This Privacy Statement applies to all business activities of Unity4 Holdings Pty Ltd and its subsidiary companies (“Unity4″) to the extent that they affect or involve the collection, use, disclosure or handling of personal information. Unity4 understands the importance to its clients and to their customers of the discreet and confidential handling of their personal information. It is Unity4’s policy to comply with the requirements of the Privacy Act 1988 and the National Privacy Principles (AUS) contained in that Act, Data Protection Act and General Data Protection (GDPR) principals (UK, EU) in all activities of Unity4 involving the collection, use, disclosure and handling of personal information. In this Privacy Statement, personal information means information or an opinion (including information or an opinion forming part of a database), whether true or not, and whether recorded in a material form or not, about an individual whose identity is apparent, or can reasonably be ascertained, from the information or opinion (source: Privacy Act 1988).
Unity4 understands that your privacy is important to you and that you care about how your personal data is used and shared online. We respect and value the privacy of everyone who visits this website, www.unity4.com (“Our Site”) and will only collect and use personal data in ways that are described here, and in a manner that is consistent with Our obligations and your rights under the law.
1. Definitions and Interpretation
In this Policy, the following terms shall have the following meanings:
“personal data” means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Site. This definition shall, where applicable, incorporate the definitions provided in the Data Protection Act 1998 OR EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”); and
“We/Us/Our” means Unity4 and its subsidiaries in Australia, United Kingdom, New Zealand, Canada and Fiji.
2. Information About Us
2.1 Our Site is owned and operated by Unity4 and its subsidiaries in Australia, United Kingdom, New Zealand, Canada and Fiji.
2.2 In the UK our VAT number is 112782039.
2.3 In Australia our ABN is 99 613 723 872
2.4 Our Data Protection Officer is Daniel Turner, and can be contacted by email at firstname.lastname@example.org, by telephone on +61296998279.
2.5 ICO Registration No. ZA336610.
3. What Does This Policy Cover?
4. Your Rights
4.1 As a data subject, you have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:
4.1.1 The right to be informed about Our collection and use of personal data;
4.1.2 The right of access to the personal data We hold about you (see section 12);
4.1.3 The right to rectification if any personal data We hold about you is inaccurate or incomplete (please contact Us using the details in section 13);
4.1.4 The right to be forgotten – i.e. the right to ask Us to delete any personal data We hold about you (We only hold your personal data for a limited time, as explained in section 6 but if you would like Us to delete it sooner, please contact Us using the details in section 13);
4.1.5 The right to restrict (i.e. prevent) the processing of your personal data;
4.1.6 The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);
4.1.7 The right to object to Us using your personal data for particular purposes; and
4.1.8 Rights with respect to automated decision making and profiling.
4.2 If you have any cause for complaint about Our use of your personal data, please contact Us using the details provided in section 13 and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.
4.3 For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.
5. What Data Do We Collect?
Depending upon your use of Our Site, we may collect some or all of the following personal and non-personal data:
5.2 date of birth;
5.4 business/company name
5.5 job title;
5.7 contact information such as postal address, email addresses and telephone numbers;
5.8 previous work history
5.9 records of correspondence with/between us
6. How Do We Use Your Data?
6.1 All personal data is processed and stored securely, for no longer than is necessary considering the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the GDPR at all times. For more details on security see section 7, below.
6.2 Our use of your personal data will always have a lawful basis, either because it is necessary for Our performance of a contract with you, because you have consented to Our use of your personal data (e.g. by subscribing to emails), or because it is in Our legitimate interests. Specifically, we may use your data for the following purposes:
6.2.1 Supplying Our products AND/OR services to you (please note that We require your personal data in order to enter into a contract with you);
6.2.2 Personalising and tailoring Our products AND/OR services for you;
6.2.3 Replying to emails from you;
6.2.4 Recruitment and and/or employment reasons.
6.3 You have the right to withdraw your consent to Us using your personal data at any time, and to request that We delete it.
6.4 We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Data will therefore be retained for the following periods (or its retention will be determined on the following bases):
6.4.1 Personal and non-personal data, such as that described above in section 5 will be kept for a maximum of 5 years unless request for deletion received or legislation requires for it to be retained for longer
7. How and Where Do We Store Your Data?
7.1 We only keep your personal data for as long as We need to in order to use it as described above in section 6, and/or for as long as We have your permission to keep it.
7.2 Some or all of your data may be stored outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). You are deemed to accept and agree to this by using Our Site and submitting information to Us. If We do store data outside the EEA, we will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the GDPR including
7.3 Data security is very important to Us, and to protect your data We have taken suitable measures to safeguard and secure data collected through Our Site.
7.4 Unity4 prides itself on the sophistication of its data security systems, networks and procedures. In particular all databases maintained by Unity4 are protected by secure network links, which are complemented by firewalls, hardware and software encryption, password protection, virus protection, internal quality procedures and are routinely tested.
Your information is only accessible by staff and contractors who are bound by appropriate policies and procedures to protect your information.
8. Do We Share Your Data?
8.1 Subject to section 8.2, We will not share any of your data with any third parties for any purposes.
8.2 In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal obligations, a court order, or a governmental authority.
9. What Happens If Our Business Changes Hands?
9.2 In the event that any of your data is to be transferred in such a manner, you will be contacted in advance and informed of the changes.
10.How Can You Control Your Data?
10.1 In addition to your rights under the GDPR, set out in section 4, when you submit personal data via Our Site, you may be given options to restrict Our use of your data.
10.2 You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
11.Your Right to Withhold Information
You may access certain areas of Our Site without providing any data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.
12.How Can You Access Your Data?
You have the right to ask for a copy of any of your personal data held by Us (where such data is held). Under the GDPR, no fee is payable and We will provide any and all information in response to your request free of charge. Please contact Us for more details at email@example.com or using the contact details below in section 13.