SIMPL3R – PRIVACY POLICY

Scooptix Pty Ltd ABN 67 654 280 887 (we, us or our), understands that protecting your personal information is important. This Privacy Policy sets out our commitment to protecting the privacy of personal information provided to us, or otherwise collected by us when providing our website “Simpl3r.com or Bountyhunters.gg” (Services) or when otherwise interacting with you.

The information we collect

Personal information: is information or an opinion, whether true or not and whether recorded in a material form or not, about an individual who is identified or reasonably identifiable.

The types of personal information we may collect about you include:

When you visit our website:

• your browser session and geo-location data, device and network information, statistics on page views and sessions, acquisition sources, search queries and/or browsing behaviour;
• your email address;
• your year of birth;
• your preferences and/or opinions;
• your username for third-party services such as Discord and Twitter;
• information you provide to us, including through feedback, customer surveys or otherwise;
• details of products and services we have provided to you and/or that you have enquired about, and our response to you;
• support requests submitted to us and our response to you;
• information about your access and use of our Services, including through the use of Internet cookies, your communications with our online Services, the type of browser you are using, the type of operating system you are using and the domain name of your Internet service provider;
• additional personal information that you provide to us, directly or indirectly, through your use of our Services, associated applications, associated social media platforms and/or accounts from which you permit us to collect information; and
• any other personal information requested by us and/or provided by you or a third party.

Sensitive information: is a sub-set of personal information that is given a higher level of protection. Sensitive information means information relating to your racial or ethnic origin, political opinions, religion, trade union or other professional associations or memberships, philosophical beliefs, sexual orientation or practices, criminal records, health information or biometric information.

Sensitive information: We do not actively request sensitive information about you. If at any time we need to collect sensitive information about you, unless otherwise permitted by law, we will first obtain your consent and we will only use it as required or authorised by law.

How we collect personal information

We collect personal information in a variety of ways, including:

• Directly: We collect personal information which you directly provide to us, including when you register for an account, through the ‘contact us’ form on our website or when you request our assistance via email, or over the telephone.
• Indirectly: We may collect personal information which you indirectly provide to us while interacting with us, such as when you use our website, in emails, over the telephone and in your online enquiries.
• From third parties: We collect personal information from third parties to assist us provide our Services to you, including but not limited to

• Twitter, who provide us with confirmation of your Twitter account. For more information on Twitter’s privacy practices, please review their applicable privacy policy;
• Discord, who provide us with confirmation of your Discord account. For more information on Discord’s privacy practices, please review their applicable privacy policy;
• details of your use of our website from our analytics and cookie providers and marketing providers. See the “Cookies” section below for more detail on the use of cookies.

Twitter, Discord and any other third-party service providers who collect your personal information may have their own privacy policy and use of their services will be governed and subject to their terms and conditions and privacy policy.

Why we collect, hold, use and disclose personal information

When you visit our website:

• to provide our website to you;
• to contact and communicate with you about any enquiries you make with us via our website;
• to comply with our legal obligations and resolve any disputes that we may have; and/or
• if otherwise required or authorised by law.

Personal information: We may collect, hold, use and disclose personal information for the following purposes:

• to enable you to access and use our Services, including to provide you with a login;
• to enable you to access and use our associated applications;
• to contact and communicate with you about our Services, including in response to any support requests you lodge with us or other enquiries you make with us;
• for internal record keeping, administrative, invoicing and billing purposes;
• for analytics, market research and business development, including to operate and improve our Services, associated applications;
• to run promotions, competitions and/or offer additional benefits to you;
• for advertising and marketing, including to send you promotional information about our products and services and other information that we consider may be of interest to you;
• to comply with our legal obligations and resolve any disputes that we may have; and
• if otherwise required or authorised by law.

Our disclosures of personal information to third parties

We may disclose personal information to:

• third party service providers for the purpose of enabling them to provide their services, to us, including (without limitation) IT service providers including Twitter and Discord, data storage, web-hosting and server providers, email marketing providers, debt collectors, couriers, maintenance or problem-solving providers, marketing or advertising providers, professional advisors and payment systems operators;
• our employees, contractors and/or related entities;
• our existing or potential agents or business partners;
• sponsors or promoters of any promotions or competition we run;
• anyone to whom our business or assets (or any part of them) are, or may (in good faith) be, transferred;
• courts, tribunals and regulatory authorities, in the event you fail to pay for goods or services we have provided to you;
• courts, tribunals, regulatory authorities and law enforcement officers, as required or authorised by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights; and
• third parties to collect and process data, such as Google Analytics (To find out how Google uses data when you use third party websites or applications, please see www.google.com/policies/privacy/partners/ or any other URL Google may use from time to time), Facebook Pixel or other relevant analytics businesses; and
• any other third parties as required or permitted by law, such as where we receive a subpoena.

