A. OVERVIEW

Your privacy is important to us. This privacy policy explains the personal data SIMBLY SOUTH LLP (‘SIMBLY SOUTH’) processes, how SIMBLY SOUTH processes it, and for what purposes.

SIMBLY SOUTH offers products and references to SIMBLY SOUTH products in this policy includes SIMBLY SOUTH services, websites, applications, software, servers, and devices.

This policy applies to the interactions SIMBLY SOUTH has with you and products and services offered by SIMBLY SOUTH.

 

B. TYPE OF PERSONAL DATA WE COLLECT

SIMBLY SOUTH collects data from you, through our interactions with you and through our products for a variety of purposes described below, including to operate effectively and provide you with the best experiences with our products. You provide some of this data directly, such as when you create an account on our platform, administer your organization’s licensing account or contact us for support. We get some of it by collecting data about your interactions, use, and experience with our products and communications.


We rely on a variety of legal reasons and permissions (“legal bases”) to process data, including with your consent, a balancing of legitimate interests, necessity to enter into and perform contracts, and compliance with legal obligations, for a variety of purposes described below.


We may also obtain data from third parties. We protect data obtained from third parties according to the practices described in this policy, plus any additional restrictions imposed by the source of the data. These third-party sources vary over time and include:

  • Data brokers from which we purchase demographic data to supplement the data we collect.
  • Services that make user-generated content from their service available to others, such as local business reviews or public social media posts.
  • Communication services, including e-mail providers and social networks, when you give us permission to access your data on such third-party services or networks.
  • Service providers that help us determine your device’s location.
  • Partners with which we offer co-branded services or engage in joint marketing activities.

You have choices when it comes to the technology you use and the data you share. When you are asked to provide personal data, you can decline. Many of our products require some personal data to operate and provide you with a service. If you choose not to provide data required to operate and provide you with a product or feature, you cannot use that product or feature. Likewise, where we need to collect personal data by law or to enter into or carry out a contract with you, and you do not provide the data, we will not be able to enter into the contract; or if this relates to an existing product you’re using, we may have to suspend or cancel it. We will notify you if this is the case at the time. Where providing the data is optional, and you choose not to share personal data, features like personalization that use the data will not work for you.


The data we collect depends on the context of your interactions with SIMBLY SOUTH and the choices you make (including your privacy settings), the products and features you use, your location, and applicable law.

 

The data we collect can include the following:

  • Name and contact data– Your first and last name, e-mail address, postal address, phone number, and other similar contact data.
  • Credentials– Passwords, password hints, and similar security information used for authentication and account access.
  • Demographic data– Data about you such as your age, gender, country, and preferred language.
  • Payment data– Data to process payments, such as your payment instrument number (such as a credit card number) and the security code associated with your payment instrument.
  • Subscription and licensing data– Information about your subscriptions, licenses, and other entitlements.
  • Interactions– Data about your use of SIMBLY SOUTH products. In some cases, such as search queries, this is data you provide in order to make use of the products. In other cases, such as error reports, this is data we generate. Other examples of interactions data include:
  • Device and usage data – Data about your device and the product and features you use, including information about your hardware and software, how our products perform, as well as your settings. For example:
    • Payment and account history– Data about the items you purchase, and activities associated with your account.
    • Browse history– Data about the webpages you visit.
    • Device, connectivity, and configuration data– Data about your device, your device configuration, and nearby networks. For example, data about the operating systems and other software installed on your device, including product keys. In addition, IP address, device identifiers (such as the IMEI number for phones), regional and language settings, and information about WLAN access points near your device.
    • Error reports and performance data– Data about the performance of the products and any problems you experience, including error reports. Error reports (“crash dumps”) can include details of the software or hardware related to an error, contents of files opened when an error occurred, and data about other software on your device.
    • Troubleshooting and help data– Data you provide when you contact SIMBLY SOUTH for help, such as the products you use, and other details that help us provide support. For example, contact or authentication data, the content of your chats and other communications with SIMBLY SOUTH, data about the condition of your device, and the products you use related to your help inquiry. When you contact us, such as for customer support, phone conversations or chat sessions with our representatives may be monitored and recorded.
    • Bot usage data– Interactions with third party bots and skills available through SIMBLY SOUTH products.
  • Interests and favourites –Data about your interests and favourites in relation to the usage of SIMBLY SOUTH products. In addition to those you explicitly provide, your interests and favourites can also be inferred or derived from other data we collect.
  • Content consumption data – Information about content you access through SIMBLY SOUTH products.
  • Searches and commands –Search queries and commands when you use SIMBLY SOUTH products with search or related productivity functionality.
  • Voice data – Your voice data (“voice clips”), such as search queries, commands, or dictation you speak, which may include background sounds.
  • Text, inking, and typing data – Text, inking, and typing data and related information. For example, when we collect inking data, we collect information about the placement of your inking instrument on your device.
  • Images –Images and related information, such as picture metadata. For example, we collect the image you provide when you use SIMBLY SOUTH products.
  • Contacts and relationships – Data about your contacts and relationships if you use a product to share information with others, manage contacts, communicate with others, or improve your productivity.
  • Social data – Information about your relationships and interactions between you, other people, and organizations, such as types of engagement (e.g., likes, dislikes, events, etc.) related to people and organizations.
  • Location data – Data about your device’s location, which can be either precise or imprecise. For example, we collect location data using Global Navigation Satellite System (GNSS) (e.g., GPS) and data about nearby cell towers and Wi-Fi hotspots. Location can also be inferred from a device’s IP address or data in your account profile that indicates where it is located with less precision, such as at a city or postal code level.
  • Other input – Other inputs provided when you use our products.
  • Content – Content of your files and communications you input, upload, receive, create, and control. For example, if you transmit a file using SIMBLY SOUTH products, we need to collect the content of that file to display it to you and the other user. Other content we collect when providing products to you may include:
    • Communications, including audio, video, text (typed, inked, dictated, or otherwise), in a message, e-mail, call, meeting request, or chat.
    • Photos, images, songs, movies, software, and other media or documents you store, retrieve, or otherwise process with our cloud.
  • Video or recordings – If you upload video recordings using SIMBLY SOUTH products, we may process your image and voice data.
  • Feedback and ratings– Information you provide to us and the content of messages you send to us, such as feedback, survey data, and product reviews you write.
  • Traffic data – Data generated through your use of SIMBLY SOUTH’s communications services. Traffic data indicates with whom you have communicated and when your communications occurred. We will process your traffic data only as required to provide, maintain, and improve our communications services and we do so with your consent.

 

C . USE OF PERSONAL DATA

SIMBLY SOUTH uses the data we collect in aid of SIMBLY SOUTH products, which you use as well as to recommend other SIMBLY SOUTH products. In particular, we use data to:

  • Provide our products, which includes updating, securing, and troubleshooting, as well as providing support. It also includes sharing data, when it is required to provide the service or carry out the transactions you request.
  • Improve and develop our products.
  • Personalize our products and make recommendations.
  • Advertise and market to you, which includes sending promotional communications, targeting advertising, and presenting you relevant offers.

We also use the data to operate our business, which includes analysing our performance, meeting our legal obligations, developing our workforce, and doing research.
For these purposes, we combine data we collect from different contexts (for example, from your use of two SIMBLY SOUTH products).

Our processing of personal data for these purposes includes both automated and manual (human) methods of processing. Our automated methods often are related to and supported by our manual methods. For example, our automated methods include artificial intelligence (‘AI’), which we think of as a set of technologies that enable computers to perceive, learn, reason, and assist in decision-making to solve problems in ways that are similar to what people do. To build, train, and improve the accuracy of our automated methods of processing (including AI), we manually review some of the predictions and inferences produced by the automated methods against the underlying data from which the predictions and inferences were made. For example, we manually review short snippets of voice data that we have taken steps to de-identify to improve our speech recognition technologies. This manual review may be conducted by SIMBLY SOUTH employees or vendors who are working on SIMBLY SOUTH’s behalf.

