Contents
- 1.What this policy covers
- 2.When we handle information for our customers
- 3.What we collect
- 4.Sensitive information
- 5.How we collect information
- 6.Why we use information
- 7.News and marketing
- 8.Cookies and similar technologies
- 9.Who we disclose information to
- 10.Disclosure overseas
- 11.How we protect information
- 12.How long we keep information
- 13.Data breaches
- 14.Accessing and correcting your information
- 15.Questions and complaints
- 16.Children
- 17.Changes to this policy
This policy explains how Smart Solution Int Pty Ltd collects, uses, discloses and protects personal information, and how you can access it, correct it or make a complaint. We handle personal information in line with the Privacy Act 1988 (Cth) and the Australian Privacy Principles.
Personal information is information or an opinion about an identified individual, or an individual who is reasonably identifiable.
1What this policy covers
This policy applies to personal information we handle through:
- our website, smartsolutionint.com (the “Website”), and our contact channels, including email, phone and WhatsApp;
- our customer and partner relationships, including quotes, orders, projects and support;
- our accounts and portals, including Smart Account, the Tensai client portal and our staff portals;
- our Products, including our digital identity products (Tensai, our readers and verifiers, our SDKs, document issuing, digital wallets and the Tensai Test Wallet), our ID document and face recognition products, and our laboratory products.
2When we handle information for our customers
Many of our Products are used by our business customers to handle information about their customers, staff or other people, for example when a venue uses one of our readers to check a mobile driver licence, or a laboratory uses our Laboratory Result Analyzer.
In those cases, our customer decides why and how that information is handled, and is responsible for telling those people about it and, where needed, obtaining their consent. We handle that information only to provide, secure and support the Product, on our customer’s instructions and in line with our agreement with them. If you have a question about information a business handled using one of our Products, please contact that business first. We will help them respond.
3What we collect
What we collect depends on how you deal with us.
Website visitors and enquiries
- Your name, organisation, role, email address, phone number and the content of your message when you contact us or ask for a quote.
- Your email address if you subscribe to our newsletter.
- Technical information, such as your IP address, browser and device type, pages visited, and the date and time of your visit, collected through server and security logs and cookies (see section 8).
Customers, partners and suppliers
- Contact and business details of the people we deal with, such as names, roles, email addresses, phone numbers and addresses.
- Order, delivery, invoice and payment records. We do not store full payment card numbers.
- Records of our communications, support requests and project information.
Account and portal users (such as Smart Account, the Tensai client portal and staff portals)
- Your name, email address, organisation and role, and the permissions your organisation gives you.
- Your password, which we store only in a protected, hashed form, and your two-step sign-in (authenticator) set-up, which we store encrypted.
- Records of sign-ins and account activity, including dates, times, IP addresses and actions taken, which we keep for security and audit purposes.
- Your acceptance of our Terms and Conditions.
- Records of emails we send you, such as invitations, password resets and notices that a licence is waiting.
Tensai test licences and the Tensai Test Wallet
- The test licence details that our customers enter, such as a name, date of birth, address, licence class and a portrait or signature image. These should be test details, or real details of a person who has given informed consent.
- Information about the phones that collect test licences, such as the phone’s make and model, operating system version, app version, an identifier for the installed app, the results of the phone’s security checks, and when it was last seen.
- Records of offers made and licences issued, such as dates, the phone used and the status. The one-time links and PINs used to collect a licence are stored only in protected form (hashed or encrypted), and are shown only to the person they are for.
Readers, verifiers and SDKs
- Our readers and SDKs are designed to check identity credentials on the device. We do not receive the identity information a customer’s device reads unless the customer chooses to send it to us, for example to investigate a support request.
- We do collect technical information needed to licence, update and support devices and software, such as device serial numbers, licence and activation details, software and firmware versions, error reports and IP addresses.
ID document and face recognition products
- Images of identity documents and the information extracted from them, images of faces, and biometric information derived from them (such as a face template or match score). We process these on behalf of our customers to provide the result they request.
Laboratory products
- Laboratory results and related information that our customers send to the Laboratory Result Analyzer. This may include health information. We ask customers to de-identify it before sending wherever possible.
Job applicants
- If you apply to work with us, your application, CV, references and our assessment.
4Sensitive information
Some of the information above is sensitive information under the Privacy Act, including biometric information used to verify or identify a person, and health information. We collect sensitive information only with the person’s consent (which, for information we handle on behalf of a customer, the customer obtains), or where the law otherwise allows it. We use it only for the purpose it was collected for, and we protect it with extra care.
5How we collect information
We collect personal information:
- from you, for example when you contact us, create an account, set up two-step sign-in or use our Products;
- from your organisation, for example when your administrator, or our staff at your organisation’s request, invites you to a portal or enters test licence details for you;
- automatically, for example through Website logs and cookies, account activity records, and information our apps and devices send to licence, update and secure them; and
- from third parties, such as our service providers, or publicly available business information.
If you give us information about another person, please make sure they know you are doing so and why, and that they agree.
You can visit the Website without giving us your name. If you do not give us the information we ask for, we may not be able to respond to you or provide a Product.
