- 1. What Information Do We Process and Collect About You
- 2. How Do We Use Your Information
- 3. How Do We Protect Your Information
- 4. Your Rights as a Data Subject
- 5. How You Can Opt Out of Processing for Marketing Purposes
- 6. How We Store Your Information
- 7. Our Third Party Data Processors
The Fournaise Marketing Group Ltd and our corporate group including those companies stated at section 14 ("We" or “Us” or “Our”) are committed to protecting and respecting Your privacy.
- All public content, images, audio or video material, text, information, data, software, executable code and pages available at www.fournaisegroup.com and/or other Fournaise- related URLs We may own and its look and feel, graphic user interface and functionality;
- the software (including any relevant algorithms) (in object code and source code format) that powers the Fournaise Website and that is used to provide the content on it (including any error corrections, updates, upgrades, modifications and enhancements to it made by Us); and
- all the private Fournaise account & service management applications (and their related modules, content, images, data and pages) accessible to Fournaise users (“Fournaise METB Solutions”). The Fournaise METB Solutions are located at URLs in the format *.fournaisegroup.com. They include the Fournaise ROI Management Centre located at roicentre.fournaisegroup.com (“FROI”), the Fournaise Account Login located at youraccount.fournaisegroup.com (“FLOG”) and the Fournaise Marketing Performance Institute located at fmpi.fournaisegroup.com (“FMPI”).
As is required under applicable law, the relevant data controller and data protection officer (“DPO”) (who is also Our nominated representative for data protection matters) are identified at section 9 and section 10 below respectively.
1. WHAT INFORMATION DO WE COLLECT AND PROCESS ABOUT YOU
So what is personal data? Personal data simply means any information about a living person which can be connected to that person by any means. The terms “personal data” and “personal information” are used interchangeably in this policy.
We use personal data to provide services and/or the general use of the Fournaise Website to You, and for Our legitimate business operations. If You choose not to provide the information We request from You, We may not from a technical and/or practical perspective be able to provide You with the services You require and We would notify You of that if relevant.
We describe and explain below the main types of personal information We receive, track and collect
and why We process such personal information.
Information You give to Us
Registration Information is the information You provide to us when You register for, sign up for and/or purchase any Fournaise Services or otherwise complete forms or input other personal information on Our Fournaise Website. This may include information without limitation You provide Us to:
- create an account
- become a user or subscriber
- Sign up for a free trial
- become an advertiser
- post comments
- receive a newsletter
- enter a game or competition
- search for services or other information on Our site
- correspond with us by phone, e-mail or otherwise
Registration Information may include, for example only, Your name, gender (if necessary), postal address (if necessary), email address, phone number(s), date of birth, financial and credit card information and, if necessary, personal description and photograph. We would only seek personal data from You which was necessary for the proper purposes and/or Your use of the service provided or any other legitimate purpose We wish to promote, such as gender inclusive services for example.
Public Information and Posts include comments or content that You post to the online Fournaise Website and the information about You that comes with those posts. This may include Your name, username, comments, likes, tweets, status, profile information and picture(s). Public Information and Posts are available to everyone who views Our Fournaise Website and may be displayed in search results on external search engines, even after You cancel Your account with Us or stop using Our Fournaise Services and/or Fournaise Website and it is likely to be outside of Our control to change that. For the avoidance of doubt, We would only be able to remove or erase personal data to the extent that it is within Our control to do so.
Information from third party Social Media means personal data provided to Us if You access or log-in to any Fournaise Services and/or the Fournaise Website through a third party social media service or connect any Fournaise Services to Your social media profile. This may include:
- Your user name for that service;
- any information or content You have permitted the social media service to share with Us (such as Your profile picture(s), email address, followers or friends lists); and
- any other information You have made public (including other posts You make using Your social media profile).
