A sub-category of Personal Information is sensitive information and data. For the purposes of this Policy, sensitive information and data includes information of a particularly sensitive nature, such as information relating to an individual’s health, racial or ethnic origins, political opinions, membership of a trade union or political association, religious beliefs or affiliations, philosophical beliefs, sexual preferences or criminal record.
1 WHAT PERSONAL INFORMATION DOES BETTER ONLINE COLLECT, FROM WHOM AND FOR WHAT PURPOSE?
Better Online will only collect Personal Information that is necessary for its functions and activities. It will only collect Personal Information by fair and lawful means. Better Online may collect and process personal information through a variety of means, including, as examples, access to Better Online sites or services, employment processes, or correspondence with Better Online representatives, through purchase of goods or services or in the course of an online services. Better Online collects and holds different categories of information depending on the services being provided and the jurisdiction in which those services are being provided. The following types of Personal Information may be collected:
a) Information about Better Online’s Contractors and Suppliers
Better Online collects, directly from our contractors and suppliers, Personal Information about them. This Personal Information includes their name and contact details which allows them to be contacted. For workplace health and safety reasons we may also collect from contractors certain Sensitive Information with consent; for example, medical information a contractor has provided us about any injuries he or she may currently suffer.
From third parties, we may also collect feedback and information relating to our contractors and suppliers’ performance of services for Better Online. This information is collected for the purposes of monitoring our contractors and suppliers’ performance of services and to ensure that we are able to provide the highest quality products and services to our customers.
b) Information about job applicants
Applicants for a position at Better Online will be asked to supply details relevant to the job application such as name, contact details, information contained in CVs, driver’s licence or passport. We may also collect from third parties identified as referees Personal Information relating to the applicant. This information is used for the purposes of determining suitability for the vacant role.
c) Information about customers and their employees and customers
Personal Information may be collected from customers such as name, contact details, bank account and credit card details.
All customer Personal Information collected by Better Online is used for our business functions and activities. These include:
- for billing purposes and order fulfilment;
- to contact customers about our provision of services;
- to maintain account details;
- to provide technical support e.g. account creation, password reset;
- to provide information on request about our products and services;
- to streamline and personalise customer experience while dealing with Better Online;
- to undertake customer satisfaction surveys and to tailor Better Online information, services or products in order to improve and enhance those services and products provided to our customers.
Better Online may also collect from its customers Personal Information relating to its employees and customers; for example, payroll information. This Personal Information is used so that we can facilitate provision of the services our customers have requested.
Occasionally, Better Online uses aggregated Personal Information derived from use of our products and services to provide Better Online with anonymous demographic and customer usage information. This information does not identify individuals. This anonymous, aggregated information is used to improve Better Online services and products.
2 QUALITY OF PERSONAL INFORMATION
Better Online will ensure, to the extent reasonably possible, that Personal Information collected, used or disclosed is accurate, up-to-date, complete and relevant. If Better Online becomes aware that any of the Personal Information it holds is inaccurate it will take prompt steps to update its records so that those records are correct.
3 DATA SECURITY
Better Online takes active measures to ensure the security of Personal Information it holds is protected from misuse, interference, loss and unauthorised access, modification or disclosure.
All Better Online ICT devices, storage and channels are subject to continuous monitoring, logging analysis and audit. Better Online may choose to contract a third party to perform those functions.
All Personal Information is stored at secure premises using good quality security protocols.
Better Online security systems are regularly reviewed and updated to maintain the integrity of the Better Online security posture
4 ACCESS AND CORRECTION OF PERSONAL INFORMATION
Subject to verification of identity, any Personal Information held about an individual may be accessed, updated or corrected by application to a Better Online Privacy Officer.
There is generally no fee for an individual to make a request or to be provided access to his or her Personal Information. However, depending on the complexity of the request a reasonable processing fee may be charged in some cases.
Better Online will endeavour to respond to access and correction of Personal Information within 15 business days after a written request is received by a Better Online Privacy Officer
5 DIRECT MARKETING
Better Online will only engage in direct marketing practices in accordance with the laws of the relevant country or jurisdiction. At any time an individual or organisation may contact Better Online to request that they no longer receive any marketing material or information from Better Online.
