1. Introduction and who we are
Dataloy Systems AS and its subsidiaries (“Dataloy”, “we”, “our” or “us”) are strongly committed to being responsible custodians of the information you provide us and the information we collect in the course of operating our business.
This Privacy Notice explains how Dataloy, as a data controller, may collect, use, share and protect information that we obtain about you directly or indirectly in accordance with applicable data privacy laws.
Where you use our services or your personal data is processed in connection with such services. We control the purpose for which such personal data is processed. Dataloy will be the data controller of such information.
From time to time, there may be more than one data controller of your information within our group where you have engaged different parts of our broader organisation to provide different or jointly delivered services.
This Privacy Notice does not apply to, and Dataloy is not responsible for, any third-party websites which may be accessible through links from this website.
2. Scope of Privacy Notice
This Privacy Notice explains and describes:
- When this Privacy Notice applies.
- How we collect your personal data.
- Legal basis for the usage of your personal data.
- How we use the personal data, we collect.
- How and when we may disclose personal data that we collect.
- What happens if your personal data is transferred overseas.
- How long we hold your personal data.
- How we protect your personal data and keep it secure.
- What cookies are and how we use them.
- What happens when you access third-party services and content.
- Your legal choices and rights.
- The status of this Privacy Notice and any changes that are made to it.
- How to request further information.
- Our contact details.
3. When this Privacy Notice applies
This Privacy Notice applies:
- to your use of any of our services where we are performing a data controller function;
- where you apply to us for a job or work placement;
- your supply of services to us where this involves any personal data; and/or
- to any personal information collected from third parties where we are the controller of such information.
4. How we collect your personal data
“Personal data” is any information that can be used to identify you or that we can link to you.
Where you use our services, we will collect personal data directly from you.
We may also collect personal data from third parties such as your employing organisation, regulatory authorities, recruitment agencies, credit reporting agencies, information or service providers, publicly available records, and the third parties described in section 7 (Disclosure of your information) below.
We collect information that you voluntarily provide to us, including when you communicate with us via email or other channels; when you sign up for or request that we send you newsletters, alerts, or other materials; when you sign up for a webinar or event; and when you respond to our communications or requests for information.
The information you provide may include current and historical personal data, including your name, contact details, title, identification, employment, positions held, and enquiry/complaint details and information about the organisation you are affiliated with. We may also collect personal data about your other dealings with us and our clients, including any contact we have with you in person, by telephone, email or online.
We may collect information from other sources, such as social media platforms that share information about how you interact with our social media content, and any information gathered through these channels will be governed by the privacy settings, policies, and/or procedures of the applicable social media platform, which we strongly encourage you to review.
We will handle any unsolicited information in accordance with law, including destroying or de-identifying such information where we are required to do so.
When you use our online services, we may collect the following:
- Information you provide by completing forms (this includes information you give us, submitting material, requesting services, entering competitions, registering for any of our online offerings or subscribing to our newsletters or other services).
- Information you provide by your participation in competitions, live chats, message boards.
- Information you provide to us if you contact us, for example to report a problem with our online services or raise a query or comment.
- Details of visits made to our online services including, but not limited to, the volume of traffic received, logs (including, where available, the IP address and location of the device connecting to the online services and other technical information and identifiers about the device and the nature of the visit) and the resources accessed.
- Where our online services require that you enter a password or other information in order to access certain features, we will collect such credentials when you enter them.
If you apply for a job or work placement with Dataloy then you may need to provide information about your education and employment. As part of your application, you will be asked to provide your express consent to our use of this information to assess your application and to allow us to carry out both recruitment analytics and any monitoring activities which may be required of us under applicable law as an employer. We may also carry out screening checks (including reference, background, directorship, financial probity, identity, eligibility to work, vocational suitability and criminal record checks) and consider you for other positions.
We may exchange your personal data with academic institutions, recruiters, screening check providers, health service providers, professional and trade associations, law enforcement agencies, recruitment analytics providers, referees and your current and previous employers. We may also gather additional information about you from publicly available resources such as LinkedIn or other social or professional media platforms and collate this with the information that you provide to us. Without your personal data, we may not be able to progress considering you for positions with us.
In some instances, personal data must be provided to us in order for us to legally or contractually perform services to you, for example where we are obligated to gather personal data for anti-money laundering identification purposes. Where relevant we will highlight to you those details that we are obligated to collect.