Information We collect about You
Activity Information – cookies and other technologies. When You visit Our Fournaise Website (including to access, log into and/or use Our Fournaise Services or to just generally use Our site) We may collect information about Your visit. For example, in order to connect You to the Fournaise Services, Our servers receive and record information about Your computer, device, and browser, which may include Your Internet Protocol (IP) address used to connect Your computer to the Internet (and which can be used to identify You and so IP addresses are considered by Us to be personal data), browser type and version, browser plug-in types and versions, operating system and platform, time zone setting, and other software or hardware information. If You access the Fournaise Services from a mobile or other device, We may collect a unique device identifier assigned to that device, geolocation data, or other transactional information from that device.
Recordings. We hold Our standards of service and safety with utmost importance and therefore We may monitor Your interactions with Our representatives, workers and employees (“Workforce”) using audio, chat, email, interaction and visual recording technology such as recording Your telephone and video calls with Our Workforce and recording Your image and conversations.
Information We receive from other sources
We may supplement the information We collect about You with information from other sources. This may include information from publicly available sources such as other published content and data providers (although We would only collect and use such personal data if Our intended use was consistent with the purposes set out above or the purposes for which the personal data was made public and/or You had given consent), as well as information from Our business partners (for purposes such as IT delivery, payment services, advertising and analytics, search information providers, other professional advisers) or related and affiliated companies in Australia, the UK or other countries.
We may also collect personal information about Our suppliers and individuals employed by Our suppliers (including service and content providers), contractors, dealers, related companies, agents and corporate customers. We will explain why We are collecting that information and how We will use it either in this policy or in correspondence with such suppliers.
2. How Do We Use Your Information
The lawful bases for which We process the information We collect about You are (1) to provide Fournaise Services to You and (2) the performance of Our contract. Otherwise, the lawful bases for processing Your personal information are either (1) Your consent, where consent is explicitly required and provided as set out in this policy and any other relevant forms or documents You complete, or (2) some other basis on which We lawfully process Your data in this policy or related documents. Also, please note that save where otherwise notified to You, Your personal data is required for contractual rather than statutory purposes.
Information You give to Us
We will use this information:
- to carry out Our obligations arising from any contracts entered into between You and Us and to provide You with the information, products and services that You request from Us and to fulfill administrative functions associated with these services (for example billing, credit and account management);
- if relevant, to check (with credit reference agencies) Your creditworthiness before entering into a contract with You;
- to provide You with information about other goods and services We offer that are similar to those that You have already purchased or enquired about;
- to provide You, or permit selected third parties to provide You, with information about goods or services We feel may interest You. If You are an existing customer, We will only contact You by electronic and/or traditional means with information about goods and services similar to those which were the subject of a previous sale or negotiations of a sale to You or which You otherwise consent to. If You are a new customer, and where We permit selected third parties to use Your data, We (or they) will contact You by electronic and/or standard means only if You have consented to this. If You do not want Us to use Your data in this way, or to pass Your details on to third parties for marketing purposes, please do not tick the relevant box situated on the form on which We collect Your data or process any verification emails You might receive;
- to allow You to comment on content, and participate in games, competitions, or rewards programs;
- to notify You about changes to Our service;
- to provide You with customer support; and
- to respond to Your enquiries.
We will also use Your personal information for the following specific purposes:
Email newsletter. If You choose to join Our email newsletter, the email address that You submit to Us will be stored in Our internal databases (located in and managed by Our Fournaise METB Solutions in secure servers, as described in section 6), and/or may be forwarded to a third party data processor (“3DP”) who provides Us with email marketing services. Your email address will remain within the 3DP’s database for as long as We continue to use the 3DP’s services for email marketing or until You specifically request removal from the list. You can do this by unsubscribing using the unsubscribe links contained in any email newsletters that We send You or by sending Us an email at firstname.lastname@example.org. When requesting removal via email, please send Your email to Us using the email account that is subscribed to the mailing list. For Your information You will receive periodic (approximately three to four times a year) newsletter-style emails from Us;
Contact forms and email links. Should You choose to contact Us using the contact forms on Our Fournaise Website or an email link like email@example.com, the data that You supply will be stored by Our Fournaise Website and/or passed to / be processed by any of the third party data processors defined in section 7 below. In addition the data may be collated into an email and sent to us directly.
