1. About This Policy
Enboard.Me Pty Ltd (ACN 606 680 602), together with its related bodies corporate Enboarder Ltd in the United Kingdom and Enboarder LLC in the United States, (collectively, Enboarder, we, us our) respect the importance of protecting your privacy.
Enboarder offers our employer clients an onboarding and engagement platform available through its website and accessible on any device. Using our platform, our employer clients build customised workflows on their own to create engaging experiences with their employees.
2. What Information Do We Collect?
“Personal information” or “personal data” is any information about you, from which you can be identified. Our Processing of your personal information will depend on our relationship with you, the circumstances of collection and the types of products and services you request from us. We may collect additional personal information from you from time to time.
We may collect personal information in the following circumstances:
Through your use of our services – When you register an account with us, access and use our services, contact our support team, make an enquiry, respond to our surveys or provide feedback or comments or otherwise interact with us or provide your personal information to us. Personal information may include your name, address, email address, telephone number and employment related information. If you are any employee of our employer client, personal information we collect about you will depend on the workflows created by your employer.
Sensitive information – We generally do not collect sensitive information about you, unless you provide it to us voluntarily. For example, you may provide sensitive information such as racial or ethnic origin, sexual orientation, health information or religious or philosophical beliefs in a workflow that your employer has created. You consent to us collecting sensitive information which you provide to us voluntarily. If we need to collect any sensitive information for a specific purpose, we will ask for your consent.
Employment – If you are an Enboarder employee or a prospective employee of Enboarder, we may collect personal information directly from you or indirectly from recruitment agencies, your referees or past employers as part of the recruitment process and human resources management. This may include name, address, phone number, employment history and experience and other employment related information. If you are an employee, we may also collect sensitive information about you and you consent to us collecting this information. This may include health information or racial or ethnic origin.
3. What If You Don’t Want To Give Us Your Information?
You don’t have to give us all the information we request. You may engage with us anonymously or using a pseudonym if it is feasible to do so. For example, if you wish to give feedback without requiring a response from us, you won’t need to provide a full name or email address. However, if you do not provide us with some or all of the personal information required, we may not be able to provide you with the products and services or information you request, to the requested standard or at all, and you may also miss out on receiving valuable information about us and our products and services.
4. Our Website And Cookies
We collect general information from your device when you use our website and services. This might include your geo-location, IP address, device identifier, the browser and operating system you are using, and details of website that IP address has come from, the pages accessed on our website and the next website visited.
Cookies are small data files placed on your computer that allows our website to “remember you” when you return to our website. The types of cookies that we use are classified, depending on their function and intended purpose, such as: necessary cookies, performance cookies, functional or preference cookies, and cookies for marketing purposes.
- Necessary cookies: These cookies make a website usable by enabling basic functions like page navigation and access to secure areas of the website. Without these cookies, the website cannot function properly.
- Performance cookies: These cookies collect information about how you use our website to help us understand how visitors interact with our website. Information collected includes the Internet browser and operating systems used, the domain name of the website previously visited, the number of visits, average duration of visit, and pages viewed. These cookies do not collect information that personally identifies you and only collects aggregated and anonymous information.
- Functional or Preference cookies: These cookies allow the website to remember choices you make such as your username or ID, language preference, or the area or region you are in to provide you with enhanced, more personalised features. These cookies can also be used to remember changes you have made to text size, fonts, and other customisable parts of web pages. The information these cookies collect may be anonymised, and they cannot track your browsing activity on other websites
- Cookies for Marketing purposes: These cookies track browsing habits and are used to deliver targeted advertising. They are also used to limit the number of times you see an ad and to measure the effectiveness of advertising campaigns. They remember that you have visited a website and this information may be shared with other organisations, such as advertisers.
5. Why Do We Process Your Information?
We may Process your personal information so that we can perform our functions and activities such as to provide our onboarding services and to evaluate and improve our website and services. We will not use or disclose sensitive information without your consent.
We may Process your personal information for the following purposes:
- Provide and administer our services and enable you (employer clients and employees) to access and use our services;
- Provide support services and troubleshooting, including through investigating and responding to your enquiries, feedback and comments;
- Provide information and communications relevant to your use of our services, including support and administrative messages, reminders, technical notices, updates, security alerts, and information requested by you;
- Operate, protect, improve and optimise our website, services and your experience; Conduct marketing and advertising activities including displaying content on our website and serving display advertising on third party websites;
- Conduct marketing and advertising activities including displaying content on our website and serving display advertising on third party websites;
- Provide information and communications marketing our products and services, including through distributing newsletters and other communication on information about us and our related services;
- Perform data analyses, research and generate client insights which may include aggregating information collected from our clients and other clients to produce general trends and statistics about our products and services;
- Manage and carry out our business and operational functions, including HR management, business decisions and technical operations;
- Maintain our records and comply with our legal obligations, resolve any disputes that we may have with any of our clients, and enforce our agreements with third parties; and
- For any other purpose disclosed at the time the information is collected or to which you consent.
We must be able to identify the legal basis on which we Process your information. These are if Processing is:
- Necessary to fulfil a contract, such as terms that we have in place with you to provide our services, for the purposes set out in points a), b), c) and j) above;
- Necessary for our legitimate interests, such as the Processing for the purposes set out in points d), e), f), g), h) and j) above, unless consent is required under applicable law;
- With your consent, such as the Processing for the purposes set out in points f) and j) above, where such consent is required under applicable law;
- Necessary for compliance with a legal obligation to which we are subject, such as the Processing for the purposes set out in point i) above; and
- Any other applicable legal grounds for Processing.
