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Privacy Policy

1. Important notice

This is the Privacy Policy for simplesearchtt.com. It describes who we are, how we obtain and use the personal data of representatives of our business customers, why we are allowed to do so by law, who has access to your personal data and what your rights are. Please review it carefully.

You have the right to object to us processing your personal data for our legitimate business interests or for direct marketing purposes (including any related profiling). For more information about your rights and how you can exercise them, please see the section Your rights.

2. About us

We are Simple Media Co Ltd, a private limited company incorporated in (and subject to the laws of) Trinidad and Tobago. Our registered address is at 37 Richmond St, Port of Spain, Trinidad. We take your privacy seriously and use your personal data as further explained in this Privacy Policy. We are the “controller” of the personal data you provide to us.

3. What personal data we collect and why

Personal data is any information which identifies you personally whether directly (for example, your name) or indirectly (for example, information about your use of our products and services). This Privacy Policy is concerned with the personal data of representatives of our business customers, including staff of companies, partners in a partnership and sole traders.

We collect the following personal data from you:

• Basic contact details: We collect your name, email address, postal address and telephone number so that we can contact you about your business listing for our advertising products and any other products and services that we have from time to time agreed to provide to your business;

• Business details: We require you to provide the name of the business you represent and details of the goods and/or services your business offers so that we can load your business listing on our search platform and provide you with the best possible service that is tailored to your business’s needs. You may also choose to provide other information about you and your business. We do not require you to do this but if you do, we will process this other information for the purposes of publishing your business listing;

• Payment details: We may require your payment card details so that we can obtain payment for any paid-for products and services that we provide to your business; and

• Credit score details: If you are a partner in a partnership, a sole trader or represent a business which is not a private or public limited company or LLP, if you have provided your consent to do so, we collect your name, job title, date of birth and residential address history dating back three years, so that we can obtain your credit score. We need to do this in order to establish the best possible payment terms we are able to offer to you.

• Correspondence: We collect any additional personal data that you may provide to us from time to time if you contact us by email, letter or telephone, through our website or by any other means. If you contact us by telephone, we may also record the call and make notes in relation to your call for training and service improvement purposes, to comply with our legal obligations and to be able to deal with any dispute or defence of a claim which may arise in the course of us providing our products and services to you.

We also obtain information about you from other sources:

• Cookies and similar technologies: We track your use of our website through cookies and other similar technologies so that we can provide important features and functionality on our website, monitor its usage, and provide you with a more personalised experienced. Please see our Cookie Policy to find out more.

• Third parties: We obtain personal data about you from third parties where you have given that third party consent to share such information with us. Details of these third parties, the type of personal data we obtain from them and why, are set out in the table below.

4. How we use your personal data

We use your personal data for the following purposes:

To include in your business profile on our products or services you have requested.

We use your personal data to accept you as a new or returning customer, include your business profile on our products or services and provide you with the products and services you have requested in accordance with their terms (which will differ depending on the particular products and services you have requested and can be found here).

To advertise the identity, address and contact details of your business on third party search engines, social media sites and other relevant business websites on your behalf

If you have registered for this service, we share the identity, address and contact details of your business with third party search engines (such as Google), social media sites (such as Facebook) and other relevant business websites so that we can help promote your business to your target audience and drive potential customers to your own website.

To register a domain name on your behalf

If you have registered for this service, we may need to share your contact details with the registrar responsible for maintaining the relevant register of domain names in order to complete the registration of a domain name on your behalf.

To send you service communications, including in relation to changes to our contract terms

We use the contact details you have provided to us so that we can communicate with you about the products and services that we provide to your business, including to let you know about major changes to those products and services or to the terms of the contract between us or to any related information (such as changes to this Privacy Policy).

To confirm your identity and verify the information you provide

For security reasons and to safeguard the authenticity of our data, we must confirm you are who you say you are. This means we may check the information you provide to us against other information we hold about you from the third party sources described above in What personal data we collect and why.

To process payments

We process your payment card details so that we can obtain payment for any paid-for products and services you have requested and collect any future payments or overdue amounts for those products and services.

