If you are a user of the Effective Services, your use of Effective Software is governed by your organisation’s policies. Please direct your privacy questions or concerns to your employer or your organisation’s Effective Software administrators.
2. OVERVIEW OF THIS STATEMENT
We collect and process your Personal Data when you use the Website, when you sign up to receive our content or newsletters and when you engage with us (for example, by sending us an email), and when you are registered as a user or employee in our Services. Our processing operations are mainly necessary to enable us to make contact with you, necessary for the purposes of operating the Services, or based on you having given us consent. We store your Personal Data on servers located within the European Economic Area (the “EEA”). We share your Personal Data within Effective Software (as defined in Section 5 below) and with third parties (as defined in Section 5 below). We may also share your Personal Data with law enforcement agencies or other bodies if we are required by law to do so.
3. INFORMATION WE COLLECT
3.1. Information Related to Your Interaction with Effective and the Offerings
Registration and Contact Information. We collect information about you when you (a) register to use the Services and (b) otherwise provide contact information to us via email, mail, or through our Offerings. This information you provide may include your username, first and last name, email address, mailing address or phone number.
Third Party Platforms. We may collect information when you interact with our advertisements and other content on third-party sites or platforms, such as social networking sites. This may include information such as “Likes”, profile information gathered from social networking sites or the fact that you viewed or interacted with our content.
3.2. Customer Data
Customers of the Services may submit various types of information and data into the Services for hosting and processing purposes (“Customer Data”). Customer Data may include, without limitation, personal information such as names, email addresses and phone numbers of users, contractors and other people involved in health and safety (“People”), which information may be input into the Services by you.
We will only use, disclose and otherwise process Customer Data for the purposes set forth in your agreement with us for the provisioning of the Services (“Service Subscription Agreement”). In addition we have added our DPA, and if you are a customer and would like a countersigned copy, please follow the procedures outlined here.
4. THE PERSONAL DATA WE PROCESS
4.1 We will collect and process the following personal data when you use the Website:
4.1.1 Device Information
4.2.1 You can choose to provide us with the following Personal Data:
Demo Request, White paper, Show Appointments : If you request a demo, request a white paper, or make a show appointments with us, we will process your email address, your name, telephone number, company name
Subscription: If you subscribe to our Blog or regular Marketing material we will process your email address. If you choose to subscribe we will also process information about how you interact with the emails and messages you receive from us, such as whether or not you open the communication, the links you click on, whether you purchase anything or whether you opt out of the communications.
Query Information: You may choose to give us information such as your name, e-mail address, address, telephone number and other details when contacting us by submitting enquiries through the Website contact form, our live chat service on the Website or by e-mailing email@example.com. If you choose to provide us with this information, we will keep a record of this correspondence for as long as is necessary to deal with this query (for further information please see our section on How Long We Keep Your Personal Data in Section 8).
4.2 We collect and process the following personal data when you use the Services:
4.2.1 Device Information
4.2.2 Personal Data
We require a name and email address in order to register a user with the Services. Additional personal data requested is controlled by the Customer for the Services, and they act as Data Controller for that information.
5. HOW AND WHY WE USE YOUR PERSONAL DATA
5.1 We use your information in the following ways:
- To provide, maintain and improve the website and services, including to operate certain features and functionality of the Offerings (for example, by remembering your information so that you will not have to re-enter it during this or subsequent visits);
- To process your inquiries and otherwise deliver customer service;
- To control unauthorised use or abuse of the Offerings and our other products and services, or otherwise detect, investigate or prevent activities that may violate our policies or be illegal;
- To analyse trends, administer or optimize the Offerings, monitor usage or traffic patterns (including to track users’ movements around the Offerings) and gather demographic information about our user base as a whole;
- To communicate directly with you, including by sending you newsletters, promotions and special offers or information about new products and services. Your opt-out options for promotional communications are described in Section 9 (Your Controls and Choices);
- To deliver you advertising, including by serving and managing ads on the Website or on third party sites and to tailor ads based on your interests and browsing history. Please see Section 9 (Your Controls and Choices) for additional information on how to manage the ads you see.
5.2 Legal Basis for Processing (EEA only):
If you are an individual from the European Economic Area (EEA), our legal basis for collecting and using the personal information will depend on the personal information concerned and the specific context in which we collect it. However, we will normally collect personal information from you only where: (a) we have your consent to do so, (b) where we need the personal information to perform a contract with you (e.g. to deliver the Services you have requested), or (c) where the processing is in our or a third party’s legitimate interests (and not overridden by your data protection interests or fundamental rights and freedoms). In some cases, we may also have a legal obligation to collect personal information from you, or may otherwise need the personal information to protect your vital interests or those of another person.
Where we rely on your consent to process the personal information, you have the right to withdraw or decline your consent at any time. Please note that this does not affect the lawfulness of the processing based on consent before its withdrawal.
If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information). Similarly, if we collect and use your personal information in reliance on our (or a third party’s) legitimate interests which are not already described in this Notice, we will make clear to you at the relevant time what those legitimate interests are.
