Effective from 1st August 2019
Last updated 03 March, 2020
Your privacy is important to us, and so is being transparent about how we collect, use and share personal information.
By being a client of Faethm and engaging us for our Services you consent to us using your Information and to receiving correspondence from us.
If you disagree with this policy or any changes to this policy, you will need to stop using the Services and deactivate your account(s).
What information we collect
We collect personal information (Information) when you provide it to us, when you use our Services, and when other sources provide it, including:
- When you engage us so that we may provide you with our Services;
- When you apply for employment with us or perform work at our direction;
- From our contractors and/ or business partners to provide you with our Services;
- when you communicate with us by phone, e-mail, or in writing, or when you participate in our surveys; and
- from someone authorised by you to provide us with your Information.
Our Services are intended for use by organisations. We do not collect or store any personal employee information, including employee name, date of birth, or home address, of our client organisations.
The Information we collect may include:
- Full name and contact details, including phone numbers, e-mail address and physical address;
- Banking details to facilitate payment of accounts;
- Employment Information such as that which appears on resumes, professional and other qualifications and memberships relevant to an individual’s employment relationship with us
- De-identified workforce data such as employee type (permanent, contract, casual), full time equivalent number, gender, birth year, job role and job level, organisational group hierarchy information (business group structure as defined by the client organisation), total compensation and bonus, location (street address, city, state, post code, country).
- Data related to your activity and usage of our Services via tracking technologies such as cookies, including about your computer, phone, tablet, or other devices you use to access the Services, device operating system, browser type, IP address, URLs of referring/exit pages.
How we use information we collect
How we use the Information we collect depends in part on which Services you use and how you use them. For example, we use Google Analytics and newrelic cookies and similar technologies to help us understand how visitors arrive at and browse our website and Platform, and identify areas for improvement such as navigation, user experience, and marketing campaigns.
We may use the Information for the following purposes:
- to provide you with news and information about our products and services such as new features, survey requests, newsletters;
- to send marketing, educational and promotional material that we believe you may be interested in;
- to manage and enhance our products and services. We are always looking for ways to make our Services smarter, faster, secure, integrated, and useful to you.
- to communicate with you including by email, post or telephone. We use your contact information to send communications via email and within the Services, including confirming your subscription and account usage levels, reminding you of subscription expirations, providing customer support, and sending you technical notices, updates, security alerts, and administrative messages. We send you email notifications when you interact with our Services, for example, when you raise a support request or support query. If an opt out is available, you will find that option within the communication itself or in your profile account settings.
- to verify your identity and authenticate you when you log in, provide customer support, and operate and maintain the Services.
- to monitor suspicious or fraudulent activity and to identify violations of our Service policies.
- as required or permitted by any law, worldwide, for example Privacy and Information Commissioner requests for breach notification.
- where you have given us consent to do so for a specific purpose not listed above, for example, we may publish testimonials or featured customer stories to promote the Services, with your permission.
How we share information we collect
Faethm builds platforms that help our clients with technology and workforce development, automation, augmentation and business intelligence through predictive scenario modelling. This means sharing information through the Services and with certain third parties. We share Information we collect in the ways discussed below, but we are not in the business of selling Information to advertisers or other third parties.
When you use the Services, we share certain Information:
- with authorised Faethm staff or third parties who are involved in the purposes outlined above. This includes international transfers within Faethm offices (Australia, United Kingdom, United States (California)) and/ or third parties based internationally;
- We work with third party service providers to provide website and application development, hosting, maintenance, backup, storage, virtual infrastructure, payment processing, analysis and other services for us, which may require them to access or use Information. If a service provider needs to access this Information to perform services on our behalf, they do so under close instruction from us, including policies and procedures designed to protect your information.
- with authorised Faethm staff or third parties involved in an investigation of concerns that unlawful activity has been, is being, or may be engaged in; or
- as required or authorised by law.
When we share Information within and among Faethm Offices and third parties, we make use of standard contractual data protection clauses, which have been approved by the European Commission.