Direct marketing (including by third parties)

If you have provided your consent or we otherwise have the right to do so, we may use your contact details to send you direct marketing and keep you informed of promotional offers by email, SMS, post or telephone relating to our products and services.

You can unsubscribe from our direct marketing at any time by clicking the “Unsubscribe” link in any of our emails or by contacting us (see How you can contact us).

Our trusted business partners would also like to use your name, email address, postal address and telephone number to inform you of similar products, services and promotional offers. We will only share your personal data with our partners where you have provided us with your consent to do so. You can unsubscribe at any time by clicking the “Unsubscribe” link in any of their emails or managing your preferences via their website.

To conduct automated decision-making and profiling

We use technology which tracks your use of our website, products and services to help us build a profile of your preferences. What this means for you is that you are more likely to receive direct marketing and promotional offers that are tailored to your specific preferences, based on your previous activity. It also means that we don’t send the same offers to all of our customers, so you may not be made the same offers as another customer.

If you don’t agree with an automated decision that our technology has made in relation to you, you can let us know (see How you can contact us) and we may decide to look into it for you. You may still have the right to object to us processing your personal data for the purpose of automated decision-making or to restrict us from doing so (see Your Rights).

Please note that the legal basis for us carrying out these activities is that it is in our legitimate interests to do so, having taken into account whether your interests and fundamental rights and freedoms are overridden by this type of processing.

To track your usage of our website, communications, products and services

We use cookies and similar technologies to track your activity on our website so that we can provide important features and functionality on our website, monitor its usage, and provide you with a more personalised experienced. Please see ourCookie Policy to find out more.

We also use tracking technology within our emails to capture information such as the time and date you open our emails and the type of device used to open it. We use this information to understand the effectiveness of our email communications so that we can improve them in the future and provide a more personalised overall service to you.

To process credit risk assessments

If you are a partner in a partnership, a sole trader or represent a business which is not a private or public limited company or LLP, if you have provided your consent to do so, we process your name, job title, date of birth and residential address history dating back three years to obtain your credit score. We need to do this in order to establish the best possible payment terms we are able to offer to you.

To produce aggregated underwriting risk analysis reports for commercial lenders and commercial insurers

We combine the personal data we hold about you with other customers’ personal data to produce underwriting risk analysis reports for our commercial lenders and commercial insurers. The reports we produce are based on combined, aggregated datasets and do not contain any personal data about you or about any of our other customers.

To contact you about a contract renewal for paid-for products and services

We use the telephone number you have provided to us so that we can call you to discuss the renewal of the contract between us for any paid-for products and services we provide. We will do this in the lead up to the expiry of your contract and, if we don’t hear back from you to confirm whether or not you would like to renew your contract with us, up to six months after the date that your contract with us expires.

Please note that if we haven’t heard from you by the time your contract for paid-for products and services expires or if you’ve told us your business no longer requires any of our paid-for products and services after your contract expires, your business may retain a free profile on some of our products or services. We will remove your listing if you tell us to (see How you can contact us).

To provide and improve customer support

We use your personal data to be able to provide and improve the customer support we provide to you (for example, where you have questions about our products and services).

To conduct internal training

We may use your personal data for internal training purposes so that our staff have the knowledge and expertise they need to ensure we provide you with the best possible customer experience. For example, if you contact us by telephone, we may record the call and make notes in relation to your call for training and service improvement purposes.

To conduct market research and analytics

We may analyse your personal data (potentially in combination with personal data relating to other customers) to better understand our customer base. We may also invite certain customers to be involved in market research. If you accept our invitation, we will use your feedback to improve our products and services.

To maintain our records and improve data accuracy

Like any business, we process personal data in the course of maintaining and administering our internal records. This includes processing your personal data to ensure that the information we hold about you is kept up to date and accurate.

To respond to enquiries, complaints and disputes

We use the personal data we hold about you to help us respond to any enquiries or complaints you have made, or deal with any dispute which may arise in the course of us providing our products and services to you, in the most effective manner.

