Privacy Policy

Effective Date: 1 May 2023

Table of Contents

  • Introduction
  • Data Protection Officer
  • How we collect and use (process) your personal information
  • Use of the Digital website
  • Cookies and tracking technologies
  • Use of the Digital Matter services
  • When and how we share information with third parties
  • Transferring personal data to the U.S.
  • Data Subject rights
  • Security of your information
  • Data storage and retention
  • Consent
  • Children’s Data
  • Changes to this Policy
  • Questions, concerns, or complaints


DIGITAL MATTER (PTY) LTD (“Digital Matter”), is a company, duly registered and incorporated in Australia with its head office situated at Suite 8, 100 Railway Road, Subiaco, 6008, Western Australia, and with offices in South Africa, North America and Europe.

We understand that you care about your own personal privacy interests, and we take that very seriously. This Privacy Notice describes Digital Matter’s policies and practices regarding its collection and use of your personal data and sets forth your privacy rights. We recognize that information privacy is an ongoing responsibility, and so we will from time to time update this Privacy Notice as we undertake new personal data practices or adopt new privacy policies.

Data Protection Officer

Digital Matter is headquartered in Perth, Subiaco, in Western Australia. Digital Matter has appointed an internal data protection officer for you to contact if you have any questions or concerns about Digital Matter’s personal data policies or practices. If you would like to exercise your privacy rights, please direct your query to Digital Matter’s internal data protection officer. Digital Matter’s data protection officer’s name and contact information are as follows:

Carl Fagelund – Gjersöe
Digital Matter BV
Rijksstraatweg 20A & B, 2171 AL Sassenheim, Netherlands
[email protected]
+31 62192 2724

How we collect and use (process) your personal information

Digital Matter collects personal information about its website visitors and its customers/resellers. With a few exceptions, this information is generally limited to:

  • name
  • job title
  • company name
  • work address
  • work email
  • work telephone number

We do not sell, lease or distribute any personal information or customer lists to any third party and only share it with third parties who require this for the sole purpose of facilitating and providing the delivery of our services, helping us perform relevant statistical analysis, invoicing, notification of updates, sending you email or postal mail, providing customer support, or arranging deliveries.

We use this information to provide prospects and customers/resellers with information on our products and services, to record and process the services and/or products you have requested and in order to be able to invoice customers/resellers. We may also contact you for the purpose of conducting surveys and research pertaining to your interest in our products and/or services and potential new products and/or services.

From time to time, Digital Matter receives personal information about individuals from third parties. Typically, information collected from third parties will include further details on your employer or industry. We may also collect and process your personal data, which is publicly available, from a third party website (e.g. LinkedIn).

Digital Matter does not store, process, transmit or disclose sensitive personal information, such as race, religion, or political affiliations.

We secure your personal information from unauthorized access, use or disclosure. We secure the personally identifiable information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure. When personal information (such as a credit card number) is transmitted to other websites, it is protected through the use of encryption, such as the Secure Socket Layer (SSL) protocol.

Use of the Digital Matter Websites

As is true of most websites, Digital Matter’s websites collect certain information automatically and store it in log files. The information may include internet protocol (IP) addresses, the region or general location from where your computer or device is accessing the internet, browser type, operating system and other usage information about the use of Digital Matter’s websites, including a history of the pages you view. We use this information to help us design our sites to better suit our users’ needs and to be able to provide users with the most appropriate/relevant information. We may also use your IP address to help diagnose problems with our server and to administer our websites, analyze trends, track visitor movements, and gather broad demographic information that assists us in identifying visitor preferences.

Digital Matter has a legitimate interest in understanding how users, customers/resellers and potential customers/resellers use its websites. This assists Digital Matter with providing more relevant products and services, tailoring our offerings and advice, communicating value to our sponsors, suppliers, other customers/resellers and with providing appropriate staffing to meet user’s and customer’s/reseller’s needs.

We keep track of the web pages our users/customers/resellers visit on our websites, in order to determine what services of ours are the most popular and the most relevant to you. This data is used to deliver customized content and advertising to users/customers/resellers whose behavior indicates that they are interested in a particular subject area.

Cookies and tracking technologies

A cookie is a text file that is placed on your hard disk by a web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie. One of the primary purposes of and reasons for cookies is to provide a convenience feature to save you time in the future when accessing the same website. The purpose of a cookie is to tell the web server that you have returned to a specific page. For example, if you personalize Digital Matter’s websites (for example Digital Matter Telematics Guru) a cookie helps to recall your information on subsequent visits. This simplifies the process of recording and recalling your information, such as billing addresses, shipping addresses, and so on, each and every time you log on. When you return to the same Digital Matter website, the information you previously provided can be retrieved, so you can easily access and use the features that you had previously customized.

You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to receive the full benefit and experience of the interactive features of the Digital Matter websites you visit.

Digital Matter makes available a comprehensive list of cookies.

Sharing information with third parties

The personal information Digital Matter collects from you is stored and/or processed in or by one or more databases hosted by third parties located in various parts of the world depending on where you are, or the customer/reseller is, based and what services/products of Digital Matter you/the customer/the reseller use. These third parties are referred to as subprocessors and their locations are listed in the table below. Sub-processors are engaged by Digital Matter to process certain elements of personal data, in order for Digital Matter to properly and effectively provide its services and products to users, customers/resellers.

Digital Matter makes available a comprehensive list of subprocessors.

From time-to-time Digital Matter’s subprocessors may change, reduce or increase. Should you wish to be notified of these changes you can subscribe here to be alerted when changes take place.