When we process personal data about you, we do so with your consent and/or as required to provide the products you use, operate our business, meet our contractual and legal obligations, protect the security of our systems and our customers, or fulfil other legitimate interests of SIMBLY SOUTH.

 

More on the purposes of processing:

  • Provide our products– We use data to operate our products and provide you with rich, interactive experiences. Additionally, as communications are a feature of various products, programs, and activities, we also use data to contact you. For example, we may contact you by phone or e-mail or other means to inform you when a subscription is ending or discuss your licensing account. We also communicate with you to secure our products, for example by letting you know when product updates are available.
  • Product improvement– We use data to continually improve our products, including adding new features or capabilities. For example, we use error reports to improve security features, search queries and to improve the relevancy of the search results, usage data to determine what new features to prioritize, and voice data to develop and improve speech recognition accuracy.
  • Personalization– Many products include personalized features, such as recommendations that enhance your productivity and usage experience. These features use automated processes to tailor your product experiences based on the data we have about you, such as inferences we make about you and your use of the product, activities, interests, and location. With your permission, we can sync your settings on several devices. Many of our products provide controls to disable personalized features.
  • Product activation– We use data such as device and application type, location, and unique device, application, network, and subscription identifiers to activate products that require activation.
  • Product development– We use data to develop new products. For example, we use data, often de-identified, to better understand our customers’ computing and productivity needs which can shape the development of new products.
  • Customer support– We use data to troubleshoot and diagnose product problems, repair customers’ devices, and provide other customer care and support services, including to help us provide, improve, and secure the quality of our products, services, and training, and to investigate security incidents. Call recording data may also be used to authenticate or identify you based on your voice to enable SIMBLY SOUTH to provide support services and investigate security incidents.
  • Help secure and troubleshoot– We use data to help secure and troubleshoot our products. This includes using data to protect the security and safety of our products and customers, detecting malware and malicious activities, troubleshooting performance and compatibility issues to help customers get the most out of their experiences, and notifying customers of updates to our products. This may include using automated systems to detect security and safety issues.
  • Safety– We use data to protect the safety of our products and our customers. Our security features and products can disrupt the operation of malicious software and notify users if malicious software is found on their devices.
  • Updates– We use data we collect to develop product updates and security patches. For example, we may use information about your device’s capabilities, such as available memory, to provide you a software update or security patch. Updates and patches are intended to maximize your experience with our products, help you protect the privacy and security of your data, provide new features, and evaluate whether your device is ready to process such updates.
  • Promotional communications– We use data we collect to deliver promotional communications. You can sign up for e-mail subscriptions and choose whether you wish to receive promotional communications from SIMBLY SOUTH by e-mail, SMS, physical mail, and telephone.
  • Relevant offers– SIMBLY SOUTH uses data to provide you with relevant and valuable information regarding our products. We analyse data from a variety of sources to predict the information that will be most interesting and relevant to you and deliver such information to you in a variety of ways.
  • Advertising– We use data we collect through our interactions with you, through some of our first-party products, services, apps, and web properties (SIMBLY SOUTH properties), and on third-party web properties, for advertising on our SIMBLY SOUTH properties and on third-party properties. We may use automated processes to help make advertising more relevant to you.
  • Transacting commerce– We use data to carry out your transactions with us. For example, we process payment information to provide customers with product subscriptions and use contact information in relation to the fulfilment of the transaction.
  • Reporting and business operations– We use data to analyse our operations and perform business intelligence. This enables us to make informed decisions and report on the performance of our business.
  • Protecting rights and property– We use data to detect and prevent fraud, resolve disputes, enforce agreements, and protect our property. For example, we use data to confirm the validity of software licenses to reduce piracy. We may use automated processes to detect and prevent activities that violate our rights and the rights of others, such as fraud.
  • Legal compliance– We process data to comply with law. For example, we use the age of our customers to assist us in meeting our obligations to protect children’s privacy. We also process contact information and credentials to help customers exercise their data protection rights.
  • Research – With appropriate technical and organizational measures to safeguard individuals’ rights and freedoms, we use data to conduct research, including for public interest and scientific purposes.