6. Direct Marketing
If you are our client, we may, from time to time, send direct marketing communications to you about our activities and services and other material that we consider you would find interesting or useful. If you do not wish to receive such direct marketing communications, you can always opt out. If you are receiving email communications from us, there will be a mechanism to opt out contained in each of those emails. To stop receiving other communications from us, you can contact us via any of the channels listed below.
If you choose to opt out of all direct marketing communications, please note that Enboarder may still contact you and your employees for other reasonable purposes, including information that Enboarder is legally required to send, notifications of changes to Enboarder services or policies and information regarding the use, rights, benefits or obligations of users of our services.
7. To Whom Do We Disclose Your Personal Information?
We may disclose personal information in accordance with the applicable law and for the purposes described above, including:
- To your employer who is our client;
- To our related bodies corporate;
- To anyone to whom our assets or businesses (or any part of them) are transferred;
- When we may be required, authorised or permitted by law, including to government agencies, regulatory bodies and law enforcement agencies; and
- To any other third party where you have provided your consent.
We may also disclose personal information to third parties such as our contractors, suppliers, agents and service providers who help us deliver, administer and support our functions and activities, including:
- Hosting our servers and website;
- Delivering marketing and digital marketing services;
- Conducting research, surveys and data analysis;
- Providing IT services;
- Data processing, storage and back-up; and
- Processing payments.
8. International Disclosures
Some of the third parties we disclose your personal information to may be based or have servers located overseas in various countries, including USA. Before we disclose your information to our overseas recipients, we will take all reasonable steps to ensure that your information is only Processed for authorised purposes and adequately protected using the appropriate technical, organisational, contractual or other lawful means. You consent to us disclosing your personal information to overseas recipients on this basis.
9. Non-Australian Resident Data
Enboarder is based in Australia, the USA and the UK and your information is stored in servers located in Australia, the USA and Germany respectively. Please be aware that as Australia is where our central operations are located, any information you provide us, may be transferred from your country of origin to Australia. Your decision to provide such information to us or allow us to collect such information constitutes your consent to this information transfer.
Enboarder takes the security of your personal information seriously and we implement a range of physical, administrative, personnel and technical measures to safeguard your information from misuse, interference and loss, as well as unauthorised access, modification or disclosure, including electronic and physical access restrictions to files containing personal information and ensuring encryption of personal information sent and received.
11. How Long Do We Keep Your Information?
Your personal information will be retained for as long is reasonably necessary for the purposes listed above or as required by applicable law. If we no longer need your personal information, we will ensure that it is either destroyed or de-identified. We may keep the de-identified form of your personal information for statistical purposes without time limits, to the extent permitted by law.
13. Accessing Or Correcting Your Personal Information
We will take all reasonable steps to ensure that the personal information we collect, use or disclose is accurate, complete and up-to-date, and we will try to confirm your details through our communications with you and promptly add updated or new personal information to existing records when we are advised. However, we rely on the accuracy of personal information as provided to us both directly and indirectly. We encourage all users to regularly review and update their personal information. If any of your details change, please notify us as soon as you can or log into your online profile to update it. If you believe we are holding information about you that is inaccurate, incomplete, irrelevant or misleading, you can ask us to correct it, or delete it altogether.
If you would like to access personal information that we hold about you, or ask us to update, correct or delete it, you can do so by contacting us in writing via the contact details set out below and verifying your identity. We will do our best to respond to your request within 30 days. We will only refuse access in exceptional circumstances, and if this is the case, we will advise you of our reasons for doing so. We may charge a fee for searching for, and providing access to, your information on a per request basis.
14. Rights Of Residents Of The European Economic Area And The UK
Under the applicable data protection law, residents of the European Economic Area and the UK have additional rights.
In accordance with applicable data protection law:
- You are entitled to know what personal information we hold about you and you may ask us to make any necessary changes to ensure that it is accurate, up to date and complete;
- You may request for us to restrict or object to the processing of personal information, including automated processing and profiling;
- You may request that we delete personal information we hold about you, unless there is a lawful reason for us not to do so such as if retention is necessary for us to comply with our legal obligations; and
- In some circumstances, you may request that we provide the personal information (that you have provided to us) to you in a structured, commonly used and machine-readable format and have it transferred to another provider of the same or similar services.
If you wish to exercise any of your rights, you can do so by contacting us in writing and verifying your identity. We will do our best to respond to your request within 30 days.
We will only refuse your request in exceptional circumstances and in accordance with the applicable law, and if this is the case, we will advise you of our reasons for doing so.
In some countries, we may charge a fee for searching for, and providing you with details of the information we hold about you.
15. Making A Complaint
We take your complaints seriously and we will attempt to resolve any issues quickly and fairly. If you think that an act or practice of Enboarder has interfered with your privacy in relation to your personal information, you can contact us using the details below. Please include your name, email address, telephone number and clearly describe your complaint.
If we cannot resolve your complaint to a satisfactory standard, you are entitled to lodge your complaint:
- With the Office of the Australian Information Commissioner at: http://www.oaic.gov.au; or
- For residents of the European Economic Area and the UK, with the relevant supervisory authority. A list of EU national data protection authorities can be found on the European Commission website at: https://ec.europa.eu/info/strategy/justice-and-fundamental-rights/data-protection_en.
16. Contact Us
Enboard.Me Pty Ltd
Level 4, 74 York Street
Sydney NSW 2000
38 Dale Road
Purley CR8 2EE England
251 Little Falls Drive
New Castle County