PRIVACY POLICY

EFFECTIVE: 02 APRIL 2024

Legal Information

We are required to inform you of the legal basis of our processing of your personal data, which are described in the table below. If you have questions about the legal basis of how we process your personal data, contact us.

Processing purpose (click link for details)

To operate the Site

We use your data for our legitimate interest.

To communicate with you

To create anonymous data

For compliance, fraud prevention and safety

For a description of the activities that constitute our legitimate interest. We consider and balance any potential impact on you and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

To provide a requested service

Processing is necessary to perform the terms, conditions or contract governing our provision of the requested service or to take steps that you request prior to requesting the service. If we are unable to process your personal data, we may not be able to provide you with the requested service.

To comply with law

Processing is necessary to comply with our legal obligations.

With your consent

Processing is based on your consent. Where we rely on your consent you have the right to withdraw it anytime in the manner indicated when we requested your consent or by contacting us.

Personal Data We Collect

We collect your personal data as follows:
Personal Data You Give Us. This includes personal data you may provide when you:

• register for an account on the Site, such as a username or password;
• complete forms or surveys or use interactive features of our Site, including your‎ name, postal address, email address, telephone number or demographic information (such as your gender);
• contact us to report a problem with our site, contact customer support or otherwise correspond with us by phone, email or otherwise.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Information from Social Networking Sites. Our Site includes interfaces that allow you to connect with social networking sites (each a “SNS”). If you connect to a SNS through our Site you authorise us to access, use and store the information that you agreed the SNS could provide to us based on your settings on that SNS. We will access, use and store that information in accordance with this Notice. You can revoke our access to the information you provide in this way at any time by amending the appropriate settings from within your account settings on the applicable SNS.

Information Automatically Collected. We may automatically log information about you and your computer or mobile device when you access our Site. For example, we may log your computer or mobile device operating system name and version, manufacturer and model, browser type, browser language, screen resolution, the website you visited before browsing to our Site, pages you viewed, how long you spent on a page, access times and information about your use of and actions on our Site. We collect this information about you using cookies. Please refer to the Cookies and Similar Technologies section for more details.

Cookies and Similar Technologies

What are cookies?

We may collect information using “cookies.” Cookies are small data files stored on the hard drive of your computer or mobile device by a website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them) to provide you with a more personal and interactive experience on our Site.

We use two broad categories of cookies: (1) first-party cookies, served directly by us to your computer or mobile device, which we use to recognise your computer or mobile device when it revisits our Site; and (2) third party cookies, which are served by service providers on our Site, and can be used by such service providers to recognise your computer or mobile device when it visits other websites.

Cookies we use

Our Site uses the following types of cookies for the purposes set out below:

Disabling cookies

You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the “settings,” “help” “tools” or “edit” facility). Many browsers are set to accept cookies until you change your settings.

Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org.

If you do not accept our cookies, you may experience some inconvenience in your use of our Site. For example, we may not be able to recognise your computer or mobile device and you may need to log in every time you visit our Site.

Pixel tags

We may also use pixel tags (which are also known as web beacons and clear GIFs) on our Site to track the actions of users on our Site. Unlike cookies, which are stored on the hard drive of your computer or mobile device by a website, pixel tags are embedded invisibly on webpages. Pixel tags measure the success of our marketing campaigns and compile statistics about usage of [the Site], so that we can manage our content more effectively. The information we collect using pixel tags is not linked to our users’ personal data.

Do Not Track Signals

Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not currently respond to do not track signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

How We Use Your Personal Data

To operate the Site

We use your personal data:

• to operate, maintain, and secure the Site;
• to study how the Site is used and to improve the Site and our other products and services;
• if you register for an account on the Site, to manage and communicate with you regarding your account, including by sending you Service announcements, technical notices, updates, security alerts, and support and administrative messages;
• to better understand your needs and interests, and personalise your experience with the Site;
• to administer promotional activities on the Site; and
• to respond to your requests, questions and feedback

To send marketing communications

If you request information from us or participate in our surveys, promotions or events, we or our group companies may send you marketing communications if permitted by law, but you will be able to opt out.

To create anonymous data

We may collect anonymous data, including aggregated or anonymous data derived from personal data of our users. We make personal data into anonymous data by excluding information that makes the data personally identifiable to you, and use that anonymous data for our lawful business purposes.

For security, compliance, fraud prevention and safety

We use your personal data as we believe necessary or appropriate to (a) implement and operate security measures designed to protect the Site and your personal data; (b) enforce the terms and conditions that govern the Service; (c) protect our rights, privacy, safety or property, and/or that of you or others; and (d) protect, investigate and deter against fraudulent, harmful, unauthorised, unethical or illegal activity.

