Sim Local Privacy Statement
Sim Local is committed to protecting the privacy and security of your personal information. This privacy notice describes how we collect and use personal information about you during and after your relationship with us.
The privacy notice below explains what information we gather about you, what we use that information for and to whom we give the information. It also sets out your rights and who you can contact for information or queries.
We respect individuals’ right to privacy and to the protection of personal information.
“Personal Information” means information about a living individual who can be identified from that information (either by itself or when combined with other information).
Sim Local data protection officer
Whenever Sim Local collects, uses or transfers your personal data for its own purposes, Sim Local acts as a data controller of your personal data.
What personal information do we collect?
Sim Local collects your personal data from your use of the Website (e.g. visiting the Website pages, the blog, downloading case studies, watching videos on the Website and viewing infographics provided in the Website), from your subscription to the newsletter or any other e-mailing list, from any request you send through the Website (e.g. completing the sales contact or white paper download form), when you attend a webinar or participate in an online survey or access a whitepaper, or when you attend an investor event or trade show and provide your personal data to us.
From time to time, Sim Local receives personal data from business partners, vendors and distributors.
Sim Local processes the following data that relates to you:
- Identification data (such as first and last name, job title, e-mail address, business phone number, company name);
- Connection data (such as IP address, operating system, region and language as well as the date and time the Website was accessed);
Activity data (such as the number and the Website pages you visited, if you send a request through a form provided by the Website).
Why we process your personal information?
Sim Local uses your personal data where it has obtained your consent to send you marketing communications (including by e-mail) related to products and/or services.
Sim Local will use your personal data for its legitimate interest to operate its Website, provide you access to it and to its features, promote its activities and services including the following reasons:
- Website visitors and prospects management, with respect to the access to the Website, to any of its pages and to the services provided; provide information and enable interaction with our teams;
- Improve the Website and its features, to better understand how you use the Website;
- Implement marketing activities specific to Sim Local, with respect to e-mailing activities; newsletter; product and/or service information.
Sim Local also uses your personal data for compliance with legal obligations to which Sim Local is subject, including for legal and regulatory compliance, with respect to maintain business records for reasonable periods as required by applicable tax and other laws.
Information Sharing and Disclosure
Sim Local will grant access to personal data on a need-to-know basis. Such access will be limited to the portion of the personal data that is necessary to perform the function for which such access is granted.
Sim Local may need to disclose your personal data to provide you the materials, products or services you requested through the Website and/or perform any agreement entered with Sim Local (including support services).
As a result, access to personal data within Sim Local may include its authorised personnel in charge of support, sales and marketing services.
International data transfers
Due to the global nature of Sim Local’s business, Sim Local may disclose and transfer certain personal data to a foreign country.
Regarding EU data subjects:
Sim Local may transfer your personal data to Sim Local entities and third-party service providers located outside the European Union (“EU”).
To comply with EU data protection laws, including the General Data Protection Regulation (GDPR), all Sim Local data importers outside the EU are obligated to process and protect all personal data received from the EU in accordance with the controller-to-controller standard contractual clauses (the “Clauses”), as approved by the European Commission in order to protect all personal data received from the EU.
The transfers of data to third-party service providers are secured by implementing the safeguards required under the applicable data protection law (including contractual arrangements with a third-party service provider).
Retention of personal information
Our policy is to retain your personal information for only as long as it may be necessary for the purpose it was collected and no longer than is allowed under the applicable data protection laws.
We will retain your personal data for a period not exceeding the greater of, where applicable, the:
- duration of your account;
- duration of the processing of your requests;
- period of time necessary for establishing, performing and terminating the contractual relationship you may have entered into with Sim Local;
- three years as from the date where such personal data was collected or before if you object to the processing of your personal data for marketing purposes;
- duration of the applicable statute of limitations.
Rights regarding your personal information
As a data subject, you may have certain rights, including the:
Right to access: the right to obtain confirmation from Sim Local as to whether any personal data concerning you is processed by Sim Local.
- This includes the right to access such personal data to obtain a copy of it free of charge (except for repetitive or excessive requests), and to be provided with a description of main features of the processing implemented in relation to your personal data, including:
- (i) Purposes of such processing,
- (ii) Categories of personal data concerned,
- (iii) Recipients or categories of recipients of personal data,
- (iv) The envisaged retention period or, if not possible, the criteria used to determine it,
- (v) Existence of the right to request rectification or erasure of personal data, as well as the right to object to or request restriction of processing,
- (vi) The right to lodge a complaint with a supervisory authority,
- (vii) Information relating to any third party source of personal data if the data were not collected from you, and
- (viii)The existence, the logic involved, the significance and the consequences of any automated decisions, including profiling.
- If you are located in the EU, and your personal data is transferred outside the EU, you have the right to be informed of the appropriate safeguards implemented relating to such transfer.
Right to rectification: the right to obtain without undue delay the rectification of inaccurate, incomplete or outdated personal data concerning you.
Right to erasure: the right to obtain without undue delay the erasure of your personal data where:
- (i) Such personal data is no longer necessary in relation to the purpose(s) for which it was collected or otherwise processed;
- (ii) You withdraw the consent on which the processing was based, and there are no other legal grounds for the processing;
- (iii) You object to the processing, as provided below;
- (iv) Your personal data has been unlawfully processed;
- (v) Your personal data has to be erased for compliance with a legal obligation.
In some cases Sim Local may refuse such request, notably where such data is necessary to comply with a legal obligation.
Right to restriction: the right to restrict the processing of your personal data in the following cases:
- (i) Where you claim inaccuracy of your personal data processed by us (the restriction being provided for a period enabling Sim Local to verify the accuracy);
- (ii) Where the processing appears unlawful, and you oppose the erasure and request the restriction of use of your personal data instead;
- (iii) Where Sim Local does not need such personal data for the purposes of processing, but such personal data is required by you for the establishment, exercise or defence of legal claims; and
- (iv) Where an objection is raised by you in relation to the processing, pending the verification whether the legitimate grounds of Sim Local override those of you.
Right to object: the right to object, at any time and on legitimate grounds relating to your particular situation, to the processing of your personal data, including the processing for marketing purposes as well as the profiling related to such marketing activities.
Right to data portability: where the processing is based on your consent or on a sales contract, and where such processing is carried out by automated means, the right to request from Sim Local:
- (i) to communicate to you the personal data concerning you, in a structured, commonly-used and machine-readable format, in order to be able to further transmit such personal data to another data controller; or
- (ii) to directly transmit such personal data to such other data controller, if technically feasible.
Right to withdraw consent: where the processing of your personal data is based on consent, the right to withdraw such consent (subject to applicable contractual and legal restrictions) at any time without affecting the lawfulness of processing based on consent before its withdrawal.
Right to lodge a complaint: the right to lodge a complaint with the competent supervisory authority.
To exercise any of these rights, please contact our DPO: firstname.lastname@example.org.
Questions or Suggestions
If you have questions or concerns about our collection, use, or disclosure of your personal data, or if you require any additional information, please contact our DPO at Dataprotection@travelwin.com.
Manage your information
You may contact our DPO at Dataprotection@travelwin.com to update you information, where applicable.
At any time, you can withdraw the consent given to the processing of your data by sending an email to Dataprotection@travelwin.com.
It is our intention that we will resolve any issue you may have with regard to data privacy but in the event that we do not achieve this to your satisfaction in a reasonable time you have the right to refer the matter to –
Ireland – Office of the Data Protection Commissioner – https://www.dataprotection.ie
United Kingdom – The Information Commissioner’s Office – https://ico.org.uk/