To investigate, detect and prevent fraud and comply with our legal obligations

In certain circumstances, we use your personal data only to the extent required in order to enable us to comply with our legal obligations, including for fraud detection, investigation and prevention purposes. This may require us to provide your personal data to law enforcement agencies.

5. Who we share your personal data with and where it is stored by them

We may provide your personal data to:

o our suppliers and services providers, including other companies in our group, who perform certain business services for us and act as “processors” of your personal data on our behalf; and

o other organisations, who use your personal data for their own purposes and are “controllers” of such data in their own right. Such organisations may be located outside of Trinidad & Tobago.

In addition, we may disclose your personal data:

o if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to protect the rights, property or safety of our business, our customers or others. This includes, in specific cases, exchanging information with other organisations for the purposes of fraud protection; and

o to successors in title or replacement operators of all or part of our business.

Please ask us if you would like more information about the safeguards that are used to protect your personal data when it is processed outside the EEA (see How you can contact us).

6. How long we keep your personal data for

We retain your personal data for no longer than is necessary for the purpose(s) for which it was provided. What this means in practice will vary between different types of data. When determining the relevant retention periods, we take into account factors including:

legal obligation(s) under applicable law to retain data for a certain period of time;

statute of limitations under applicable law;

potential or actual disputes; and

guidelines issued by relevant data protection authorities.

Otherwise, we securely erase your personal data from our systems when it is no longer needed.

7. Your rights

You have the following rights regarding your personal data:

Rights What does this mean?
1. Right to be informed You have the right to be provided with clear, transparent and easily understandable information about how we use your personal data and your rights. This is why we are providing you with the information in this Privacy Policy.
2. Right of access You have the right to obtain access to your personal data (if we are processing it) and certain other information (similar to that provided in this Privacy Policy). This is so you are aware and can check that we are using your personal data in accordance with data protection law.
3. Right to rectification You are entitled to have your personal data corrected if it is inaccurate or incomplete.
4. Right to erasure This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your personal data where there is no compelling reason for us to keep using it. This is not a general right to erasure; there are exceptions.
5. Right to restrict processing You have the right to ‘block’ or suppress further use of your personal data in certain circumstances. When processing is restricted, we can still store your personal data, but may not use it further. We keep lists of people who have asked for further use of their personal data to be ‘blocked’ to make sure the restriction is respected in future.
6. Right to data portability You have the right to obtain and reuse your personal data in a structured, commonly used and machine-readable format in certain circumstances. In addition, where certain conditions apply, you have the right to have such information transferred directly to a third party.
7. Right to object to processing You have the right to object to us processing your personal data for our legitimate business interests or for direct marketing purposes (including in each case any related profiling).
8. Right to withdraw consent to processing If you have given your consent to us to process your personal data for a particular purpose (for example, direct marketing), you have the right to withdraw your consent at any time (although if you do so, it does not mean that any processing of your personal data up to that point is unlawful).
9. Right to make a complaint to the data protection authorities You have the right to make a complaint to the Information Commissioner’s Office (ICO) if you are unhappy with how we have handled your personal data or believe our processing of your personal data does not comply with data protection law.

For more information about your rights or if you would like to exercise any of your rights, you are welcome to contact us at the contact details set out below under How you can contact us.

8. How you can contact us

If you would like to exercise your data protection rights or if you are unhappy with how we have handled your personal data, you may contact us by:

• emailing: admin@simplesearchtt.com;

• writing to: Simple Search Media Ltd, 29 Long Circular Rd, Port of Spain, Trinidad.

• calling: 868-822-6062; or

• submitting a message through our online contact form.

9. Links to other websites

Our website contains hyperlinks to websites owned and operated by third parties. This Privacy Policy does not apply to those other websites. We encourage you to read the privacy statements on the other websites you visit, as they will govern the use of any personal data you provide when visiting those websites. We do not accept any responsibility or liability for the privacy practices of such third party websites and your use of such websites is at your own risk.

10. Changes to this Privacy Policy

This Privacy Policy was last updated on 12 July 2018

This Privacy Policy may be updated from time to time so you may wish to check it each time you provide personal data to us. We won’t alert you to minor changes, but if there are any major changes we will let you know and where appropriate ask for your consent.

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