Information We collect about You
We will use this information:
- to administer Our Fournaise Website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- to ensure that content from Our Fournaise Website is presented in the most effective manner for You and for Your computer;
- as part of Our efforts to keep Our Fournaise Website safe and secure and deter any criminal or other harmful acts by Our Workforce or customers or users and to keep such persons safe (and so We may record Your calls, chats, video calls and other interactions with Our Workforce);
- to measure and improve Fournaise Services and their individual features (and so We may
record Your calls, chats, video calls and other interactions with Our Workforce);
- to improve Your experience by delivering content (including editorial, marketing and advertising) We think You will find relevant and interesting, subject to the provisos set out above in relation to marketing; and
- to seek to prevent criminal or other harmful acts by Our Workforce or customers or users and to keep such persons safe, and to satisfy any relevant internal governance, mitigation, and/or compliance obligations, and/or to satisfy regulatory obligations (and so We may record Your conversations and interactions by the use of video, audio, chat and/or interaction recording technology).
The recorded calls, videos, chats and other interactions:
- will be securely stored in Our Secure Servers (see section 6) and/or in Our secure storage accounts with third party storage specialists such as Amazon Web Services (“AWS”) and/or Carbonite;
- will be securely accessed internally from time to time by Our selected and authorised staff, workers and/or employees only (“Selected Staff”), for compliance, fact compliance, risk mitigation, training, coaching, dispute resolution, unauthorised use detection, safety, quality control and governance purposes; and
- will be accessed by a limited, small number of Selected Staff. These Selected Staff belong to Our technology and operations teams.
To confirm, We do not engage in covert monitoring of customers or users in respect of audio, chat or visual recordings and We will do Our best to ensure that Our ongoing use of any such recording is reviewed on a regular basis to ensure that its use remains necessary and appropriate, and that any such recording system is continuing to address the needs that justified its introduction.
We use the information We collect about You for the following additional purposes:
Research and data analysis. We may use Your information for research and data analysis to improve Our Fournaise Services. We may do this research or engage a service provider to do this.
To allow service and content providers to assist Us in providing and managing the Fournaise Services. We may make Your information available to certain third party service and content providers who help Us manage or provide the Fournaise Services and/or Fournaise Website or who provide Us with related services. This might include providers of cloud services, website hosting service providers, debt collection service providers and direct marketing service providers. These third parties may be located in a range of different countries including the United States of America (USA), the United Kingdom, Australia, France and Singapore. Our agreements with these third party providers require them not to use Your information except for the lawful purpose(s) they are engaged by Us and to the minimum extent necessary for such purpose(s).. Also, countries signed up to the EU’s General Data Protection Regulation (GDPR), which includes the UK and France, are deemed to have adequate law in place to protect Your data, and whenever possible We do Our best to work with companies in the USA and other countries who have signed up to the EU-US Privacy Shield. Where We transfer Your data outside of those EU countries mentioned or to companies which have not signed up to the EU-US Privacy shield, then Your personal data may not be as well protected by the law of that jurisdiction as it would under the GDPR and notwithstanding such risks You explicitly consent to such transfer in any event to facilitate the provision of the Fournaise Services as set out in this policy and any related documents.
To deliver relevant advertisements and content. We and Our advertisers may use the information We collect about You to provide You with relevant advertisements and content when You use Fournaise Services. In Section 5, below, We provide information about how to choose what advertisements You may see when using Our Fournaise Services. You explicitly consent to Our use of automated decision making for marketing purposes and You may raise any concerns with Us and/or withdraw such consent by contacting Our DPO at the contact details provided in this policy.
For consumer insight analytics. We may combine information that We hold about You with information about You that We collect from other trusted businesses with whom You also have a relationship or from public sources, so long as Our collection and use is in line with the purposes such personal data was first published or collected. We and those trusted businesses do this in order to enable the development of consumer insights about You so that each of us can serve You better. This includes being able to better understand Your preferences and interests, personalise Your experience, enhance the products and services You receive, and to tell You about products and services. Where those insights are provided to others for their own marketing purposes, such insights do not contain any information that identifies You and so would not be Your personal data. We may also use third party service providers to undertake the process of creating these consumer insights.