We do not otherwise reveal your personal data to non-Digital Matter persons or businesses for their independent use unless: (1) you request or authorize it; (2) it’s necessary in order for Digital Matter to effectively provide the services or products you procure from us; (3) the information is provided to comply with the law (for example, compelled by law enforcement to comply with a search warrant, subpoena, or court order), enforce an agreement we have with you, or to protect our rights, property or safety, or the rights, property or safety of our employees or others; (4) the information is provided to our agents, vendors or service providers who perform functions on our behalf; (5) to address emergencies or acts of God;  (6) to assess and/or address disputes, claims; or (7) to persons demonstrating reasonable legal authority to act on your behalf. We may also gather aggregated data about our services and website visitors and disclose the results of such aggregated (but not personally identifiable) information to our partners, service providers, advertisers, and/or other third parties for marketing or promotional purposes.

The Digital Matter websites connect with third party services such as Facebook, LinkedIn, Twitter and others. If you choose to share information from the Digital Matter websites through these services, you should review the privacy policy of that service. If you are a member of a third party service, the aforementioned connections may allow that service to connect your visit to Digital Matter’s websites to your personal data.

Transferring personal data to the U.S.

While Digital Matter’s head office is in Australia, some of the information we collect about you will be processed in the United States. By using Digital Matter’s web site and services, you acknowledge that your personal information will be processed in the United States of America and you consent thereto. The United States has not sought nor received a finding of “adequacy” from the European Union under Article 45 of the General Data Protection Regulation (“GDPR”). Pursuant to Article 46 of the GDPR, Digital Matter is providing for appropriate safeguards by entering binding, standard data protection clauses, enforceable by data subjects in the EEA and the UK. These clauses have been enhanced based on the guidance of the European Data Protection Board and will be updated when the new draft model clauses are approved.

Depending on the circumstance, Digital Matter also collects and transfers personal data to the United States in the following circumstances: with your prior express consent; to perform in terms of a contract with you; or to fulfill a compelling legitimate interest of Digital Matter in a manner that does not outweigh your rights and freedoms. Digital Matter endeavors to apply suitable safeguards to protect the privacy and security of your personal data and to only use it in furtherance of your relationship with Digital Matter and the practices described in this Privacy Statement. Digital Matter also enters into data processing agreements and model clauses with its vendors whenever feasible and appropriate. Since it was founded, Digital Matter has received no government requests for information.

For more information or if you have any questions, please contact us at: [email protected]

Data Subject rights

GDPR Compliant Logo

The GDPR and other countries’ privacy laws provide certain rights to data subjects – meaning individuals such as you. Data Subject rights under GDPR include the following:


  • Right to be informed
  • Right of access
  • Right to rectification
  • Right to erasure
  • Right to restrict processing
  • Right of data portability
  • Right to object
  • Rights related to automated decision-making including profiling


This Privacy Notice is intended to provide you with, amongst others, information about what personal data Digital Matter collects about you and how it is used.

If you wish to confirm that Digital Matter is processing your personal data, or to have access to the personal data Digital Matter may have about you, please contact us using the mail address provided below.

You may also request information about: the purpose of the processing; the categories of personal data concerned; who else outside Digital Matter might have received the data from Digital Matter; what the source of the information was (if you didn’t provide it directly to Digital Matter); and how long it will be stored. You have a right to correct (rectify) the record of your personal data maintained by Digital Matter if it is inaccurate. You may request that Digital Matter erase that data or cease processing it, subject to certain exceptions. You may also request that Digital Matter cease using your data for direct marketing purposes. In many countries, you have a right to lodge a complaint with the appropriate data protection authority if you have concerns about how Digital Matter processes your personal data. When technically and legally feasible, Digital Matter will—at your request—provide your personal data to you.

Reasonable access to your personal data will be provided at no cost. If access cannot be provided within a reasonable time frame, Digital Matter will provide you with a date when the information will be provided. If for some reason access is denied, Digital Matter will provide an explanation as to why access has been denied.

For questions or complaints concerning the processing of your personal data, you can email us at [email protected]. Alternatively, if you are located in the European Union, you can also have recourse to the European Data Protection Supervisor or to your country’s relevant data protection authority.

Data storage and retention

Your personal data is stored by Digital Matter on its servers, and on the servers of the cloud-based database management services that Digital Matter engages, located in the regions as listed under the subprocessors section. In some instances and dependent on the services and/or product you utilize, Digital Matter may retain certain data provided and obtained in the performance of the service or the use of the product, for the duration of the customer’s business relationship with Digital Matter and for a period of time thereafter, in order to successfully and appropriately provide the services and/or to analyze the data for Digital Matter’s own operations, and for historical and archiving purposes associated with Digital Matter’s services. Digital Matter retains prospect data until such time as it no longer has business value and is purged from Digital Matter’s systems. All personal data that Digital Matter controls may be deleted upon verified request from Data Subjects or their authorized agents. For more information on where and how long your personal data is stored, and for more information on your rights of erasure and portability, please contact us at: [email protected].


By your review of this privacy policy and electing to proceed to access Digital Matter’s websites and/or order and/or use Digital Matter’s services and/or products you are expressly granting Digital Matter your consent to store, process, sub-process and utilize your personal information.

Children’s data

Digital Matter does not knowingly attempt to solicit, receive, store, transmit or process information from or about children.

Changes to this policy

Digital Matter will occasionally update this Privacy Policy. You are therefore encouraged to periodically review this Privacy Policy.

Questions, concerns or complaints

If you have questions, concerns, complaints, or would like to exercise your rights, please contact us at:

Digital Matter (Pty) Ltd
C/O Digital Matter BV
Rijksstraatweg 20a and b, 2171 AL Sassenheim, Netherlands
[email protected]