6Why we use information
We use personal information to:
- respond to enquiries, prepare quotes and supply Products and Services;
- create and manage accounts, verify sign-ins and keep accounts secure;
- issue test licences, deliver them to the right phone and record what happened;
- licence, update, maintain and support our Software and Hardware;
- send service messages, such as invitations, password resets, security notices and changes to our terms;
- detect, investigate and prevent fraud, misuse and security incidents, and keep audit records;
- improve our Products, using aggregated or de-identified information wherever possible;
- manage our business, including invoicing, accounting, record keeping and recruitment;
- send you news about our Products, if you agree (see section 7); and
- meet our legal obligations and enforce our agreements.
We do not sell personal information.
7News and marketing
We send marketing emails only if you have agreed, or if the law otherwise allows it, and always in line with the Spam Act 2003 (Cth). Every marketing email includes a way to unsubscribe, and you can also ask us to stop at any time using the details in section 15. We will still send you service messages about your account and Products.
8Cookies and similar technologies
The Website uses cookies and similar technologies to make it work, keep it secure (for example, to detect malicious traffic) and remember your preferences. Some are set by our service providers, such as our hosting, content-delivery and security providers. Where we use analytics, we use it to understand how the Website is used so we can improve it.
Our portals use cookies that are necessary to keep you signed in securely. They also store some preferences, such as a light or dark theme, on your device.
You can block or delete cookies in your browser settings, but parts of the Website and our portals may not work without them.
9Who we disclose information to
We disclose personal information only as needed for the purposes in section 6, to:
- service providers who help us run our business and Products, such as cloud hosting (our Tensai services are hosted by Amazon Web Services in Sydney, Australia), content delivery and security, email delivery, business email and productivity tools, payment and accounting services, and couriers. They may use the information only to provide their services to us;
- our related companies and team members, who help us provide and support our Products, including in Oman;
- your organisation, for information about your account and your use of Products that your organisation provides to you, for example its administrators can see who has been invited and which licences have been sent;
- professional advisers, such as lawyers, accountants and auditors;
- government agencies, regulators and law enforcement, where the law requires or allows it; and
- a buyer or successor of all or part of our business, under confidentiality obligations.
10Disclosure overseas
Some of the people we disclose information to are outside Australia. It is likely that personal information will be disclosed to, or accessible from:
- Oman, where some of our team and related companies are located; and
- the United States and other countries where our service providers, such as our content-delivery, email and productivity providers, store or process data.
Our Tensai platform data (accounts, test licences, device records and audit records) is hosted in Australia. Where information is disclosed overseas, we take reasonable steps to make sure the recipient handles it in line with the Australian Privacy Principles, for example through contractual obligations and by choosing reputable providers.
11How we protect information
We take reasonable steps to protect personal information from misuse, interference, loss and unauthorised access, change or disclosure. Our measures include:
- encryption in transit and, for sensitive data such as test licence details and authenticator set-ups, encryption at rest with managed encryption keys;
- two-step sign-in for portal users and access controls that limit staff access to what their role needs;
- audit records of access to sensitive information;
- protected hosting environments, security monitoring and regular updates; and
- confidentiality obligations for our staff and service providers.
No system is completely secure. If you think your account or information has been compromised, please tell us straight away.
12How long we keep information
We keep personal information only as long as we need it for the purposes in section 6, or as the law requires (for example, financial records). Then we delete it or de-identify it. For example:
- account information: while your account is active, and for a reasonable period after it closes for security and audit purposes;
- email contents: once an email has been sent, we delete its contents from our systems and keep only a record that it was sent;
- test licence details: while needed for testing. They can be purged by us or at our customer’s request, and test details no longer in use may be purged automatically;
- information we handle for customers (including ID document, face and laboratory information): only as long as needed to provide the result and as our agreement with the customer requires; and
- audit and security records: for as long as needed to protect our systems and meet our obligations.
13Data breaches
If we have an eligible data breach, we will notify affected people and the Office of the Australian Information Commissioner (OAIC) as required by the Notifiable Data Breaches scheme. Where a breach involves information we handle for a customer, we will tell the customer promptly and help them respond.
14Accessing and correcting your information
You can ask to access the personal information we hold about you, or ask us to correct it if it is inaccurate, out of date, incomplete, irrelevant or misleading. Contact us using the details in section 15. We may need to verify your identity first.
We will respond within 30 days. We do not charge for a request to access or correct your information, but we may charge a reasonable fee for the cost of providing access to large amounts of information. If we refuse a request, we will tell you why, in writing, and how you can complain.
Account users can also see and update some information directly in their portal, and administrators of an organisation can manage their own people’s access.
15Questions and complaints
If you have a question about this policy or a complaint about how we have handled your personal information, please contact our Privacy Officer:
Privacy Officer, Smart Solution Int Pty LtdEmail [email protected]Post Sydney NSW 2000, Australia
Please give us enough detail to understand your concern. We will acknowledge your complaint promptly and aim to resolve it within 30 days.
If you are not satisfied with our response, you can complain to the Office of the Australian Information Commissioner:Website www.oaic.gov.auPhone 1300 363 992
16Children
Our Products are for businesses and professionals. They are not directed at children, and we do not knowingly collect personal information from children, except where a customer uses our Products lawfully to check the age or identity of a person who presents a credential.
17Changes to this policy
We may update this policy from time to time. We will post the new version on the Website with a new “Last updated” date. If a change is significant, we will tell you by email or in the relevant portal.