Squiz's approach to privacy
Squiz Pty Ltd and the other Squiz entities in the Squiz group (including Squiz Australia Pty Ltd, Squiz Inc, Squiz Limited (New Zealand), Squiz Poland sp. z.o.o., Squiz Scotland Ltd, Squiz UK Limited, Funnelback Pty Ltd, Funnelback UK Ltd and Funnelback Inc) (Squiz) are the controllers of and have access to your information for use in accordance with this Privacy Notice.
Squiz takes its responsibilities regarding privacy seriously and complies with all laws and regulations to the extent they apply in the jurisdictions in which Squiz conducts business. A summary of the key elements of this Privacy Notice are shown below.
Squiz is strongly committed to protecting your privacy when you use our services or interact with us.
This Privacy Notice explains:
- when this Privacy Notice applies;
- what information we collect and why we collect it;
- how we collect information;
- our use of cookies to collect information and how you can control or delete these cookies;
- how long we keep that information;
- who has access and how we may disclose that information;
- your rights, such as how you can access and update the information we hold about you;
- how we protect your information.
California Residents. If you are a California resident, please review the Additional Information for California Residents set out at the end of this notice
1. When this Privacy Notice applies
This Privacy Notice applies to all personal information collected by Squiz from you or other individuals. It is designed to cover the processing we undertake for our customers, website users, service providers and business partners.
2. What personal information do we collect and why do we collect it
We have set out below, in a table format, a description of all the ways we plan to use your personal information, and which of the lawful bases we rely on to do so (as required by applicable data protection laws). We have also identified what our legitimate interests are, where appropriate.
Note that we may process your personal information for more than one lawful basis depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific lawful basis we are relying on to process your personal information where more than one ground has been set out in the table below.
| Purpose for processing | Categories of date | Lawful basis |
|---|---|---|
To correspond with Squiz | Name Email address Telephone number Organisation name Location Information about your order and services requested Correspondence from you, including feedback | Legitimate interest (i.e. we have a legitimate interest in responding to all questions and comments) |
To participate in community forums, seminars and webinars | Legitimate interest (i.e. we have a legitimate interest in providing and facilitating participation in the community forum. | |
| To provide products or services requested (e.g. receiving support services) and dealing with complaints | Performance of a contract with you. Legitimate interest (i.e. to provide our products and services to you (or your employer, employees or end-users) and providing you support services). | |
To improve our services (e.g. collecting & analysing statistical & research data and the use of cookies) | Legitimate interest (i.e. in improving our services and the customer experience and interactions with Squiz). | |
| To register for Squiz events | Legitimate interests (i.e. to ensure that individuals who wish to participate in our events are properly accounted for, and so that Squiz can understand who attends them for business and security purposes) | |
To send our newsletter and marketing materials including surveys and promotions either directly or via our third party supplier. | Consent - Where required by privacy laws, your consent. Legitimate interest - to send you communications related to similar products or services to which you have previously purchased where permitted by privacy laws. | |
In connection with a sale, transfer of assets, investments, acquisition, bankruptcy or similar event. | All personal data mentioned in this Privacy Notice | Legitimate interests – in growing the business and making investment decisions. |
To improve our website and ensure it remains secure and accessible. | Information about the webpages you visit, your IP address, browser type, your operating system, device type, the number of times you visit our website, your interactions with our website, your display settings, and time zone. | Legitimate interests – in providing a website. Consent – for the placement of cookies that are not strictly necessary such as performance and functionality. |
3. How we collect information
Broadly, there are two methods we use to collect your personal information:
(a) Information that you specifically give us
In some instances, you must provide personal information if you wish to receive a particular service or participate in an activity.
You may choose to provide some personal information that is not required but is directly related to our functions and activities. This type of information will usually enable us to improve or broaden the services we offer you. If you choose not to provide this optional information, we would still be able to offer you the service although it may be with fewer options than if you had provided the optional information.
If you provide us with unsolicited information that we do not require or that is not directly related to our functions or activities, we may be required to destroy or de-identify that information, provided it is lawful and reasonable to do so.
