GDPR Privacy Policy
We are required by law to comply with the Australian Privacy Principles and the General Data Protection Regulation, also known as GDPR.
If you live in the UK, Europe or use data services in the UK or Europe, as of 25 May 2018, you will have increased digital rights under the General Data Protection Regulation or GDPR. If live in the UK or EU, this policy helps you to understand how we respect your Privacy in these regions.
Our data protection policy can be found here:https://thesocialindex.com/data-retention-policy/
1.Introduction
This privacy notice provides you with details of how we collect and process your personal data through your use of our site – https://thesocialindex.com/ .
By providing us with your data, you warrant to us that you are over 13 years of age.
The Social Index Pty Ltd is the data controller and we are responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).
If you have any questions regarding this privacy notice, please contact our Data Protection Lead. Details are provided below.
Contact Details
Our full details are:
The Social Index Pty Ltd
Attn: Data Protection Lead
Address: Suite 3, Level 27
Governor Macquarie Tower
1 Farrer Place
Sydney.NSW. 2000
Australia
Email address: privacy@thesocialindex.com
Alternatively, you may contact us via the contact form on this website.
Representation for data subjects in the EU and the UK
We value your privacy and your rights as a data subject and have therefore appointed Prighter as our privacy representative and your point of contact.
Prighter gives you an easy way to exercise your privacy-related rights (e.g. requests to access or erase personal data). If you want to contact us via our representative Prighter or make use of your data subject rights, please visit: https://prighter.com/q/13531254617
It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at privacy @thesocialindex.com.
2. What data do we collect about you, for what purpose and on what grounds we process it.
Personal data means any information capable of identifying an individual. It does not include anonymised data.
We may process the following categories of personal data about you:
Communication Data that includes any communication that you send to us whether that be through the contact form on our website, through email, text, social media messaging, social media posting or any other communication that you send us. We process this data for the purposes of communicating with you, for record keeping and for the establishment, pursuance or defence of legal claims. Our lawful ground for this processing is our legitimate interests which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.
Customer Data that includes data relating to any purchases of goods and/or services such as your name, title, billing address, delivery address email address, phone number, contact details, purchase details and your card details. We process this data to supply the goods and/or services you have purchased and to keep records of such transactions. Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract.
User Data that includes data about how you use our website and any online services together with any data that you post for publication on our website or through other online services. We process this data to operate our website and ensure relevant content is provided to you, to ensure the security of our website, to maintain back- ups of our website and/or databases and to enable publication and administration of our website, other online services and business. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business.
Technical Data that includes data about your use of our website and online services such as your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website. The source of this data is from our analytics tracking system. We process this data to analyse your use of our website and other online services, to administer and protect our business and website, to deliver relevant website content and advertisements to you and to understand the effectiveness of our advertising. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business and to grow our business and to decide our marketing strategy.
Marketing Data that includes data about your preferences in receiving marketing from us and our third parties and your communication preferences. We process this data to enable you to partake in our promotions, to deliver relevant website content and advertisements to you and measure or understand the effectiveness of this advertising. Our lawful ground for this processing is our legitimate interests which in this case are to study how customers use our products/services, to develop them, to grow our business and to decide our marketing strategy.
We may use Customer Data, User Data, Technical Data and Marketing Data to deliver relevant website content and advertisements to you (including Facebook adverts or other display advertisements) and to measure or understand the effectiveness of the advertising we serve you. Our lawful ground for this processing is legitimate interests which is to grow our business. We may also use such data to send other marketing communications to you. Our lawful ground for this processing is either consent or legitimate interests (namely to grow our business).
2.1 Sensitive Data
We do not collect any Sensitive Data about you, unless you specifically sign up for one of our services that requires it for delivery of the service – details provided below. Sensitive data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. We do not collect any information about criminal convictions and offences.
We need to collect the following sensitive data about you in order to prepare a profile of your online footprint to support career development. The information that we access is all already publically available, but may include the following:
– Racial and ethnic origin
– Political opinions
– Religious and philosophical beliefs
– Trade union membership
– Health
– Sex life or orientation
– Gender
We ask for gender as some names are not gender specific and this helps us ensure that we are looking at the correct profiles.
Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver goods or services to you). If you don’t provide us with the requested data, we may have to cancel a product or service you have ordered but if we do, we will notify you at the time.
We will only use your personal data for a purpose it was collected for or a reasonably compatible purpose if necessary. For more information on this please email us at privacy@thesocialindex.com. In case we need to use your details for an unrelated new purpose we will let you know and explain the legal grounds for processing.
We may process your personal data without your knowledge or consent where this is required or permitted by law.
We do not carry out automated decision making or any type of automated profiling
3. How we collect your Personal Data.
We may collect data about you by you providing the data directly to us (for example by filling in forms on our site or by sending us emails). We may automatically collect certain data from you as you use our website by using cookies and similar technologies. Refer to section 11 for additional information about cookies.
We may receive data from third parties such as analytics providers such as Google based outside the UK and/or the EU, advertising networks such as Facebook based outside the UK and/or the EU, such as search information providers such as Google based outside the UK and/or the EU and providers of technical, payment and delivery services.
For the provision of some of our services, we will search publicly available information on you (i.e. Google search, social media profiles). We may also require access to additional data that both yourself and the provider explicitly agree to share with us (i.e. LinkedIn allows data to be extracted via an API if we have your consent). Please note, that we only view data – we never edit or update any of the data we are accessing, nor will we post or comment or make representations that we are you.