For email communications, Better Online also provides a simple opt-out (unsubscribe) mechanism that individuals can easily submit at any time.
If you feel at any stage we have incorrectly used your Personal Information for direct marketing, please contact us immediately.
6 DISCLOSURE AND RETENTION OF PERSONAL INFORMATION
As part of providing services to a customer, Better Online may disclose Personal Information to third party suppliers and contractors of services or retain and disclose Personal Information as authorised by law for example metadata.
Better Online may disclose some Personal Information to its affiliated entities in countries in which Better Online operates for the purposes of providing services to our customers, including technical support. Such disclosure is subject to the privacy laws applicable in the jurisdiction where that affiliated entity is located. A formal intragroup agreement is in place to ensure all Personal Information is properly protected at all times for transfers within the Better Online global group.
Better Online only retains Personal Information for as long as required by applicable law or as needed for our business functions and activities. If Personal Information is no longer needed it is then destroyed or disposed of in a secure manner.
7 WEBSITE BROWSING
Accessing Better Online’s websites will result in some information being logged including but not limited to the time of access, IP address and the pages that have been viewed or accessed.
Better Online’s websites may contain links to external websites. Better Online is not responsible for the content or privacy policies that govern such external websites.
8 INTERNATIONAL DATA TRANSFERS
As a provider and user of IT Services including cloud services, Better Online retains Personal Information on servers that may be located in a number of overseas countries.
Better Online recognizes and respects the varying national laws and obligations and their impact on cross-border data transfers when transferring or processing Personal Information outside of the country of collection for the purposes identified above. Better Online will take all reasonable steps to ensure that no person or entity, breaches any relevant privacy and data protection laws using a variety of lawful data transfer mechanisms and contractual agreements for privacy and data protection.
When you access and use our website or services, we or a third party partner may serve you advertisements regarding goods and services that may be of interest to you (or in some cases, to users who our service providers deem to have characteristics similar to our customers) based on information relating to your access to and use of the Services and other websites. To do so, we or our service providers may place or recognize a unique cookie on your browser (alone or in conjunction with web beacons, pixel tags or other tracking technologies).
If you would like more information about this practice and to learn about your choices in connection with these practices, please visit http://optout.aboutads.info/?c=2#!/, http://preferences-mgr.truste.com, http://optout.networkadvertising.org/?c=1#!/ and http://www.aboutads.info/. If you are located in the European Union click here.
You may set your web browser to restrict or to entirely block cookies, to configure cookie notification settings and/or to delete cookies already present on the browser or device. Information on how to do this should be provided in your web browser’s help/reference section, removing cookies may prevent in customers using certain portions of the Applications, depending on how the browser settings are configured.
- Facebook Custom Audiences to deliver advertisements to Website Visitors on Facebook based on email addresses that we have collected. You may learn more about Facebook Custom Audiences by visiting https://www.facebook.com/ including how to opt-out of receiving advertisements from Better Online based on your email address.
- Third party analytics providers, including Google, Mouseflow and others, to collect information about your use of the Services and enable us to improve how the Services work. The information allows us to see the overall patterns of usage on the Services, helps us record any difficulties you have with the Services, shows us whether our advertising is effective or not, and allows us to use responses to advertisements to optimize advertisement performance.
- Mouseflow which collects information related to mouse clicks, mouse movements, scroll behaviour, and/or keystroke activity, but it does not collect personally identifiable information on our behalf or track users’ browsing habits across other websites that do not use Mouseflow. You can learn more about Mouseflow’s practices by visiting http://mouseflow.com/privacy.
- We also may use information associated with Visitor social media accounts, such as demographic and other information about an individual’s title, industry or organization, to improve our marketing efforts if that individual connects those social media accounts to a Website profile.
To learn more about Google’s practices or opt-out options go to https://policies.google.com/privacy/partners and opt-out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.
10 PRIVACY ISSUES
Any questions about this Policy or to raise any issues about privacy within Better Online should be directed to a Better Online Privacy Officer.