To share with business partners. We may share Your information with business partners for the purposes of providing services related to the Fournaise Services or, where You have specifically agreed to it, so they can send You marketing communications.
To protect Our rights and the rights of others. We may share Your information with other third parties where We are lawfully entitled to do so. This includes when We have a reasonable basis to believe that sharing Your information is necessary to:
- protect the safety, privacy, and security of users of the Fournaise Services or members of the public;
- protect against fraud or for risk management purposes;
- comply with the law or legal process in any country; or
- respond to requests from public and government authorities.
To complete a merger or sale of assets. If We sell all or part of Our business or assets, We may disclose Your information to the party or parties involved in the sale transaction. We may also do this if We are involved in a merger or transfer of all or a material part of Our business. We may disclose Your information prior to the sale, transfer or merger so that the party or parties involved can consider the transaction and complete any due diligence. We will consider in each circumstance whether it is appropriate or not to anonymize or pseudonymise Your data. For an explanation of “pseudonymisation”, see section 6).
We may also remove certain information or alter the information We collect about You so You can no longer be identified from that information. We do this so that We can use it or disclose it to third parties for other purposes which will be set out to You at the relevant time.
3. HOW DO WE PROTECT YOUR INFORMATION
We use reasonable measures to safeguard the personal information We hold about You from loss, theft and unauthorised use, disclosure or modification, including:
- System security. We take reasonable steps to prevent unauthorised access to Our online and computerised systems by using measures such as firewalls, data encryption, virus detection methods, and password restricted access. Please see below at the section “How We store Your information” for more security information.
- Where We transfer Your personal data to jurisdictions outside of Your jurisdiction We will do Our best to seek whenever possible appropriate contractual protections from the recipients of such data and only transfer data where it is necessary to do so.
- In order to ensure that the rights of individuals recorded by Our visual, audio and chat technology as mentioned above are protected, We will do Our best to ensure that data gathered by such technology is stored in a way that maintains its integrity and security. This may include encrypting the data, where it is possible for Us to do so.
4. Your Rights as a Data Subject
If You wish to exercise any of the following rights which You might have in certain jurisdictions, please raise the matter with Our DPO and Our DPO will ensure that We comply with applicable law:
- Right of access. You may be able to request copies of personal data We hold and other information about You related to such data.
- Right to rectification. If We process inaccurate personal data about You, please contact Our DPO who will seek to amend such data after checking that it is indeed inaccurate.
- Right to erasure (“right to be forgotten”). In certain circumstances, You can require that We erase personal data We hold and process about You. Again, You can discuss Your rights with Our DPO and what the consequences would be by exercising such rights (for instance We may not be able to continue to provide the Fournaise Services to You).
- Right to restriction of and/or to object to processing. You may have rights to restrict or stop how We process Your personal data.
If You would like to access, review, correct or update Your personal information, You may log in into Your Fournaise account and/or contact Us (see section 13). When You contact Us, please provide Your name and contact details (including Your email address, postal address, and telephone number) and specify clearly what information You would like to access, review, correct or update. We may need to share Your information with others, including third party data processors, who can help Us respond to Your request. We will try to respond to Your request as soon as reasonably practicable and in any event, We will respond within statutory timeframes.
5. HOW CAN YOU OPT OUT OF PROCESSING FOR MARKETING PURPOSES
Unless You are an existing customer or contact and We are marketing services We provided to You previously and You had previously provided consent to such marketing (in which case You are deemed under this policy to have provided consent (subject of course to Your subsequent withdrawal of that consent) We will ask for Your consent for direct marketing and by using Our Fournaise Website site You consent to all other processing set out in this policy (although We may have other lawful processing reasons to process Your data in addition to consent). However, We set out below actions You can take to remove Your consent to processing for marketing purposes (which does not affect the lawfulness of processing prior to the removal of such consent):
- Direct marketing. If You do not want to receive promotional messages from Us, You can change Your account settings or follow the unsubscribe instructions which We include at the bottom of Our emails and text messages. If You have installed Our app when it is available, You can stop push notifications by changing the settings in the app or on Your mobile device. Please note that if You have previously consented to receive promotional messages from third parties, You will need to unsubscribe from those third parties’ offerings, as We have no control over third party marketing preferences.