 

 D. SHARING OF PERSONAL DATA

We share your personal data with your consent or as necessary to complete any transaction or provide any product you have requested or authorized. If you use a SIMBLY SOUTH product provided by an organization you are affiliated with, such as an employer or school, or use an email address provided by such organization to access SIMBLY SOUTH products, we share certain data, such as interaction data and diagnostic data to enable your organization to manage the products. When you provide payment data to make a purchase, we will share payment data with banks and other entities that process payment transactions or provide other financial services, and for fraud prevention and credit risk reduction. When you permit push notifications for SIMBLY SOUTH products or applications, the operating system of that device will process some personal data to provide push notifications. Accordingly, SIMBLY SOUTH may send data to an external, third-party notification provider to deliver push notifications. Your device’s push notification services are governed by their own service-specific terms and privacy policy’s.


In addition, we share personal data among affiliates and subsidiaries of SIMBLY SOUTH. We also share personal data with vendors or agents working on our behalf for the purposes described in this policy. For example, companies we’ve hired to provide customer service support or assist in protecting and securing our systems and services may need access to personal data to provide those functions. In such cases, these companies must abide by our data privacy and security requirements and are not allowed to use personal data they receive from us for any other purpose. We may also disclose personal data as part of a corporate transaction such as a merger or sale of assets.


Finally, we will retain, access, transfer, disclose, and preserve personal data, including your content, when we have a good faith belief that doing so is necessary to do any of the following:

  • Comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies. 
  • Protect our customers, for example, to prevent spam or attempts to defraud users of our products, or to help prevent the loss of life or serious injury of anyone.
  • Operate and maintain the security of our products, including to prevent or stop an attack on our computer systems or networks.
  • Protect the rights or property of SIMBLY SOUTH, including enforcing the terms governing the use of the services. However, if we receive information indicating that someone is using our services to traffic in stolen intellectual or physical property of SIMBLY SOUTH, we will not inspect a customer’s private content ourselves, but we may refer the matter to law enforcement.

Please note that some of our products include links to or otherwise enable you to access products of third parties whose privacy practices differ from those of SIMBLY SOUTH. If you provide personal data to any of those products, your data is governed by their privacy policies.

 

 E. ACCESS AND CONTROL YOUR PERSONAL DATA

You can also make choices about the collection and use of your data by SIMBLY SOUTH. You can control your personal data that SIMBLY SOUTH has obtained, and exercise your data protection rights, by contacting SIMBLY SOUTH. In some cases, your ability to access or control your personal data will be limited, as required or permitted by applicable law.
If your organization, such as your employer, school, or service provider, provides you with access to and is administering your use of SIMBLY SOUTH products, contact your organization to learn more about how to access and control your personal data.

 

 F. ORGANISATIONAL USERS – NOTICE TO END USERS

If you use a SIMBLY SOUTH product with an account provided by an organization you are affiliated with, such as your work or school account, that organization can:

  • Control and administer your SIMBLY SOUTH product and product account, including controlling privacy-related settings of the product or product account.
  • Access and process your data, including the interaction data, diagnostic data, and the contents of your communications and files associated with your SIMBLY SOUTH product and product accounts.

If you lose access to your work or school account (in event of change of employment, for example), you may lose access to products and the content associated with those products, including those you acquired on your own behalf, if you used your work or school account to sign into such products.