How we store and secure information we collect
All Information provided to us by our customers is in a de-identified format – that is, XXX
We deploy and continuously improve our security measures designed to protect against the loss, misuse and/or alteration of Information under our control including but not limited to:
- all staff and business partners sign up to confidentiality requirements in their employee, contractor, supplier or partner agreements;
- For our European customers, our subscription agreements apply the Standard Contractual Clauses (Processors) from the European Commission Decision 2010/87/EU of 5 February 2010
- We use industry standard technical and organisational measures to secure the Information we collect and store including encryption, advanced and up-to-date firewalls and other security monitoring technologies;
- access to the Information is based on the least privilege principle and restricted to staff, suppliers and business partners based on the need to carry out his/her role to provide you with our Services;
- regular back-ups are conducted of critical Information to support our Services and our application data is stored and replicated across data centres to support our platform-wide resiliency.
- subject to any legal requirements we will take reasonable steps to destroy or permanently de- identify Information if it is no longer needed for any purpose for which it was collected, in accordance with this policy.
How long we keep Information we collect depends on the type of information:
- We will either retain your information to help further development our Services, or delete or anonymise your information upon request or, if this is not possible (for example, because the information has been stored in backup archives), then we will securely store your information and isolate it from any further use until deletion is possible.
- We retain your account information for as long as your account is active and thereafter in case you decide to re-activate the Services. We also retain some of your information as necessary to comply with our legal obligations, to resolve disputes, to enforce our agreements, to support business operations, and to continue to develop and improve our Services. Where we retain information for Service improvement and development, we take steps to eliminate Information that directly identifies you, and we only use the information to uncover collective insights about the use of our Services, not to specifically analyse personal characteristics about individuals.
- If your account is deactivated or disabled, some Information (email address, name and encrypted password) that you have provided will remain in order to facilitate re-activation.
- If you have elected to receive marketing emails from us, we retain Information about your marketing preferences from the date you last expressed interest in our Services, such as when you last opened an email from us or ceased using your Faethm account. We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created.
How to access and control your information
By being a Faethm client and engaging us for our Services you consent to us using your Information and to receiving correspondence from us.
Our Services and related documentation give you the ability to access and update certain information about you from within the Service. For example, you can update your profile information within your profile settings.
If you no longer wish to use our Services, you or your Faethm Owner may be able to deactivate your account. If you can deactivate your own account, that setting is available to you in your account settings. Otherwise, please contact your Faethm Owner. If you are a Faethm Owner and are unable to deactivate an account through your administrator settings, please contact Faethm support.
Some browsers have incorporated "Do Not Track" (DNT) features that can send a signal to the websites you visit indicating you do not wish to be tracked. Our Services currently do not enable cookies where the browser DNT signal is received.
You may opt out of receiving promotional communications from us by using the unsubscribe link within each email, updating your email preferences within the Platform’s account settings menu, or by contacting support to be removed from our promotional email list or registration database.
Our Services are intended for use by organisations. Where the Services are made available to you through an organisation (e.g. your employer or Consultant), that organisation is the administrator of the Services (‘Faethm Owner’) and is responsible for the accounts and/or Services over which it has control. Where this is the case, please direct your data privacy questions to your Faethm Owner in the first instance, as your use of the Services is subject to that organisation's policies. We are not responsible for the privacy or security practices of an Faethm Owner’s organisation, which may be different than this policy.
If you have consented to our use of Information for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place. Where we are using Information because we or a third party (e.g. your employer) have a legitimate interest to do so, you have the right to object to that use though, in some cases, this may mean no longer using the Services. If you wish to revoke your consent for us to use the Information please contact your Faethm Owner in the first instance or deactivate your account(s).
Faethm Owners can:
- require you to reset your account password;
- restrict, suspend or terminate your access to the Services;
- change the email address associated with your account;
- access or change your information, including profile information;
- grant or restrict access (read, edit, export) to Information and Platform Views in the Services
You may have access to your Information at any time by sending a written request to firstname.lastname@example.org and we will endeavour to provide you with the Information as soon as possible. Please note that we may need to take steps to confirm your identity to ensure that it is actually you making the request for the Information.
Changes to this Policy
How to contact us
If you have questions or concerns about how your information is handled, please direct your enquiry to our Data Privacy Officer below.
Data Privacy Officer
c/o Faethm Pty Ltd
Level 27, One International Towers