Legal Notice & Privacy
Legal Notice
Site operator
SMAPAS PTY LTD
1/24 Tango Ave
Dee Why NSW 2099
Sydney, Australia
Australian Business Number
ABN 84 695 587 314
Contact
Email: info@smapas.com
Responsible party
SMAPAS PTY LTD
Privacy Policy
1. About this policy
SMAPAS PTY LTD ("SMAPAS", "we", "us") handles personal information in line with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs). This policy explains what personal information we collect through this website and when you work with us, why we collect it, where it is stored, and how you can access or correct it or make a complaint. Personal information is information about an identified or reasonably identifiable person. Clients and visitors in the European Union or European Economic Area should also read the GDPR section below.
2. What we collect and why
Visiting this website
When you load a page, our hosting provider records technical data such as your IP address, browser, operating system, the page requested, the referring page and the time. We use it only to deliver the website, keep it secure and fix errors. Log files are kept for a short period and are not combined with other data.
Booking a call
Calls are booked on our own booking page at portal.smapas.com, operated by SMAPAS PTY LTD, which loads no third-party content. When you book, we collect your name, email address, company (optional), your answers to the booking questions, the time you choose, technical data such as your IP address and browser, and how you reached the page (campaign parameters and the referring website). We use this only to arrange and hold the call (APP 3, APP 6). The appointment and its Microsoft Teams invitation are created in our Microsoft 365 calendar, and the booking record is stored with our hosting providers; these service providers may store data outside Australia, including in the European Union (APP 8). We keep booking records only as long as needed to arrange and follow up the call. Privacy requests and complaints can be directed to us first or to the Office of the Australian Information Commissioner (OAIC).
Contact form and contact card
If you send us your details through a contact form (for example on a team member's contact card), we collect your name, email address and whatever else you choose to give us, such as phone number, company, job title and message. We send it by email to the person you contacted and use it only to reply to you and follow up your enquiry.
Chat assistant (Lina)
The chat assistant on this website is an AI system. What you type is sent to Microsoft Azure OpenAI Service (through our own Azure subscription) to generate an answer. We do not store the conversation, and we instruct the service not to store it either. Microsoft may keep inputs for a limited time for abuse monitoring under its own terms. Please do not enter personal or confidential information. We use what you type only to answer your question (APP 3, APP 6).
Clients and prospective clients
When we work with you, we collect business contact details, correspondence, meeting notes and the information needed to deliver, invoice and support our services. Where a project involves your own customers' or staff's personal information, we handle it only on your instructions and as agreed in our contract with you.
Anonymity and direct marketing
You can browse this website and ask general questions without telling us who you are (APP 2). We only send you marketing emails if you have agreed to it or we already have a business relationship, and every such email lets you unsubscribe (APP 7, Spam Act 2003). We do not sell personal information.
3. Where your data is processed
We use the following service providers. Their servers are mostly outside Australia, in the European Union (APP 8). We choose providers that are bound by data processing terms and security standards at least as strong as the APPs.
- Hostinger International Ltd. (Cyprus): website and booking page hosting. Servers in Frankfurt (EU); pages are delivered through Hostinger's content delivery network, with an edge location in Sydney.
- Microsoft Azure (Microsoft Corporation): email delivery (data stored in the EU) and the AI chat assistant (resource in Sweden). For the chat assistant, Microsoft may process a request in another of its data centres to answer it.
- Microsoft 365: email, calendar and Microsoft Teams meetings. Our tenant is hosted in the European Union.
4. Security and retention
We protect personal information with access controls, encryption in transit and multi-factor authentication on our business systems. We keep it only as long as we need it for the purpose it was collected for, or as the law requires (for example, tax records), and then delete or de-identify it. If a data breach is likely to cause you serious harm, we will notify you and the OAIC under the Notifiable Data Breaches scheme.
5. Access, correction and complaints
You can ask for access to the personal information we hold about you, or ask us to correct or delete it, at any time and free of charge: info@smapas.com. We will reply within 30 days. If you have a privacy concern, please contact us first so we can try to resolve it. If you are not satisfied with our answer, you can complain to the Office of the Australian Information Commissioner (OAIC): oaic.gov.au.
6. Fonts
This website hosts all its fonts itself. No connection to Google or any other font service is made.
European Clients (GDPR)
This section applies if you are in the European Union or European Economic Area, and to our clients there. It adds to the privacy policy above.
GDPR-compliant infrastructure
For clients in the EU/EEA, we build and run all relevant apps and services on GDPR-compliant infrastructure in the European Union: Microsoft Azure data centres in the EU (including Sweden), Microsoft 365 hosted in the EU, and Hostinger servers in Frankfurt. Each provider is bound by a data processing agreement that includes the EU Standard Contractual Clauses. Where we process personal data on your behalf, we conclude a data processing agreement with you under Art. 28 GDPR.
Controller
SMAPAS PTY LTD, 1/24 Tango Ave, Dee Why NSW 2099, Australia. Email: info@smapas.com
Legal bases
- Delivering this website and keeping it secure, including server logs and strictly necessary storage: our legitimate interest (Art. 6(1)(f) GDPR).
- Booking a call, answering your enquiry and working on a project with you: taking steps before a contract, or performing it (Art. 6(1)(b) GDPR).
- Optional measurement and any other non-essential storage: your consent (Art. 6(1)(a) GDPR), which you can withdraw at any time.
- Keeping business and tax records: our legal obligations (Art. 6(1)(c) GDPR).
Transfers outside the EU
SMAPAS is based in Australia, which has no EU adequacy decision. Where our team in Australia accesses your data, we rely on the EU Standard Contractual Clauses, or where they do not apply, on the transfer being necessary to perform our contract with you (Art. 46 and Art. 49(1)(b) GDPR).
Your rights
You have the right to access (Art. 15), rectification (Art. 16), erasure (Art. 17), restriction of processing (Art. 18), data portability (Art. 20) and to object to processing based on legitimate interest (Art. 21). You can withdraw consent at any time; this does not affect processing carried out before the withdrawal. To use any of these rights, email info@smapas.com. You also have the right to complain to a data protection supervisory authority, in particular in the EU member state where you live or work (Art. 77 GDPR): list of EU data protection authorities.
Website Terms
The content on this website is general information about our services and is not professional advice for your situation. We take care to keep it accurate and up to date, but we do not guarantee it. Nothing on this website excludes, restricts or modifies any consumer guarantee or right you have under the Australian Consumer Law. Links to other websites are provided for convenience; we are not responsible for their content. The text, graphics and design of this website belong to SMAPAS PTY LTD unless stated otherwise. These terms are governed by the laws of New South Wales, Australia.