- Social media sharing. If You have linked any of Your social media profiles to Your account for any Fournaise Service, You can cancel that link by changing Your account settings.
6. How We Store Your Information
Fournaise Website Hosting & Secure Servers.
- The Fournaise Website is hosted in secure data centres in the United States by two specialised 3rd party web hosting providers (“3PWHP”) named SiteGround & Gigenet. To the best of Our knowledge their facilities are protected by 24×7 human security, biometrics and video surveillance.
The Fournaise METB Solutions are securely hosted by specialised 3rd party cloud hosting providers on high-performance servers located within secure Tier 3 data centres located in the United States and the United Kingdom (to the best of our knowledge). For security reasons We will not publish here the names of these 3rd party cloud hosting providers but if You have questions about them You may contact Our DPO.
To the best of Our knowledge some of their data centres’ more notable security features are as follows:
- Multi-layer security control procedures
- 24/7 staffing
- Only authorised security-cleared staff are allowed into the facilities
All traffic (transferral of files) between Our Fournaise Website and Your browser is encrypted and delivered over HTTPS.
Pseudonymisation. Your personal and other information will be stored in Our internal databases (located in and managed by Our Fournaise METB Solutions in secure servers, as described above), in which We are working on applying pseudonymisation and will implement it whenever we judge we are ready. Put simply, this is a process to transform data in a way that stops it from being attributed to You without the use of additional information. An example of this might be using a unique reference ID for You rather than Your name when storing their data in a database. A second table of names and corresponding IDs stored may then be used to join the tables together and recreate the data. In this way if a data breach occurred and the personal data was stolen, pseudonymisation minimises the risk of the data exposing actual names.
7. Our Third Party Data Processors
We use a number of third parties to process personal data on Our behalf. These third parties have been carefully chosen and have confirmed in Our commercial agreements or in their own standard terms or other relevant documents, agreements or treaties that they comply with applicable data protection law.
8. Personal Data Breaches
Our DPO will ensure that We are ready to respond to any personal data breaches in accordance with Our legal obligations and if the DPO believes that there is a high risk to Your rights and freedoms as a result of a personal data breach, You will be notified of the likely consequences of the breach and of the measures taken or proposed to be taken to address the breach. At the same time, You will be reminded of the contact details of the DPO, from whom more information can be obtained.
9. Data Controller
The data controller of Our Fournaise Website is:
The Fournaise Marketing Group Ltd.
Registered in England & Wales. Number: 6443467
Whose trading address is at:
Holden House, 4th Floor
54-68 Oxford Street
W1T 1JU London
10. Data Protection Officer
Mr. Darren Coulson
Vice President Operations
12. Other Important Information For You
Location of Data. Some Fournaise Services are hosted in and managed outside Your country of residence. You explicitly consent to this practice and in any event You acknowledge that it is necessary for Our business operations for Us to do that, understanding that Your personal information may be accessible from or transmitted outside Your country of residence.
Complaint. If You think We have breached an applicable privacy law, You can contact Our DPO to make a complaint. When You contact Us, please include Your name and contact details (including Your email address, address, and telephone number) and clearly describe Your complaint. We may need to share Your information with others (including third party data processors) who can assist in responding to Your complaint. We will seek to apply with all applicable law when We respond. If You are not satisfied with Our response, You may refer Your complaint to the Office of the Australian Information Commissioner (www.oaic.gov.au) (if You are in Australia) or the Information Commissioner’s Office in the UK (www.ico.org.uk) (if You are in the UK) or any other applicable regulator within Your own jurisdiction if You live outside of Australia or the UK.
13. How You Can Contact Us
14. List of Included Companies
- The Fournaise Marketing Group Ltd (Registered in England & Wales. Number: 6443467)
- The Fournaise Marketing Group Pte Ltd (registered in Singapore. Number 199907353K)
15. Change Log
v1.2. Last updated on: 18 Jun 2019.