The business of EasiYo includes an online marketplace which is made available by and through a number of partners, including content sharing partners, distribution partners and implementation partners (all of whom are referred to as ‘affiliates’ for the purpose of this policy).
We operate in numerous countries, including: New Zealand, Australia, EU countries, the US and several Asian countries and are continually expanding our global reach. We acknowledge our obligations to all recipients of our services and products, including visitors to our website at www.easiyo.com, our registered users and administrators of our software portals on behalf of our users (‘administrators’) (collectively, ‘users’) to collect, manage, process and use personal information in accordance with the laws and regulations of each of the countries in which we operate, including the latest General Data Protection Regulation that applies to the European Union.
- Data protection principles
- What information we collect and why we collect it;
- How we collect, use and secure that information;
- How long we hold information
- Individual rights, including how to access and update information; and
- How we will respond to data breaches.
Data protection principles
EasiYo will comply with the following data protection principles when processing personal information:
- we will process personal information lawfully, fairly and in a transparent manner;
- we will collect personal information for specified, explicit and legitimate purposes only, and will not process it in a way that is incompatible with those legitimate purposes;
- we will only process the personal information that is adequate, relevant and necessary for the relevant purposes;
- we will keep accurate and up to date personal information, and take reasonable steps to ensure that inaccurate personal information is deleted or corrected without delay;
- we will keep personal information for no longer than is necessary for the purposes for which the information is processed; and
- we will take appropriate technical and organisational measures to ensure that personal information are kept secure and protected against unauthorised or unlawful processing, and against accidental loss, destruction or damage.
What we collect and why
The reasons we collect, store, process and use this kind of information include:
- to identify and authenticate users;
- for support or response purposes, when users request support or make an inquiry;
- to plan, improve, tailor, optimise and promote our products and services for users;
- to provide users with relevant information and offers of products and other services that we believe might be of interest to users, which we may do by email;
- to manage users’ accounts;
- for contractual and other lawful legitimate business purposes or for the establishment, exercise or defence of legal claims.
We do not collect more data than is necessary for the above purposes.
Our affiliates and other third party service providers to EasiYo, which may include cloud based customer relationship, content management and hosting services and involve application programming interfaces, are also given access to some or all of the above information for similar purposes. For example:
- our distribution partners, who offer our products for sale through their own platforms or who otherwise integrate with our software, may collect and handle the same information; and
- our implementation partners may have access to the information we collect for the purpose of assisting us and our distribution partners to develop our systems to offer and deliver our products and services.
All such third parties are bound by the same laws and regulations that we are, wherever they are located in the world, and we require them to adopt and apply data protection policies and practices that are consistent with this policy.
Users need to understand that their choice not to provide certain personal information, as described above, will limit or prevent their ability to access and use our products and services.
How we collect information
We ordinarily ask for consent from users to collect, process, manage, store and use personal information, as set out in this policy. This is ordinarily done on-line, as part of registration. When users ‘Contact Us’ via the contact page on our website they will voluntarily provide the kind of information set out above.
How long we hold information
We hold information only for so long as is necessary for the purposes set out above; in this, we are guided by our contractual obligations and by other lawful legitimate business interests. If, at any time, a user wishes us to delete or transfer their record, they may do so as set out below.
Individual rights on accessing, updating and deleting personal information
Upon registration, administrators and users have ongoing access to their online accounts, within which they can correct inaccuracies or update or add information.
You (in common with other data subjects) have the following rights in relation to your personal information:
- to be informed about how, why and on what basis that information is processed
- to obtain confirmation that your information is being processed and to obtain access to it and certain other information, by making a subject access request
- to have data corrected if it is inaccurate or incomplete;
- to have data erased if it is no longer necessary for the purpose for which it was originally collected/processed, or if there are no overriding legitimate grounds for the processing (this is sometimes known as ‘the right to be forgotten’);
- to restrict the processing of personal information where the accuracy of the information is contested, or the processing is unlawful (but you do not want the data to be erased), or where the employer no longer needs the personal information but you require the data to establish, exercise or defend a legal claim; and
- to restrict the processing of personal information temporarily where you do not think it is accurate (and EasiYo is verifying whether it is accurate), or where you have objected to the processing (and EasiYo is considering whether the organisation’s legitimate grounds override your interests).