Many SIMBLY SOUTH products are intended for use by organizations, such as schools and businesses. If your organization provides you with access to SIMBLY SOUTH products, your use of the SIMBLY SOUTH products is subject to your organization’s policies, if any. You should direct your privacy inquiries, including any requests to exercise your data protection rights, to your organization’s administrator. SIMBLY SOUTH is not responsible for the privacy or security practices of our customers, which may differ from those set forth in this privacy policy.
When you use a SIMBLY SOUTH product provided by your organization, SIMBLY SOUTH’s processing of your personal data in connection with that product is governed by a contract between SIMBLY SOUTH and your organization. SIMBLY SOUTH processes your personal data to provide the product to your organization and you. If you have questions about SIMBLY SOUTH’s processing of your personal data in connection with providing products to your organization, please contact your organization.
For SIMBLY SOUTH products provided by your school, SIMBLY SOUTH will:

  • not collect or use student personal data beyond that needed for authorized educational or school purposes;
  • not sell or rent student personal data;
  • not use or share student personal data for advertising or similar commercial purposes, such as behavioural targeting of advertisements to students;
  • not build a personal profile of a student, other than for supporting authorized educational or school purposes or as authorized by the parent, guardian, or student of appropriate age; and
  • require that our vendors with whom student personal data is shared to deliver the educational service, if any, are obligated to implement these same commitments for student personal data.

 

 G. COLLECTION OF DATA FROM CHILDREN

When a SIMBLY SOUTH product collects age, and there is an age in your jurisdiction under which parental consent or authorization is required to use the product, the product will either block users under that age or will ask them to provide consent or authorization from a parent or guardian before they can use it. We will not knowingly ask children under that age to provide more data than is required to provide for the product.


In respect of organisational accounts, if an organisation takes our product for usage by a minor, then the organisation is required to first obtain consent and/or authorisation from the parent/guardian prior to permitting usage of our products by a minor.
We recommend you to also view our Terms of Use which is available at https://gradesup.in/terms.html .

Parents or guardians can change or revoke the consent choices previously made, and review, edit, or request the deletion of the personal data of the children for whom they provided consent or authorization.

 

 H. SECURITY OF PERSONAL DATA

SIMBLY SOUTH is committed to protecting the security of your personal data. We use a variety of security technologies and procedures to help protect your personal data from unauthorized access, use, or disclosure. For example, we store the personal data you provide on computer systems that have limited access and are in controlled facilities. When we transmit highly confidential data (such as a credit card number or password) over the internet, we protect it through the use of encryption. SIMBLY SOUTH complies with applicable data protection laws, including applicable security breach notification laws.

 

 I. STORAGE AND PROCESSING OF PERSONAL DATA

If you utilize our Services from a country other than the country where our servers are located, your personal information may be transferred across international borders, which will only be done when necessary inter-alia, to provide you with our services. Transfer of your personal information is also the appropriate contractual clauses in place with regard to the usage of SIMBLY SOUTH products.


Typically, apart from the primary storage location your data may also have a backup in other locations. The storage location(s) are chosen in order to operate efficiently, to improve performance, and to create redundancies in order to protect the data in the event of an outage or other problem. We take steps to process the data that we collect under this privacy policy according to this policy’s provisions and the requirements of applicable law.

 

 J. RETENTION OF PERSONAL DATA

SIMBLY SOUTH retains personal data for as long as necessary to provide the products and fulfil the transactions you have requested, or for other legitimate purposes such as complying with our legal obligations, resolving disputes, and enforcing our agreements.

 

 K. CHANGES TO THIS PRIVACY POLICY

This privacy policy is subject to periodic revisions without prior intimation. When we post changes to this policy, we will revise the “last updated” date at the top of the policy. We encourage you to periodically review this privacy policy to remain updated about this privacy policy.

 

 L. CONFLICT

In the event of a conflict between this privacy policy and the terms of any agreement(s) between a customer and SIMBLY SOUTH, the terms of those agreement(s) will prevail.

 

 M. HOW TO CONTACT US

If you have a privacy concern, complaint, or questions for us, please contact us by sending an e-mail to info@gradesup.in  .