If you have any questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided further below.
6. WHO WE SHARE YOUR PERSONAL DATA WITH
6.1 We will disclose your personal data to our employees and suitably authorised personnel. For example, our Sales and Marketing personnel will use contact information in order to respond to enquiries received via the Website. Our Customer Success and Product Team personnel may use personal information, with our customer’s permission, in order to resolve a product query, or analyse a technical issue with the Services.
6.2 We will disclose your personal information to third parties outside Effective Software including in the following circumstances:
Third Party Service Providers
- to send you post or email via third party communications or delivery service providers
- to provide our customer service infrastructure including our live chat and helpdesk features
- to manage how we follow up with enquiries
For a full list of the sub processors we use, click here.
Regulatory Authorities, Law Enforcement Agencies, Public Bodies and Other Third-Party Companies
- to comply with any applicable legal obligation, court order, summons, search warrants, or any other legal or regulatory obligation or request to which Effective Software is or may become subject; and
- to protect the rights, property or safety of Effective Software, our customers, or others.
SECURITY, STORING AND TRANSFERS OF YOUR PERSONAL DATA
7.1 We store and process your Personal Data on servers located within the European Economic Area (the “EEA”). However, we may transfer your Personal Data outside the EEA where we engage with third party services providers. We only transfer your personal data outside the EEA where the European Commission has decided that the country in question ensures an adequate level of protection in line with EEA data protection standards or there are appropriate safeguards in place to protect your Personal Data. If you would like to find out more about the appropriate safeguards that we have in place to govern the transfer of your Personal Data you can contact us at firstname.lastname@example.org
7.2 Information you provide to us through the Website is protected by encryption. Once we have received your information, we use strictly maintained physical, electronic and procedural safeguards to prevent unauthorised access.
8. WEBSITE LINKS
8.1 The Website contains links to other websites (“Linked Websites”). Effective Software is not responsible for the privacy statements or practices on Linked Websites. This Statement governs only information collected on the Website. When accessing Linked Websites, you should read the privacy statement published on the relevant Linked Website. The terms of our Statement do not apply to Linked Websites. Please check these statements before you submit any Personal Data to Linked Websites.
8.2 The Website contains links to other websites and resources provided by third parties for your convenience and information only. We accept no liability in connection with any Linked Website, or any contract entered on or through a Linked Website. We have no control over the contents of those websites or resources and accept no responsibility for them or for any loss or damage that may arise from your use of Linked Websites.
9. HOW LONG WE KEEP YOUR PERSONAL DATA
9.1 We will keep your Personal Data no longer than is necessary for the purposes for which the data was provided.
9.1.1 Subscription Information: Where you have opted in to receive communications and subsequently opted out or have not confirmed your subscription, we will retain your data for a period not longer than 6 months before removing it from our systems.
9.1.2 Device Information: Device information is stored for a period of 3 years. Where device information is associated with an account that is deleted by request or as per our data retention policy then the associated device information will also be removed.
9.1.3 Query Information: We retain query information for 3 years from the date the query was marked as closed.
9.1.4 User Information: We retain user information for 3 years from the date a Customer ceases to use our service, unless they specifically request us to remove their data sooner than this.
9.2 Please note that in certain circumstances, we may hold your Personal Data for a longer period, for example, if we are processing an ongoing claim or believe in good faith that the law or a relevant regulator may reasonably in our view expect or require us to preserve your data, or to maintain system backups.
10. YOUR CONTROLS AND CHOICES
10.1 Opt-Outs. We may provide you with the opportunity to “opt-out” of having your personal information used for certain purposes when we ask for this information. If you decide to opt-out, we may not be able to provide certain features of the Offerings to you.
10.2 Communication Preferences. If you no longer wish to receive our newsletter and promotional communications, you may opt-out of receiving them by following the instructions included on such communications.
10.3 Blocking Cookies. You can remove or block certain cookies using the settings in your browser but certain features in the website may cease to function as expected if you do so.
10.4 Accessing and Updating Your Personal Information
You have the right to request a copy of the Personal Data held by us about you and to access the following information in relation to the processing of your Personal Data:
- the purposes of processing;
- the categories of Personal Data concerned;
- the recipients of your Personal Data;
- the period for which your Personal Data will be stored;
- the existence of your right to lodge a complaint with the Office of the Data Protection Commissioner; and
- the source of your Personal Data;
We will only charge you for making such an access request where we feel your request is unjustified or excessive. To request your information, please contact us at either email@example.com (if you are not a paying customer) or firstname.lastname@example.org (if you are) with your name and the information requested to be accessed, corrected or removed. We will provide you with information without undue delay and at the latest within one month of receiving your request. We may extend this up to 2 months if necessary, however we will inform you if this arises.
10.5 You have the right to lodge a complaint with a data protection supervisory authority with regards to us processing your Personal Data.
12. NO CHILDREN UNDER 16
For any questions, please email us at email@example.com