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Sesimi Privacy Policy

This privacy policy sets out how MyAdbox Pty Ltd (ACN 140 175 971) as trustee for the My Adbox Unit Trust (ABN 59 273 034 906) (“MyAdbox”/ “Sesimi”/ “we” / “us”/ “our”) handles “personal information” or “personal data” you provide to us or that we collect when you interact with us using our website sesimi.com or sesimi.app, to access our content or use our goods and services (“Personal Information”).

Sesimi provides the “Sesimi” marketing collateral creation, customisation, and distribution platform (“our website”), which includes the supply of services like analytics, software development, and support for businesses to create their own advertising and marketing campaigns, materials and assets including via external creative agencies (our “goods” and “services”). Sesimi is primarily based in Melbourne, Australia but offers its goods and services to users all over the world (including in the United Kingdom and European Union).

We have created this privacy policy to demonstrate our commitment to the Privacy Act 1988 (Cth) (“Privacy Act”) and the Australian Privacy Principles (“APPs”), and to the extent that Sesimi offers its goods and services to individuals in the European Union (including, the United Kingdom) or otherwise monitors the behaviour of individuals in the European Union, we have created this privacy policy to comply with the European Union’s General Data Protection Regulation (“GDPR”).

For the purposes of the GDPR, Sesimi is both the “data controller” and a “data processor” of Personal Information and is legally responsible for how Personal Information is collected and used. This policy sets out how we collect, hold, protect, use or disclose your Personal Information, and how you may change or request that we amend your Personal Information.

What information do we collect?

We collect and hold your Personal Information which may include your name, location information, email address, phone number, mailing address, information relating to your business and other information relevant to the supply of our goods and services (including information about your dealers, customers, and/or prospective customers, which may include age, location, activity tracking, and sensitive information). If you use our website or otherwise engage our services, we may also collect your bank, credit card details and account details.

We may also collect anonymised, aggregated, and otherwise non-personally identifiable information about you or your customers or dealers (such as anonymous usage data, IP addresses, location and browser etc.).

More detailed examples of the information we collect include:

  • Personal information you may give us when you use our website or set up an account with us:
    • Identifying information such as your name, addresses, telephone numbers or email addresses when you use our website’s contact form.
    • Other content that you input or that is otherwise connected to your use of the contact form.
    • Financial information (such as credit card or bank account numbers).
    • You may also provide us other information by updating or adding information to your account, through your communications with our support services, or when you otherwise communicate with us regarding our goods and services.
    • Additional information we are required or authorised by applicable laws to collect and process in order to authenticate or identify you or to verify the information we have collected.
  • Personal information we collect automatically when you use our website or register for an account with us:
    • We collect information about your interaction with our website, your usage preferences, and your communications with us. We receive this information from Google Analytics when you access our website. This information could include the following:
      • Location information from your mobile device (if applicable).
      • Computer and connection information such as statistics on your page views, traffic to and from sites, referral URL, ad data, your IP address, your browsing history, and your web log information.
    • We use cookies, web beacons, unique identifiers, and similar technologies to collect information about the pages you view, the links you click, and other actions you take when using our website. See our further discussion on this below under the “Cookies” section.
  • Personal information collected from other sources:
    • We supplement the personal information we collect directly with information collected from third parties. For example, we also collect information from and share information with third-party payment providers (including third-party support service providers and payment providers).
  • If you give us personal information about someone else, you must do so only with that person’s authorisation. You should inform them how we collect, use, disclose, and retain their personal information according to our privacy policy.

How do we collect Personal Information?

We collect your Personal Information during the course of providing our goods and services to you. This includes when you use sesimi.com, provide information to us via our support services or by email, when you provide information to us about you and/or your business, or otherwise via customer enquiries and communications.

Generally, we collect your Personal Information directly or automatically through your use of our website, but we may also collect your Personal Information from other people or organisations if you have given your consent.

Why do we need your Personal Information?

We only collect or hold your Personal Information for legitimate purposes, including to provide you with our goods and services, and for the proper administration of our website. In particular, we need your Personal Information to:

  • Provide you with the goods and services we offer;
  • Maintain our business relationship with you by answering any questions or queries you may have about Sesimi, or the goods we provide, communicating with you about our goods and/or services, creating and updating our database(s) and other records, ensuring compliance with our contractual and other legal obligations to you, providing support services to you and otherwise responding to enquiries;
  • Market and advertise to you including by sending you newsletters, special offers, and promotions, or otherwise contacting you about goods and services, or information we think may interest you. We may contact you through phone, email, or SMS;
  • Improve the quality and design of our goods and services by storing, tracking, analysing and processing user preferences and trends as well as user activity to create new features, functionality and services in relation to the website;
  • Comply with the law including by complying with our legal obligations and by investigating, preventing or taking action in respect of suspected illegal activity, fraud, or similar activities; and
  • Exercise our legal rights including exercising rights we may have under law or a contract between us and you, or between us and a third party,

(together our “Purposes”).