Similarly, users may withdraw their consent for us to hold any or all of their personal information by sending a request to Support@easiyo.com and may unsubscribe to any or all emails through the automated facility sent with each email.
As mentioned above, these actions or requests will limit the ability of users to access and use our products and services.
It may be the case that, for contractual or other lawful legitimate business purposes, we retain and use an archived version of users’ personal information, which may be pseudonymised, anonymised or otherwise de-identified.
We have facilities in place to request affiliates and other third parties, as necessary, to amend or delete personal information held on their systems.
We work hard to protect EasiYo and our users from misuse, interference, loss, unauthorised access, modification or disclosure of information we hold. In doing so, we apply technical and organisational measures to ensure a level of security appropriate to the risk including:
- analysing and assessing privacy and security issues, risks and impacts during the design and development of new features and solutions for our products, services and delivery platform, governed by guidelines and security standards for our IT developers;
- ensuring confidentiality, integrity, availability and resilience of processing systems and services (for instance, we restrict access to personal information of EasiYo employees, contractors; affiliates and other third parties described above, who need the information for the purposes described above and who are subject to strict contractual privacy and confidentiality obligations);
- the ability to promptly restore availability and access to personal data in the event of an incident;
- regular review and testing of our information collection, storage and processing practices, including physical security measures, aimed to ensure security of data processing; and
- as we deem necessary, pseudonymisation and encryption of data; for example, for the purpose of transfers, when data is encrypted and access is restricted at rest.
Given that EasiYo operates internationally, personal information of users may be transferred across national and continental borders, including for contractual and other lawful legitimate business purposes or at the request of users. Within the EasiYo organisation, such international transfers are governed by internal controls and rules, consistent with this policy. For such international transfers to and from affiliates and other third parties, EasiYo has in place enforceable agreements containing privacy and data protection obligations consistent with this policy.
Cookies and log files
We allow limited use of various technologies to collect and store information when users visit our website; this may include using cookies (i.e. a string of unique data that a website stores on a user’s computer and that the user’s browser provides to the website each time the user returns) or similar technologies to identify the user’s browser or device. This helps us to optimise our users’ experience and to continually improve and tailor our products and services for users.
Users may set their browser to block all cookies or to indicate when a cookie is being set.
We automatically log IP addresses, browser types and dates/times, which assist with our support efforts, diagnoses of user-initiated issues and queries, and audits for security purposes.
We acknowledge the various data breach obligations in each of the jurisdictions in which we operate.
A data breach may take many different forms, for example:
- loss or theft of data or equipment on which personal information is stored;
- unauthorised access to or use of personal information either by a member of staff or third party;
- loss of data resulting from an equipment or systems (including hardware and software) failure;
- human error, such as accidental deletion or alteration of data;
- unforeseen circumstances, such as a fire or flood;
- deliberate attacks on IT systems, such as hacking, viruses or phishing scams; and
- ‘blagging’ offences, where information is obtained by deceiving the organisation which holds it.
- make the required report of a data breach to the Information Commissioner’s Office without undue delay and, where possible within 72 hours of becoming aware of it, if it is likely to result in a risk to the rights and freedoms of individuals; and
- notify the affected individuals, if a data breach is likely to result in a high risk to their rights and freedoms and notification is required by law.
Complaints, inquiries and requests
As mentioned above, requests to access, update, restrict or delete personal information can be made to Support@easiyo.com .
They can be reached by:
Writing: Chief Information Officer
56 Livingstone Street
PO Box 96
Telephone: +64 3 756 9800
We will gladly provide the contact details of the relevant supervisory authorities within the countries in which we operate.
We aim to respond to all inquiries and complaints within 30 days.
Last updated: August 28, 2018