We may also receive data from publicly availably sources such as Companies House and the Electoral Register based inside or outside the UK and/or the EU.
4. Marketing Communications
Our lawful ground of processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely to grow our business).
Under the Privacy and Electronic Communications Regulations, we may send you marketing communications from us if (i) you made a purchase or asked for information from us about our goods or services or (ii) you agreed to receive marketing communications and in each case you have not opted out of receiving such communications since. Under these regulations, if you are a limited company, we may send you marketing emails without your consent. However you can still opt out of receiving marketing emails from us at any time.
Before we share your personal data with any third party for their own marketing purposes we will get your express consent.
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or OR by emailing us at privacy@thesocialindex.com at any time.
If you opt out of receiving marketing communications this opt-out does not apply to personal data provided as a result of other transactions, such as purchases, warranty registrations etc.
5. Disclosures of your Personal Data.
We may have to share your personal data with the parties set out below:
– Service providers who provide IT and system administration services.
– Professional advisers including lawyers, bankers, auditors and insurers
– Service providers who provide analysis, coaching and career advice
– Government bodies that require us to report processing activities.
– Third parties to whom we sell, transfer, or merge parts of our business or our assets.
We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.
6. International Transfers
The Social Index Ltd is headquartered in Australia and much of our business is managed from there. We are conscious that some of our clients are within the UK and EU, and we want to protect any international transfer of your data and comply with the relevant UK and EU regulations.
Given this, we will protect your personal data in line with the provisions of the UK General Data Protection Regulations or the EU General Data Protection Regulations – as appropriate.
Where we transfer your data to third parties outside of the UK or EU, we will ensure that certain safeguards are in place to ensure a similar degree of security for your personal data. As such:
– We may transfer your personal data to countries that the relevant regulatory authorities in the United Kingdom or European Commission have approved as providing an adequate level of protection for personal data by; or
– If we use US-based providers that are part of a UK regulator or EU approved privacy framework, we may transfer data to them, as they have equivalent safeguards in place; or
– Where we use certain service providers who are established outside of the UK or EEA, we may use specific contracts or codes of conduct or certification mechanisms approved by the United Kingdom or EU regulators which give personal data the same protection it has in the UK or EEA.
If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.
7. Data Security
We have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorisation. We also allow access to your personal data only to those employees and partners who have a business need to know such data. They will only process your personal data on our instructions and they must keep it confidential.
We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we are legally required to.
8. Data Retention
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
When deciding what the correct time is to keep the data for we look at its amount, nature and sensitivity, potential risk of harm from unauthorised use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements.
For tax purposes the law requires us to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for seven years after the transaction date.
In some circumstances we may anonymise your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
9. Your Legal Rights
Under data protection laws you have rights in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent.
If you are within the UK, you can see more about these rights at:
https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/ If you wish to exercise any of the rights set out above.
Alternatively, you may email us at privacy@thesocialindex.com.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive or refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you.
If you are within the UK and are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.
If you are within the EU and are not happy with any aspect of how we collect and use your data, you have the right to complain to the data protection authority of the country in which you are based. We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.
10. Third Party Links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
11. Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.
What’s a cookie?
– A “cookie” is a piece of information that is stored on your computer’s hard drive if you agree to this and which records how you move your way around a website so that, when you revisit that website, it can present tailored options based on the information stored about your last visit. Cookies can also be used to analyse traffic and for advertising and marketing purposes.
– Cookies are used by nearly all websites and do not harm your system.
We are required to obtain your consent for all non-essential cookies used on our website. You can block cookies (including essential cookies) at any time by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block essential cookies you may not be able to access all or parts of our site.
How do we use cookies?
We use cookies to track your use of our website. This enables us to understand how you use the site and track any patterns with regards how you are using our website. This helps us to develop and improve our website as well as products and / or services in response to what you might need or want.
Cookies are either:
– Session cookies: these are only stored on your computer during your web session and are automatically deleted when you close your browser – they usually store an anonymous session ID allowing you to browse a website without having to log in to each page but they do not collect any personal data from your computer; or
– Persistent cookies: a persistent cookie is stored as a file on your computer and it remains there when you close your web browser. The cookie can be read by the website that created it when you visit that website again. (We use persistent cookies for Google Analytics.)
Cookies can also be categorised as follows:
– Strictly necessary cookies: These cookies are essential to enable you to use the website effectively, such as when buying a product and / or service. Without these cookies, the services available to you on our website cannot be provided. These cookies do not gather information about you that could be used for marketing or remembering where you have been on the internet.
– Performance cookies: These cookies enable us to monitor and improve the performance of our website. For example, they allow us to count visits, identify traffic sources and see which parts of the site are most popular.
– Functionality cookies: These cookies allow our website to remember choices you make and provide enhanced features. For instance, we may be able to provide you with news or updates relevant to the services you use. They may also be used to provide services you have requested such as viewing a video or commenting on a blog. The information these cookies collect is usually anonymised.
– Targeting cookies: These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests.
– First and third party cookies: First party cookies are cookies set by our website. Third party cookies are cookies on our website that are set by a website other than our website, such as where we have adverts on our website or use Facebook pixels so that we can show you relevant content from us when you are on Facebook.
Signed and Approved:
Date Approved: 9 June 2022
Name: Fiona McLean
Role: CEO
Signature: FLMcLean