www.allaboutcookies.org.

Changes to this Privacy Statement

We reserve the right to change this Privacy Statement from time to time at our sole discretion. If we make any changes, we will post those changes here and update the “Last Updated” in this Privacy Statement. Your continued use of this website after we make changes is deemed to be acceptance of those changes, so please check this Privacy Statement periodically for updates.

How to Contact Us

For questions or complaints regarding our use of your personal information or this notice, please use the following information to contact us at info@simplifidm.com

Governing Law and Jurisdiction

This Privacy Statement and all issues regarding this Website are governed by Irish law.