Effective date: 25 May 2018
For the purposes of this policy,
SilverSiphon defines the term “Visitor” as an individual that visits any page of our front-end website (for example www.silversiphon.com)
The term “User” as an entity with which SilverSiphon has an established relationship with when a Visitor uses its products or signs up for an account on the website.
“Service” includes our:
- SaaS Products
but does not include:
- Any Third Party Products. These are third party products or services that you may choose to integrate with SilverSiphon’s products or services, such as third-party Add-Ons. You should always review the policies of third party products and services to make sure you are comfortable with the ways in which they collect and use your information.
Any information stored by SilverSiphon is treated as confidential. All information is stored securely and is accessed by authorized personnel only. SilverSiphon implements and maintains appropriate technical, security and organisational measures to protect Personal Data against unauthorized or unlawful processing and use, and against accidental loss, destruction, damage, theft or disclosure.
2. Purpose of our policy
(a) Providing the system and services that SilverSiphon offers; and
(b) The normal day-to-day operations of our business.
(a) The Australian Privacy Principles set by the Australian Government for the handling of Personal Information under the Privacy Act 1988 (Cth) (Privacy Act); and
(b) The regulations and principles set by the European Union’s General Data Protection Regulation (GDPR) for the handling of Personal Data.
3. Information we Collect
SilverSiphon takes online security very seriously and is committed to protecting your privacy. In order to access some SilverSiphon services you will be asked to provide personal identification information (“Personal Information”). How, why and other information in regards to this is explained below.
In general, you may visit SilverSiphon’s web pages without disclosing to us who you are and without revealing any Personal Information about yourself however without providing personal information you may not be able to download or purchase our products or services.
3.1. Collection and use of User data
During a registration on the SilverSiphon website, you give consent to provide information that is of personal and confidential in nature. Without limitation, the type of information we may collect is:
- Personal Information: We may collect personal details such as an individual’s name, location, date of birth, nationality, family details and other information defined as “Personal Information” in the Privacy Act that allows us to identify who the individual is;
- Contact Information: We may collect information such as an individual’s email address, telephone & fax number, third-party usernames, residential, business and postal address and other information that allows us to contact the individual;
- Financial Information: We may collect financial information related to an individual such as any bank or credit card details used to transact with us and other information that allows us to transact with the individual and/or provide them with our services;
- Statistical Information: We may collect information about an individual’s online and offline preferences, habits, movements, trends, decisions, associations, memberships, finances, purchases and other information for statistical purposes; and
- Information an individual provides us: We may collect any Personal Information that an individual provides us, or that is sent to us by others about the individual’s activities.
Generally information will be collected in association with an individual’s use of SilverSiphon, an enquiry about SilverSiphon, or by dealing with us in other manners. We may also receive Personal Information from sources such as advertising, an individual’s own promotions, public records, mailing lists, contractors, staff, recruitment agencies and our business partners. In particular, information is likely to be collected as follows:
- Application Programming Interfaces (APsI): We collect Personal Information when an individual transacts through our users’ website, or our own website, that is then connected to the SilverSiphon application. The nature of our Services means that this information may typically come from, but is not limited to, Stripe.com or Xero.com and their related services;
- Registrations: When an individual registers or subscribes for a service, list, account, connection or other process whereby they enter Personal Information details in order to receive or access something, including a transaction;
- Accounts/Memberships: When an individual submits their details to open an account and/or become a member with us;
- Supply: When an individual supplies us with goods or services;
- Contact: When an individual contacts us in any way;
- Access: When an individual accesses us physically we may require them to provide us with details for us to permit them such access. When an individual accesses us through the internet we may collect information using cookies (if relevant – an individual can adjust their browser’s setting to accept or reject cookies) or analytical services; and/or
- Pixel Tags: Pixel tags enable us to send email messages in a format customers can read and they tell us whether mail has been opened.
Where we collect the information directly, we will ensure that an individual is always aware of when their Personal Information is being collected (whether by electronic or physical means).
Where we obtain Personal Information without an individual’s knowledge (such as by accidental acquisition from a client) we will either delete/destroy the information, or inform the individual that we hold such information, in accordance with the Australian Privacy Principles and the GDPR.
This information is used by SilverSiphon to identify you as a User and provide you with access to:
- purchase and use our software,
- use support and services
- participate in mailings, sales and marketing actions,
- for billing purposes
- to meet any other contractual obligations
We do not use your Personal Data for the purposes of automated decision-making. However, we may do so in order to fulfil obligations imposed by law, in which case we will inform you of any such processing and provide you with an opportunity to object.
We do not collect sensitive information such as medical, health, racial, ethnic, political, religious, philosophic, union membership or sexual orientation information. If we are made aware that we have received such information, we will promptly proceed to its deletion.
3.2. Data Access, Correction, Deletion, and Opt Out.
Users can at any time access and edit, update or delete their contact details by logging in to their account on the SilverSiphon website with their username and password.
SilverSiphon will not retain User data longer than is necessary to fulfil the purposes for which it was collected or as required by applicable laws or regulations.
To the extent that you do provide us with Personal Information, SilverSiphon wishes to maintain it accurately and up-to-date. Where we collect Personal Information from you, our goal is to provide a means of contacting SilverSiphon should you need to access, update or correct that Information.