5. Legal basis for usage of personal data
Where we intend to use your personal data, we rely on the following legal grounds:
Performance of a contract: We may need to collect and use your personal data to enter into a contract with you or to perform a contract that you have with us. For example, where we respond to your requests and provide you with services in accordance with our terms of service or other applicable terms of business agreed with you or with your employing organisation.
Legitimate interests: Where we consider use of your information as being (a) non-detrimental to you, (b) within your reasonable expectations, and (c) necessary for our own, or a third party’s legitimate purpose, we may use your personal data, which may include:
- for our own direct marketing or continued communication;
- the prevention of fraud;
- our own internal administrative purposes;
- personalisation of the service(s) we provide to you;
- ensuring network and information security, including preventing unauthorised access to electronic communications networks and stopping damage to computer and electronic communication systems; and/or
- reporting possible criminal acts or threats to public security to a competent authority.
Compliance with a legal obligation: We may be required to process your information due to legal requirements, including employment laws, tax laws and other regulatory provisions applicable to Dataloy as a provider of software services.
Consent: You may be asked to provide your consent in connection with certain services that we offer, for example in respect of any processing of your personal data for our marketing purposes where you or your employing organisation is not a client of Dataloy, or in respect of certain special categories of personal data such as your health or racial background for which we are legally obliged to gain your consent due to the sensitive nature of such information and the circumstances in which it is gathered or transferred. Where we are reliant upon your consent, you may withdraw this at any time by contacting us in accordance with section 15 (Contact and further information) below, however please note that we will no longer be able to provide you with the products or services that rely on having your consent.
6. How we use your personal data
We use your information in order to provide you with, and improve, our services, for example:
- To provide you with Dataloy’s services (as noted above) that you or your employing organisation request.
- To respond to your enquiries.
- To carry out our obligations arising from any contracts entered into between you and us.
- To facilitate our internal business operations, including to fulfil our legal or regulatory requirements.
- To maintain and develop our relationship with you.
- For business purposes, data analysis, submitting invoices, detecting, preventing, and responding to actual or potential fraud, illegal activities, or intellectual property infringement.
- To maintain and update our records, including our database of contacts.
- To provide you on an ongoing basis with information and services, including relevant marketing communications related to Dataloy, and other information or materials, that you request from us or which we feel may interest you where you have indicated that you would like to receive these from us.
- To evaluate, recruit, and hire personnel.
- To measure the popularity and effectiveness of services such as newsletters and seminar invitations to improve what we offer to you and other recipients.
- To ensure that content from our online services is presented most effectively and securely for you and the device on which you are accessing our services, and to troubleshoot and improve such online services.
- To allow you to use or access interactive features or secure areas of our online services, when you choose to do so.
- For research, planning, service development, security or risk management.
- As we believe reasonably necessary or appropriate to: comply with our legal obligations; respond to legal process or requests for information issued by government authorities or other third parties; or protector your, our, or others’ rights.
We may not be able to do some or all of these things without your personal data.
If we intend to change the purpose for which we hold your personal data, for example, to offer you a complimentary service that we may provide in the future, in that case, we will give you prior information of that new purpose so you are aware of this.
7. Disclosure of your information
We may, in providing our services and operating our business, allow access to your personal data to the different entities within Dataloy’s group for our internal administrative purposes such as billing, promoting our events and services, and providing you or your organisation with services, provided in all instances that such processing is consistent with section 5 (Legal basis for usage of personal data) above and applicable law.
We may exchange your personal data with third-party service providers contracted to Dataloy where any of the following apply:
- You have consented to us sharing your personal data in this way.
- We deem reasonably necessary to provide you with the services that you have required at any particular time.
- Such sharing is provided for under contract, including our terms of service for any particular service that we may provide to you.
- Such sharing is to law enforcement bodies or other government authority.
- We need to enforce or apply our terms of service to which you have agreed (or other terms that have been agreed to apply to our relationship with you or your employing organisation).
- It is necessary to protect the rights and interests, property, or safety of Dataloy, our clients or others.
- It is relevant in the circumstances to disclose the information to parties with whom we have co-promotional arrangements (such as jointly sponsored events, external venues, or caterers).
- Our agents or contractors who assist us in providing our services require such information, for example in fulfilling requests for information, receiving and sending communications, updating marketing lists, analysing data, providing support services or in other tasks from time to time. Our agents and contractors will only use your information to the extent necessary to perform their functions.
