Privacy Policy

This is the Privacy Policy applying to all users of Smart Life Gadgets & Upside.Digital.

This Privacy Policy is issued under the General Data Protection Regulation and applies to everyone in the EU and United Kingdom.

It also applies to Californian Residents and everyone in Australia.

This Privacy Policy applies to personal data we collect and process. Personal data is information relating to an identifiable person.

1. Who are we?
   • We are Upside.Digital Pty Ltd.
   • This privacy policy applies to smartlifegdtus.wpengine.com
2. We are both a Data Controller and a Data Processor.
   • Data Controller.
     • We are the data controller for the personal data you give us when we provide our services to you or the company you work for.
     • We also collect personal data from you if you send us a request via our website and when you are browsing our website. We are the Data Controller for that personal data.
   • Data Processor.
     • We are the data processor for the personal data collected by our clients when they use our platform.
     • In these cases, the clients are the data controllers.
3. What information do we collect?
   • If you sign up to Upside.Digital we will collect some of your personal information. The extent and type of personal information collected will vary depending on how you interact with us, but usually includes:
     • information about your interests, and products/services you select to receive communications about;
     • contact details such as your name, address, phone number and email address;
     • other information such as your year of birth, gender, family size including children and pets, your type of mobile phone, personal income, employment situation, online shopping habits and personal interests.
   • If you are browsing our websites, we collect information about your browsing session. This includes the browser type, language setting, referring site, any additional websites, and the date and time of each visit.
   • We will also collect your Internet Protocol (IP) address.
4. What information do we process?
   • We process personal data collected by you if you have entered into an agreement with us to use our website and software.
   • We process information about you on behalf of a data controller if we have a processing agreement with that controller.
   • We do not process data except if it is data we control or on instructions from the data controller.
5. How we collect your information?
   • We collect information directly from you.
   • We also collect personal information when you access our website and software and when we provide our services to you.
   • We receive personal information from third parties. If we do, we will protect it as set out in this Privacy Policy.
   • We also collect information through cookies and other tracking technologies. These are very small files which a website uses to identify you when you come back to the site and to store details about your use of the site.
6. Why we collect this information – the legal basis for collecting this information
   • We collect personal data from you because it is necessary for the performance of the contract between you and us.
   • We also collect personal data from you because you consent. You are able to remove your consent at any time. You can do this by contacting info@upside.digital
7. Why we collect this information – the purpose for collecting this information
   • We will use this information to provide our services. We will also use this data to verify your identity, monitor suspicious or fraudulent activity, and to identify violations of our service polices.
   • With your consent, we may use personal data for specific purposes that are separate from any contract between you and us. When we ask you consent, we will provide you with information about why we are collecting this data. You may choose whether to consent or not.
8. How we store your data
   • All data you provide us is stored in secure hosting facilities on the AWS Servers in Sydney, Australia Unless we are required by law to store your data, we will stop processing and delete it once we no longer require it.
9. Your Rights
   • If we process your personal data, you have the rights listed below.
   • For information that we control, we will facilitate your rights.
   • For information that we process, we will assist the data controller to facilitate your rights.
   • We will respond to any requests concerning your rights without undue delay.
   • We will not charge for any request, unless the request is obviously unfounded, or excessive. In the exercise of your rights, we will need to take steps to verify your identity.
   • Right to information.
     • You have a right to information regarding the purposes and nature of the processing we undertake.
   • Right to access.
     • You can access the personal data about that we control and process.
   • Right to correction.
     • If you ask us to, we will correct any information that we hold about you that is incorrect.
   • Right to restrict processing.
     • You can ask us to temporarily stop processing your personal data.
     • You can ask us not to process your personal data for some particular purpose.
   • Right to deletion of your data.
     • Unless we are required by law to hold your data, you may request that we delete it.
     • In any event, unless we are required by law to hold your personal data, we will delete it when we stop providing the service under the data processing agreement.
   • Portability of your data.
     • You can ask us to give you your personal data in a form that allows it to be read by other data controllers of processors. We will provide the data in a structured, commonly used and machine-readable format.
   • Right to complain to the Supervisory Authority
     • You have the right to complain to the data protection Supervisory Authority in your country.
     • If you are in the EU, you can find contact details for your Supervisory Authority here: https://edpb.europa.eu/about-edpb/board/members_en
     • If you are in the UK you can find contact details for the Information Commissioner’s Office here https://ico.org.uk/make-a-complaint/
     • If you are in Australia, the website for the Office Australian Information Commissioner is here: https://www.oaic.gov.au/privacy/privacy-complaints/
10. Personal Data Transfers to other countries
    • IF YOU ARE IN THE EU OR THE UK: Where we are data processors, we will only transfer your personal data out of the UK in accordance with our data processing agreement and standard data protection clauses approved by the Information Commissioner’s Office or the European Data Protection Board.
11. How we secure your personal data
    • Personal Data that we control is stored in secured servers provided by AWS. We have in place Technical and Organisational measures to secure your personal data.
    • Passwords are stored via LastPass
12. Contact Details
    • If you have any questions about the data we control or process, our contact details are
    • info@upside.digital
    • Our mailing address is:
      Suite 5 / 1a Rialto Workspace, Level 1, 60-64 The Corso, Manly NSW 2095, Australia.