Privacy

Effective from 1st December 2020

Last updated 07 December, 2020

1. INTRODUCTION

Faethm respects your right to privacy. This privacy notice explains who we are, how we collect, share, use, and protect personal information about you, and how you can exercise your privacy rights.

Faethm Holdings Pty Ltd is a private limited company registered in Australia under ABN 48611627368 and has its main office at Level 3, 14 Martin Place Sydney NSW 2000. It has subsidiaries in Australia, the United Kingdom and the USA. For ease of reference all Faethm legal entities will be collectively referred to throughout this Privacy Policy as “Faethm”.

This Privacy Policy applies to all personal information collected by Faethm legal entities and covers all users of our websites and products (the “Services”), our employees and our customers.

Depending on the context of your personal information, Faethm may be a data controller or data processor under this policy.

Faethm reserves the right to make changes periodically to this Privacy Policy at our sole discretion. These changes will always be made available at www.faethm.ai.

2. THE TYPES OF PERSONAL INFORMATION WE COLLECT

Where appropriate we currently collect and process the following information:

Your contact details i.e. your:

i. Name

ii. Employer details

iii. Email address

iv. Telephone number

v. Country of location

vi. Social media ID

Details of your interactions with us, such as:

i. We collect details of enquiries and comments you make in the web pages you visit or when you contact us by email, telephone or in person

ii. Data related to your activity and usage of our Services including 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.

Additionally, for employment purposes:

i. Gender

ii. Date of birth

iii. Social security (or equivalent) details incl. remuneration, pension, and tax details

iv. Bank details

v. Passport/Identity card & additionally visa details where applicable

vi. Drivers’ licence

vii. Postal address

viii. Next of Kin details

ix. Health information

x. Employment history, qualifications, memberships, training records. performance evaluations, psychometric tests, attendance records, references, and Employment ID

Customer supplied data

De-identified workforce records 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), remuneration related information and company location (street address, city, state, post code, country).

3. WHEN WE COLLECT PERSONAL INFORMATION

We collect personal information:

i. when you engage with us so that we may provide you with our Services.

ii. from our contractors and/ or business partners to provide you with our Services.

iii. when you communicate with us by phone, e-mail, or in writing, or when you participate in our surveys.

iv. when you access our website and accept cookies;

v. from someone authorised by you to provide us with your Information; or

vi. when you apply for employment with us or perform work at our direction.

4. HOW WE USE PERSONAL INFORMATION

Most of the personal information we process is provided to us directly by you for one of the following reasons:

i. to operate, deliver and enhance our business and Services. This is done based on legitimate interests so that we may provide you with the best possible customer experience and you may derive the intended benefit from our Services.

ii. provide you with news and information about our Services such as new features, survey requests, newsletters. This is done based on your consent.

iii. to send marketing, educational, and promotional material. This is done based on your consent.

iv. to process payments and prevent fraudulent transactions. This is done based on legitimate interests to protect all parties from fraud.

v. to monitor suspicious or fraudulent activity and to identify violations of our Service policies. This is done based on legitimate interests to protect all parties.

vi. to abide by law enforcement requests. This is done based on compliance with legal obligations.

vii. to exercise our legal rights where necessary e.g. litigation, financial collections. This is done based on a legitimate need to defend our interests.

viii. to fulfil our obligations to employees, contractors, temporary, short-term, and similar workers. This is done based on fulfilling contractual obligations.

5. WITH WHOM WE SHARE PERSONAL INFORMATION

Faethm does not sell or share information with third parties for marketing purposes. When using personal information as described above we may share it with the following types of organisation where it is deemed necessary and only then in a proportionate manner.

i. Hosting, maintenance, backup, storage, and virtual infrastructure companies

ii. Application development companies

iii. Social media companies

iv. Customer Relationship Management application providers

v. Financial service providers

vi. Regulatory authorities

vii. Estate Services

viii. Online webinar providers

ix. Insurers

x. Travel service providers

xi. Recruitment industry organisations including assessment companies

When you use a service from one of our chosen partners, your data will be collected and used by them under the terms of their own separate privacy policies which you are encouraged to read.

Where data is transferred across jurisdictions with differing privacy laws then this will be safeguarded using Standard Contractual Clauses (Processors) from the European Commission Decision 2010/87/EU of 5 February 2010 or Adequacy Decisions as appropriate.

6. HOW WE STORE AND SECURE YOUR PERSONAL INFORMATION

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:

i. 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.

ii. 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.

iii. 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.

iv. 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.

v. All staff and business partners sign up to confidentiality requirements as part of their documented working arrangements with Faethm.

7. HOW LONG WE KEEP PERSONAL INFORMATION

We keep your personal information only for as long as it is required:

i. to fulfil the relevant purposes described in this Privacy Policy.

ii. as may be required by law (including for tax and accounting purposes).

iii. as required to fulfil our obligations as an employer to relevant staff, contractors, temporary, short-term, and similar workers.

iv. or as otherwise communicated to you.

8. YOUR DATA PROTECTION RIGHTS

Under data protection law, you have rights including:

i. your right of access - You have the right to ask us for copies of your personal information.

ii. your right to rectification - You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.

iii. your right to erasure - You have the right to ask us to erase your personal information in certain circumstances.

iv. your right to restriction of processing - You have the right to ask us to restrict the processing of your personal information in certain circumstances.

v. your right to object to processing - You have the right to object to the processing of your personal information in certain circumstances.

vi. your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.

Please contact us at compliance@faethm.ai if you wish to make a request.

9. HOW TO COMPLAIN

If you have any concerns about our use of your personal information, you can make a complaint to us at compliance@faethm.ai

You can also complain to the ICO if you are unhappy with how we have used your data at https://www.ico.org.uk