Overseas disclosure

We may store personal information overseas. Where we disclose your personal information to the third parties listed above, these third parties may also store, transfer or access personal information outside of Australia.

Unless we seek and receive your consent to an overseas disclosure of your personal information, we will only disclose your personal information to countries with laws which protect your personal information in a way which is substantially similar to the Australian Privacy Principles and/or we will take such steps as are reasonable in the circumstances to require that overseas recipients protect your personal information in accordance with the Australian Privacy Principles.

Your rights and controlling your personal information

Your choice: Please read this Privacy Policy carefully. If you provide personal information to us, you understand we will collect, hold, use and disclose your personal information in accordance with this Privacy Policy. You do not have to provide personal information to us, however, if you do not, it may affect our ability to provide our Services to you and your use of our Services.

Information from third parties: If we receive personal information about you from a third party, we will protect it as set out in this Privacy Policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have such person’s consent to provide the personal information to us.

Restrict and unsubscribe: To object to processing for direct marketing/unsubscribe from our email database or opt-out of communications (including marketing communications), please contact us using the details below or opt-out using the opt-out facilities provided in the communication.

Access: You may request access to the personal information that we hold about you.  An administrative fee may be payable for the provision of such information. Please note, in some situations, we may be legally permitted to withhold access to your personal information. If we cannot provide access to your information, we will advise you as soon as reasonably possible and provide you with the reasons for our refusal and any mechanism available to complain about the refusal. If we can provide access to your information in another form that still meets your needs, then we will take reasonable steps to give you such access.

Correction: If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the details below. We will take reasonable steps to promptly correct any information found to be inaccurate, out of date, incomplete, irrelevant or misleading. Please note, in some situations, we may be legally permitted to not correct your personal information. If we cannot correct your information, we will advise you as soon as reasonably possible and provide you with the reasons for our refusal and any mechanism available to complain about the refusal.

Complaints: If you wish to make a complaint, please contact us using the details below and provide us with full details of the complaint. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take in response to your complaint. If you are not satisfied with our response, you also have the right to contact the Office of the Australian Information Commissioner.

Storage and security

We are committed to ensuring that the personal information we collect is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures, to safeguard and secure personal information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.

While we are committed to security, we cannot guarantee the security of any information that is transmitted to or by us over the Internet. The transmission and exchange of information is carried out at your own risk.

Cookies

We may use cookies on our website from time to time. Cookies are text files placed in your computer's browser to store your preferences. Cookies, by themselves, do not tell us your email address or other personally identifiable information. However, they do recognise you when you return to our online website and allow third parties, such as Google and Facebook, to cause our advertisements to appear on your social media and online media feeds as part of our retargeting campaigns. If and when you choose to provide our online website with personal information, this information may be linked to the data stored in the cookie.

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website.

Links to other websites

Our website may contain links to other party’s websites. We do not have any control over those websites and we are not responsible for the protection and privacy of any personal information which you provide whilst visiting those websites. Those websites are not governed by this Privacy Policy.

We use Google’s Application Programming Interface (API) Service to insert why our client is accessing information: ie access your email account to read your emails in order to enable you to [insert purpose.

Our use of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements (set out in the Google API Services User Data Policy).

We limit our use of the personal information that we collect to providing or improving our Services. We do not use the personal information for any other purposes.

We only transfer the personal information to others if it is necessary to provide or improve our Services or as necessary to comply with applicable law or as part of a merger, acquisition or sale of assets where we notify you of this.

We do not use or transfer the personal information for serving ads, including retargeting, personalised or interest based advertising.

We don’t allow humans to read the personal information unless

• we have first received your consent to view specific messages, files or other data;
• it is necessary for security purposes (such as investigating a bug or abuse);
• our use is limited to internal operations and the personal information (including derivations) have been aggregated and anonymised.

These restrictions apply to the raw data we obtain from the restricted scopes and data that is aggregated, anonymised or derived from them.

We have policies and procedures in place setting out appropriate safeguards for protecting your personal information obtained with the Google APIs. We will also ensure that our employees, agents, contractors and successors comply with the Google API Services Data Policy.

Amendments

We may, at any time and at our discretion, vary this Privacy Policy by publishing the amended Privacy Policy on our website. We recommend you check our website regularly to ensure you are aware of our current Privacy Policy.

For any questions or notices, please contact us at:

Scooptix Pty Ltd ABN 67 654 280 887

Email: contact@simpl3r.com

Last update: 17 April 2023

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