You can contact us any time to:
- Request access to information that SilverSiphon has about you
- Correct any Information that SilverSiphon has about you
- Delete information that SilverSiphon has about you
Contact us at firstname.lastname@example.org and we will make reasonable efforts to promptly provide you with the information or assistance you need free of charge.
Further, if you notify us that such information is incorrect, or you wish to have such information removed, we will correct, amend, or delete your Personal Information as soon as practicable. Your personal data will be removed without the requirement to state a reason for discontinuing your account with us.
3.3. Our Role
SilverSiphon processes Personal Data both as a Processor and as a Controller, as defined in the Directive and the GDPR.
3.4. Data Transfer Across Borders
Personal data collected by SilverSiphon will be stored in secure hosting facilities provided by Amazon Web Services located in the US which is on the EU Commission’s list of countries or territories providing adequate protection for the rights and freedoms of data subjects in connection with the processing of their personal data. All hosting is performed in accordance with the highest security regulations and Amazon Web Services is EU-US Privacy Shield compliance certified and follows the relevant principles.
3.5. Compromise of Personal Information.
In the event that personal information is compromised as a breach of security, SilverSiphon will promptly notify our customers in compliance with applicable law.
You may choose whether or not to provide Personal Information to SilverSiphon. However, when you engage in certain activities on this site, such as purchasing products or services, downloading software, or entering competitions, SilverSiphon may require that you provide certain information about yourself by filling out and submitting an online form. It is entirely optional for you to engage in these activities. If you elect to engage in these activities, SilverSiphon may require that you provide certain personal information, such as your name, mailing address, e-mail address, and other personal identifying information.
4. How We Share Your Information
4.1 Personally Identifiable Information:
4.2 Non-Personally Identifiable Information:
We may share non-personally identifiable information (such as anonymous usage data, referring/exit pages and URLs, platform types, number of clicks, etc.) with third parties to help us understand the usage patterns for our website. Such data consist solely of non-personally identifiable information. Non-personally identifiable information may be stored indefinitely.
4.3 Instances Where We Are Required To Share Your Information:
SilverSiphon will disclose your information where required to do so by law, if subject to subpoena or other legal proceeding or if we reasonably believe that such action is necessary to (a) comply with the law and the reasonable requests of law enforcement; (b) to enforce our terms or to protect the security or integrity of our Service; and/or (c) to exercise or protect the rights, property, or personal safety of SilverSiphon, our users or others.
4.4 What Happens In The Event Of A Change Of Control:
We may buy or sell/divest/transfer the company (including any shares in the company), or any combination of its products, services, assets and/or businesses. Your information such as customer names and email addresses, and other User information related to the Service may be among the items sold or otherwise transferred in these types of transactions. We may also sell, assign or otherwise transfer such information in the course of corporate divestitures, mergers, acquisitions, bankruptcies, dissolutions, reorganizations, liquidations, similar transactions or proceedings involving all or a portion of the company. You will be notified via email and/or a prominent notice on our website of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.
We display personal testimonials (success stories) of satisfied customers on our Site in addition to other endorsements. With your consent, we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us at email@example.com.
5. Cookies and Other Tracking Technologies
When you visit any SilverSiphon website, you may surf the site anonymously and access important information without revealing your identity. In order to analyze and improve our site, we use “cookies” to track your visit. A cookie is small amount of data that is transferred to your browser by a web server and can only be read by the server that gave it to you. “Cookies” cannot be executed as code or deliver viruses.
Most browsers are initially set to accept cookies. You can set your browser to notify you when you receive a cookie, therefore allowing you to decide whether or not to accept it. (For some web pages that require an authorization, cookies are not optional. Users choosing not to accept cookies will not be able to access such pages.)
Some cookies are associated with your account and personal information in order to remember that you are logged in. Other cookies are not tied to your account but are unique and allow us to carry out analytics and customization, among other similar things. Cookies can be used to recognize you when you visit this Site or another Site managed by SilverSiphon or with or use our Services, remember your preferences, and give you a personalized experience that’s consistent with your settings. Cookies also make your interactions faster and more secure.
We collect analytics information when you use our Websites to help us improve our products and services. This information is anonymous and cannot be used to identify you.
Wherever your Personal Information may be held by SilverSiphon or by a third party on SilverSiphon’s behalf, reasonable and appropriate precautions, such as encryption, firewalls and like technologies, are and will be implemented to protect such Personal Information from loss, misuse, or unauthorized access.
7. Aggregate Information
The Site may track the total number of visitors to our Site, the number of visitors to each page of our Site, IP addresses, External Web Sites (defined below) linked to, and we may analyze this data for trends and statistics in the aggregate, but such information will be maintained, used and disclosed in aggregate form only and it will not contain Personal Information. We may use such aggregate information to analyze trends, administer the Site, track users’ movement, and gather broad demographic information for aggregate use. We may share this aggregate information with third parties to assist them in targeting advertisements to appropriate audiences.
8. Links to Third Party Sites
9. Children’s Privacy
SilverSiphon and its websites are not designed nor structured to attract children. Accordingly, we do not intend to collect Personal Information from anyone we know to be under 16 years of age. If we are made aware that information is or has been submitted by or collected from a child under the age of 16, we will promptly delete this information.
10. Data Protection Officer
SilverSiphon has a “Data Protection Officer” who is responsible for matters relating to privacy and data protection. This Data Protection officer can be reached by email: firstname.lastname@example.org
11. Your Consent