If you do not provide us with your Personal Information, we may not be able to carry out some or all of our Purposes.

Can you remain anonymous or use a pseudonym?

Given the nature of the goods and services we provide, we do not allow you to use a pseudonym or to otherwise remain anonymous, as this is impractical.

We also note that if you do not provide us with some or all of the Personal Information we request, we may not be able to provide you with the relevant goods or services. This may also have an effect on whether we can begin or continue a relationship with you.

What disclosures do we make?

Generally speaking (and as described above under the heading “Why do we need your Personal Information”) we will disclose your Personal Information for our Purposes. We may also disclose your Personal Information in other ways with your consent, to any other party where we are authorised or required to do so by law, or to our related entities, partners or service providers (including hosting providers, payment processors, security service providers, and support service providers in order to assist us to provide our products or services to you.

Some of our related entities, partners and service providers or the services they provide may be based outside of Australia (including in the United Kingdom and the European Union). By providing us with your Personal Information, you acknowledge that your Personal Information may be used, stored and disclosed overseas, including in jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction. To protect your Personal Information we take care to work with entities, partners and service providers who are based in countries that provide adequate levels of data protection, or we otherwise take steps to ensure that your Personal Information receives adequate levels of data protection in the jurisdictions in which it is processed in accordance with all applicable privacy laws (including the GDPR).

Personal Information of minors

We do not knowingly collect or solicit Personal Information from anyone under the age of 16 years of age or knowingly allow such persons to use our goods or services (including by registering an account on our website). If we become aware that we have collected personal information from a person under the age of 16 years without parental consent, we will take all reasonable steps to delete that information.

Do we use “cookies”?

When you visit our website, the server may attach a "cookie" to your computer's memory. A “cookie” assists us to store information about how you use our website and to make assumptions about what information may be of most interest to you. This information is generally not linked to your identity. We may use knowledge of your user experience to better understand what goods or services may be of interest to you and to collect statistical information.

Using other sites

Our website may contain links to other websites, platforms or applications. We are not responsible for the privacy practices of the owners of those websites, platforms, or applications. We recommend that you read the privacy policy of any website, platform, or application that asks you to provide your Personal Information.

Is your Personal Information confidential and secure?

We take all reasonable steps to keep your Personal Information secure and to ensure it is protected against misuse, loss, unauthorised access, modification or inappropriate disclosure. We may keep your Personal Information in both hard copy and electronic forms, but adopt appropriate technical and organisational security measures to protect it including by storing it in secure systems accessible only to authorised personnel.

We also urge you to take steps to keep your Personal Information safe, such as choosing a strong password and keeping it private, as well as logging out of your account on our website, and closing your web browser when you are finished using our website on a shared or unsecured device.

Your choices and rights

We welcome your enquires and comments and encourage you to contact us to update your Personal Information if it changes. You may confirm if we are processing your Personal Information and request a copy of it. For your protection, however, we may require that you confirm your identity before we provide a copy of your Personal Information to you.

You may also update or correct your Personal Information by contacting us, or by amending your Personal Information on your account via our website.

In some instances, you may request that we delete your Personal Information. In accordance with and subject to relevant privacy laws (including the GDPR), you may object to certain Personal Information being processed and request that processing of your Personal Information be limited. You may also limit or manage our communications with you by “unsubscribing” from certain email and newsletter updates, and by closing your account on our website.

If you choose to limit the Personal Information we process about you we may not be able to communicate with you or fulfil our Purposes outlined above.

Queries and complaints

If you have a question or want to make a complaint about how we handle your Personal Information please contact us using the details below. We will review any question, complaint or concern you may have and will respond to you after we have carefully considered it. We will, where reasonably possible, take steps to investigate and resolve complaints within 30 days. Please note, we may require further information from you in order to resolve any complaints. If we need more time, we will notify you about the reasons for the delay and seek to agree a longer period with you (if you do not agree, we may not be able to resolve your complaint).

We can be contacted at: support@sesimi.com.

For more information about privacy issues in Australia and protecting your privacy, please visit the OAIC website at www.oaic.gov.au. For more information about the GDPR, please contact the European Data Protection Supervisor, the European Union’s independent data protection authority or visit their website at: https://edps.europa.eu.

Changes to our Privacy Policy

We may need to change this privacy policy from time to time. When we do amend it, the changes will be effective immediately upon being made public on our website. We will use reasonable measures to notify you of any relevant changes to this privacy policy, but please be aware that it is your responsibility to review our privacy regularly and make sure you keep up to date with any changes.

Last date Updated: 22 May 2024

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