Email: privacy [at] better.online
Due to the nature of the services that Better Online provides, in most situations it will be impracticable for an individual to deal with us on an anonymous basis. However, Better Online will consider requests on a case by case basis.
If you are not satisfied with Better Online’s response and the issue relates to a privacy concern or alleged breach by one of Better Online’s affiliates, you may take your complaint to the relevant government authority responsible for Privacy.
11 GDPR STATEMENT
The following definitions are used in this GDPR Statement:
Customer – the counterparty to a Service Agreement with Better Online who has received consent from EU Data Subjects to collect and process their Personal Information;
EU Data Subject – living individual residing in an European Union Member State, including the United Kingdom;
GDPR – Regulation (EU) 2016/679 of the European Parliament and Council, and all applicable data protection and privacy laws and regulations in any EU Member State or nation within the European Economic Area;
Legitimate Interest – the legal basis under GDPR for collection of Personal Information;
Service Agreement – any written contract, any written statement of work, or any other written binding agreement between Better Online and the Customer.
Legal Basis for Collection of Personal Information of EU Data Subjects
Better Online collects, uses, stores and transfers Personal Information to manage its relationship with its Customers, employees, business partners and other third parties (“covered individuals”) and better serve covered individuals by personalizing their experience and interaction with Better Online. Such processing is done in compliance with applicable laws, Service Agreements, including appropriate notice and consent.
EU Data Subject rights
- Request that we provide you with a copy of Personal Information that we collect and you have the right to be informed of the source of your Personal Information, the purpose of collection and legal basis, as well as the processing methods used by Better Online and to whom your Personal Information may be transferred.
- Request that we correct inaccurate Personal Information. We may seek to verify the accuracy of the Personal Information before correcting it.
- Request that we delete your Personal Information when it is no longer needed for the purpose under which it was collected or you withdraw your consent to use (subject to our legal obligations for retaining historic records).
- Ask us:
- To restrict your Personal Information, where the Personal Information is not accurate or unlawfully processed, or it is no longer needed for the purpose under which it was collected. We will only continue to use your Personal Information where we have your consent or to protect the rights of covered individuals or exercise legal rights.
- To provide your Personal Information to you in a readable format or have it transferred to another party for automated processing under consent or Service Agreement.
- Object to any processing of your Personal Information which has our Legitimate Interests as its legal basis, if you believe your fundamental rights and freedoms outweigh our Legitimate Interests. You can also request that we change the manner in which we contact you for marking purposes or you can remove yourself from our marketing lists.
We may not always be able to fully address your request, for example if it would impact the duty of confidentiality we owe to others, or if we are legally required to retain Personal Information, or we are entitled to deal with the request in a different way.
How you can access, correct, update, restrict or delete your Personal Information
Processing and sub processing Personal Information on behalf of Customers
The details of the Personal Information that will be processed by Better Online on behalf of a Customer, including the duration, purpose and categories of Personal Information, will be set out in a Service Agreement with the Customer for authorisation to process Personal Information. Better Online will create and maintain records of the processing of the Personal Information. By signing the Service Agreement, the Customer authorises Better Online to process or to subcontract the processing of personal data to a third party, and confirms that consent has been obtained from the EU Data Subjects.
Personal Information Transfers
Personal Information from EU Data Subjects will only be transferred outside of the European Economic Area in accordance with the provisions and protections within the GDPR. Better Online uses a variety of lawful data transfer mechanisms for this purpose, including EU Standard Contractual Clauses.
Better Online has an intragroup agreement on the transfer and processing of Personal Information within the Datacom global group which has the EU Standard Contractual Clauses incorporated. This agreement allows Better Online to ensure that Personal Information, including Personal Information originating from the European Economic Area, which is transferred cross-border and processed by other Better Online entities, including those located outside the European Economic Area, is adequately protected in accordance with the GDPR.
Better Online does not knowingly collect information from children as defined by local law, and does not target its websites and services to children. We encourage parents and guardians to take an active role in their children’s online activities and interests.
Notification of Changes
We may update this GDPR Statement from time to time. If we do, we will post the revised version, with an updated revision date.
Questions and Better Online Representative