- any information or an opinion (whether true or not) about a natural person by which the person’s identity can reasonably be ascertained, whether directly or indirectly;
- your name, organisation, location data, online identifier, address, phone number, fax number, e-mail address, marital status, credit card and taxation information, identification document numbers, health and medical information;
- any identifying factor/s specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person; or,
- any other information about you which is regulated by any applicable laws or regulations.
Any other information is deemed to be Non-Personal.
PRINCIPLES RELATING TO PERSONAL INFORMATION COLLECTION
When we collect personal information, we shall do so according to the following principles, that data will be:
- Processed lawfully, fairly and in a transparent manner;
- Collected for specified, explicit and legitimate purposes;
- Adequate, relevant and limited to what is necessary for the stated purpose;
- Kept accurately in an up-to-date manner, considering available technology;
- Kept in a form that does not permit the identification of a natural person for any longer than is necessary for the stated purpose to be effected; and,
- Processed through methods that ensures appropriate security of the data.
MINORS, INFORMATION COLLECTION AND CONSENT
Our services, campaigns, surveys or training programs powered or hosted by us are sometimes intended for completion by a minor (being any person under the age of majority in their country of residence). If we become aware that we hold information that is identifiable with respect to a minor not engaged with our organisation for the purposes of our stated delivery of a product or service, we will delete it immediately.
In circumstances where our services, surveys or training programs powered or hosted by us are intended for completion by a minor:
- We will highlight the specific purpose/s of collecting information, and its use and disclosure;
- We will never seek or accept the collection of information from minors holding citizenship within any European Union (EU) country while aged less than 13 years unless required expressly by domestic legislation, law, regulation or policy in order to conduct our operations as a housing and training provider;
- If we do seek or accept the collection of information from minors holding EU citizenship while aged between 13 and 16 years, we will obtain appropriate consent by the holder of parental responsibility over that child, while taking into consideration the restrictions of technology available to us, to facilitate receipt of such consent, at that time;
- We will ask the minor to confirm that they are a minor;
- We will not ask the minor for any sensitive information, including details about health, medical, race, ethnicity, political opinions, sexual orientation, philosophical beliefs;
- We will not ask for a residential address, credit card details, or any identification document numbers;
- We will not disclose any information provided to any third party other than a third party identified in the communication the minor receives from us.
If a minor opts in, we will ask for permission to offer further services, surveys or rewards, and we will highlight our standard policies in regard to accessing and correcting information, namely that:
- a minor may opt out at any time by contacting us via our Contact page or by unsubscribing from within any sent electronic direct mail (EDM);
- a minor may at any time, ask us what information we continue to hold, and we will correct that information if it has changed or is wrong; and,
WHAT INFORMATION DO WE COLLECT?
You may be asked to provide Personal Information during your conduct with our organisation. Although you do not have to provide the information requested, if you do not you may not be entitled to receive service, treatment or education.
We will collect and retain your responses, any other information you provide and other data we collect when you scan a QR Code or complete a survey. This may include your server address, your internet protocol address, your geographical location and the referral QR Code, browser type, usage information.
WHAT PERSONAL INFORMATION WILL WE NOT COLLECT?
Generally, we will not collect special categories of personal data or information as described by Article 9 of the General Data Protection Regulation (GDPR). However, when we do, we may elect to exclude EU citizens from interaction with our organisation, its marketing or data collection activities. Such exclusion will be outlined in the relevant terms and conditions, which are clearly housed and readily accessible within our software during engagement by a Respondent.
Such special categories of information may be identified as those which reveal racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union memberships. It may also consider genetic and biometric data, health data, or information concerning a natural person’s sex life or sexual orientation.
HOW WILL WE USE AND DISCLOSE YOUR INFORMATION?
We will only use your Personal Information to:
- Appropriately and ethically profile you as a potential user or customer of certain products and services. This profiling may be done in an automated or manual fashion;
- Email you with details of a training program or related service or product from us;
- Produce reports and analysis;
- Respond to any direct questions or enquiries from you; or
We will not use your Personal Information for any other purpose without first obtaining your express permission.
Non-Personal Information and de-identified information: We may use and store your survey responses and other information in an anonymous, de-identified form. We may use and disclose this and other Non-Personal information (including usage and statistical information) for any purpose (including the management and improvement of our services and to provide new services).
We may disclose your Personal Information:
Non-Personal Information and de-identified information: We may use and disclose your information in an anonymous and de-identified form. We may use and disclose this and other Non-Personal information (including usage and statistical information) for any purpose, (including the management and improvement of our services and to provide new services or to provide aggregated or categories of ‘mood/happiness’ ratings.
HOW DO WE PROTECT YOUR INFORMATION?
The confidentiality of information collected about you is of utmost importance to us. We maintain reasonable physical, electronic, and procedural safeguards to protect the security and confidentiality of your information from unauthorized access, misuse or disclosure. We continually review these arrangements to ensure we are doing all that are reasonably and technically feasible at the time to protect your information. However, since no system is 100% secure or error-free, we cannot guarantee that your information is totally protected, for example, from hackers or misuse.
You can also help to keep your information safe by exercising due care to safeguard any passwords, ID numbers, or other special access features associated with your use of our Site or Services. We will try to notify all Members of any possible breach of security and may also post a notice on our website if appropriate.
RETENTION OF DATA
We will take reasonable steps to destroy or permanently de-identify Personal Information from our systems which is no longer required by us, or as any applicable laws or regulations otherwise require.
THIRD PARTY WEBSITES
Our Site may contain links to third party websites, which may or may not be operated in conjunction with our Site. We do not monitor or control the information collected and used when you choose to “click through” links to these websites. The treatment of user data by the operators of third party websites may be different from ours. For details regarding their treatment of information about you, you will need to read their privacy policies or contact them.
YOUR ACCESS TO YOUR PERSONAL INFORMATION
We strive to keep your Personal Information accurate, up-to-date and complete as necessary for the purposes for which we use that data. You can find out what Personal Information we hold about you and correct that information if it is wrong. However, we may refuse access to Personal Information where the information being sought is mixed with other information that would disclose Personal Information of another person, where providing access would be unlawful or where denying access is authorised by law.
If you believe that any information we hold about you is incorrect or out-of-date, please let us know immediately. We will be happy to accept updated Personal Information in writing from the owner of that information at any time (subject to verification of your identity). Except where applicable laws and regulations provide otherwise, we reserve the right to recover any reasonable costs involved in providing extensive access to Personal Information, for example the cost supplying information held in archives. You may request the erasure of your personal information or the restriction of the processing of your personal data at any time, in writing to us. We may decide to erase your personal data provided that it:
- Is no longer necessary in relation to our stated purpose during collected, and as consented to by you;
- If you expressly withdraw your consent for our use of the data (this must be done in writing);
- That you object to the grounds upon which your data has been, or will be, processed; or,
- It is found by a relevant legal authority that such data collection was unlawfully processed.
UNSUBSCRIPTION DOES NOT AUTOMATICALLY PROMPT PERSONAL INFORMATION ERASURE
ADDITIONAL COUNTRY SPECIFIC INFORMATION
EUROPEAN UNION (EU) and the GDPR