To provide a requested service

If you participate in a promotion on the Site or request a service through the Site, we may request personal data that we need to facilitate your participation in the promotion or provide the requested service.

To comply with law

We use your personal data as we believe necessary or appropriate to comply with applicable laws, lawful requests and legal process, such as to respond to subpoenas or requests from government authorities.

With your consent

We will request your consent to use cookies and similar technologies as described in this Notice where required by law. Otherwise, we do not generally use personal data for purposes that that legally require your consent. If we request your consent to use your personal data, you have the right to withdraw your consent any time in the manner indicated when we requested the consent or by contacting us.

To share with third parties

We share your personal data with third parties as described below.
For information about the legal bases of the purposes above, see the Legal Information section.

How We Share Your Personal Data

We may share your personal data as follows:

• Affiliates. We may disclose your personal data to our subsidiaries and corporate affiliates for purposes consistent with this Notice.
• Service Providers. We may employ third party companies and individuals to help us process your personal data as described in this Notice (such as hosting, data storage, website analytics and testing, email delivery and database management services).
• Professional advisors. We may disclose your personal data to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us for purposes consistent with this Notice.
• Compliance with Laws and Law Enforcement; Protection and Safety. Segment may disclose information about you to government or law enforcement officials or private parties as required by law, and disclose and use such information as we believe necessary or appropriate as described above to comply with law and for compliance, fraud prevention and safety.
• Business Transfers. We may sell, transfer or otherwise share some or all of its business or assets, including your personal data, in connection with a business deal (or potential business deal) such as a merger, consolidation, acquisition, reorganisation or sale of assets or in the event of bankruptcy.

Third Party Sites

Our Site may contain links to third-party websites and features. This Notice does not cover the privacy practices of such third parties. These third parties have their own privacy policies and we do not accept any responsibility or liability for their websites, features or policies. Please read their privacy policies before you submit any data to them.

International Data Transfer

Where we transfer personal data to a country that has not been approved by the European Commission as providing a level of data protection comparable to the EEA’s, we will transfer it subject to at least one of the following safeguards that allow us to conduct the transfer in accordance with the EEA’s data protection laws:

• Specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For details, see the European Commission’s website for model contracts for the transfer of personal data to third countries.
• For transfers to the US, recipients that participate in the Data Privacy Framework (DPF). For details, see the European Commission’s website on the EU-US Data Privacy Framework.

Please contact us for further information on the specific mechanism used by us when transferring your personal data out of the EEA.

Security

Although we take a number of technical and organisational measures to protect your personal data, no security measures can ensure complete security and we cannot guarantee the security of the Site or your personal data. If you have reason to believe that the Site or personal data you have shared with us is not secure, please contact us immediately.

Retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Our Notice on Children

Our Site is not directed to children under 16. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us. We will delete such information from our files as soon as reasonably practicable.

Sensitive Personal Data

We ask that you not send us, and you not disclose, any sensitive personal data (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Site or otherwise to us.

If you send or disclose any sensitive personal data to us when you use the Site, you must consent to our processing and use of such sensitive personal data in accordance with this Notice. If you do not consent to our processing and use of such sensitive personal data, you must not submit such user-generated content to our Site.

Your Rights

European data protection laws give you certain rights regarding your personal data. You may ask us to take the following actions in relation to your personal data that we hold:

• Opt-out. Stop sending you direct marketing communications. You may continue to receive administrative and other non-marketing emails.
• Access. Provide you with information about our use of your personal data and give you access to it.
• Correct. Update or correct inaccuracies in your personal data.
• Delete. Delete your personal data.
• Transfer. Transfer a machine-readable copy of your personal data to you or a third party of your choice.
• Restrict. Restrict the processing of your personal data.
• Object. Object to our reliance on our legitimate interests as the legal basis for our use of your personal data as described in the Legal Information section, where our use impacts your rights.

You can submit these requests by using our contact details in the contact us section below. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal data or response to your requests regarding your personal data, you may contact us or submit a complaint to the data protection regulator in your jurisdiction. You can find your data protection regulator here.

Changes to this Notice

We reserve the right to modify this Notice at any time. If we make material changes to this Notice you will be notified via e-mail (if you have an account linked to your email address) or another manner through the Site that we believe reasonably likely to reach you (which may include posting a new announcement or notice on the Site).

Any modifications to this Notice will be effective upon our posting of the modified Notice (or as otherwise indicated at the time of posting).

Contact Us

You can reach us at the contact details set out in the table below.