- We use third-party service providers to provide services that involve data processing, for example archival, web-hosting, analytics providers in connection with the operation of our online services, event hosting, information technology providers, auditing, reference checking, professional advisory (including legal, accounting, financial and business consulting), mailing vendor, delivery, technology, website, research, banking, payment, client contact, data processing, insurance, forensic, litigation support, marketing and security services.
- All, or most, of the assets of Dataloy or any single business unit within Dataloy are merged with or acquired by a third party, or we expand or re-organise our business, in which case your personal data may form part of the transferred or merged assets.
- We are under a legal, regulatory or professional obligation to do so (for example, in order to comply with a Court Order).
Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to fulfil the service they provide you on Dataloy’s behalf. When such third parties no longer need your personal data to fulfil this service, they will dispose of such details in line with Dataloy’s procedures unless they are themselves under a legal obligation to retain information (provided that this will be in accordance with applicable data privacy laws). If we wish to pass your sensitive personal data onto a third party, we will only do so once we have obtained your consent, unless we are legally required to do otherwise.
We also provide anonymous statistical information about users of our websites and related usage information to reputable third parties, including analytics and search engine providers. We own the database rights in the information collected via our online services. We do not sell, rent, or otherwise share information that reasonably identifies you or your organisation with unaffiliated entities for their independent use except as expressly described in this Privacy Notice or with your express prior permission.
We may share information that does not reasonably identify you or your organisation as permitted by applicable law.
8. International Transfers
Where you are submitting personal data from within the European Economic Area (“EEA”), such information may be transferred to countries outside the EEA. By way of example, this may happen if one or more of our third-party service providers with whom we share personal data in accordance with section 7 (Disclosure of your information) are located, or have their servers located, outside your country or the country from which the data were provided.
If we transfer your information outside the EEA in this way, we will take steps to ensure that your privacy rights continue to be protected.
9. Retention of your data
We retain the information we collect no longer than is reasonably necessary to fulfil the purposes that such data was originally collected in accordance with our internal data retention policies or to comply with our legal and regulatory obligations.
A maintained copy of our retention policy is available upon request. Should you wish to review our retention policy then please contact us in accordance with section 15 (Contact and further information) below.
We take steps to hold information securely in electronic or physical form.
Our information security policy is supported by a variety of processes and procedures, and we store information in access-controlled premises or electronic databases requiring logins and passwords. All employees, officers or contractors of Dataloy and third-party providers with access to confidential information are subject to access controls and confidentiality obligations, and we require our third-party data storage providers to comply with appropriate information security industry standards.
Whilst we continually strive to ensure that our systems and controls are updated to reflect technological changes, the transmission of information via the internet is not completely secure, and as such, we cannot guarantee the security of your data transmitted to our online services, which is at your own risk.
If you communicate with us using a non-secure web platforms, you assume the risks that such communications between us are intercepted, not received, delayed, corrupted or are received by persons other than the intended recipient.
Once we have received your information, we will take reasonable steps to use procedures and security features to try to prevent unauthorised access, modification or disclosure.
You can help us to keep your information secure by ensuring that any user name or password in relation to our online services is kept strictly personal to you and not be made available to any other person. You should stop using your username and password and notify us immediately if you suspect that someone else may be using your user details or password.
11. Cookies Policy
Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently to improve the user experience, as well as to provide certain information to the owners of the site.
We may, for example, collect information about the type of device you use to access our online services, the operating system and version, your IP address, your general geographic location as indicated by your IP address, your browser type, the content you view and features you access on our online services, the web pages you view immediately before and after you access our online services, whether and how you interact with content available on our online services, and the search terms you enter on our online services.
Dataloy’s website sets cookies which remain on your computer for differing times. Some expire at the end of each session and some remain for longer so that when you return to our website, you will have a better user experience.
Which cookies we use
Detailed below are the cookies we use and why and how long they last.
We collect standard internet log information and details of visitor behaviour patterns by using Google Analytics cookies which expires after 26 months. We do this to compile reports and to help us find out things such as the number of visitors to the various parts of our website, so that this can be improved. This information does not identify visitors or collect any personal details. We do not make any attempt to find out the identities of those visiting our websites. We will not associate any data gathered in this way with any personal data from any source. For more information about Google Analytics cookies, please see the link here.