In some instances, you will be asked to confirm that you agree to a particular activity such as expressly agreeing that you would like to receive our newsletter or other marketing communications. You can always opt-out of receiving marketing emails from us by clicking on the unsubscribe link at the bottom of the email or by visiting our email subscription management page here (www.squiz.net/unsubscribe).
We may use third parties to collect your personal information on our behalf but the collection and processing of that personal data will still be on the terms set out in this Privacy Notice.
(b) Automatic collection
When you browse our website, we collect information as set out in the table above in order to improve user experience and to keep the website secure.
We may use a feature of your browser called a cookie to assign your computer a 'User ID'. Cookies do not contain information by which we can identify you – they only identify your computer to our servers.
4. Cookies used on the site
For further information about cookies, please see our Cookie Notice here.
5. How long do we keep your information?
We will retain your information for as long as necessary for the uses set out in this Privacy Notice. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and any applicable requirements which may relate to any legal, regulatory, accounting, reporting, insurance, professional indemnity, internal policy or other obligations. If you ask us to delete your information before that time, we may not be able to do so, due to legal or regulatory constraints. For example, we would need to retain your name and contact details for suppression purposes if you do not want to receive direct marketing from us.
If we withdraw a product or service, such as an online forum, we may either archive or delete the information you have provided to it.
6. Who has access to your information?
We may share your personal information within the wider Squiz group of companies, and we will do so via an intra-group agreement containing relevant data protection requirements.
Otherwise, we do not share personal information with other companies, organisations and individuals unless one of the following circumstances applies:
- on your request – we will share your personal information when we have your consent to do so;
- third-party suppliers who provide services to us for example for delivery services, agencies which send direct marketing on our behalf, software providers or market research agencies. We may also use suppliers to collect your information on our behalf but the use of your information will still be subject to this Privacy Notice;
- business partners and affiliates;
- for legal reasons; or
- if we sell part or all of our business, customer information may be one of the transferred business assets. If this happens, your information may be disclosed to any successors of our business for them to use for the purposes set out in this Privacy Notice.
Where we provide you with a service that is dependent on age or residency and we have an obligation to verify this information then we may pass your details to a third party to carry out the verification for us.
We will only disclose your information to third-party companies for their own purposes, including marketing their products and services when we have a legal basis to do so. In most cases, this would require your prior consent.
7. Information transfers
When you provide us with your information or use our services, we may transfer your information to other members of the Squiz group or to third parties in another country (including outside the European Economic Area) but will do so with appropriate measures and controls in place to protect that information in accordance with applicable data protection legislation. You have a right to request a copy of the appropriate measures we put in place.
8. Third-party information
When you give us information about another person, you confirm that they have agreed that you can share their information with us and have given them a copy of this Privacy Notice.
9. User access and controls
You have several rights in relation to your personal information which will depend on your location and the relevant data protection laws that are applicable. In certain circumstances these rights may not be absolute, which we can discuss with you further where relevant. You are not required to pay a charge in most circumstances for exercising your rights and we generally have one month to respond to your request.
We ask for proof of ID where we need to confirm the identity of the individual making the request.
You can make such a request to exercise any of your data subject rights by sending us an email to [email protected] or your Account Manager or Business Development Manager.
(a) Right to access personal information
You may request a copy of your personal information from any Squiz group company which may hold personal information about you (we expect in all but exceptional circumstances to carry this out free of charge). You can also ask us to correct any inaccuracies in your personal information (which is free) though we may need to verify the accuracy of the new data you provide to us.
If particular circumstances apply, we are permitted by the Australian Privacy Act or other relevant data protection law to deny your request for access or limit the access we provide. We will let you know why your request is denied or limited.
(b) Right to erase personal information
You have the right to ask us to delete or remove personal information where there is no good reason for us to continue processing it. You also have the right to ask us to delete or remove your personal information where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal information to comply with local law.
If you ask us to delete your information, we may not be able to do so, due to technical, legal, regulatory and contractual constraints which will be notified to you, if applicable, at the time of your request. For example, we need to retain your name and contact details for suppression purposes if you do not want to receive direct marketing from us.
If you ask for your account to be closed, we will do this as soon as is reasonably possible subject to any applicable terms and conditions relating to the account. Personal information from closed accounts is retained in order to comply with legal obligations, prevent fraud, collect any fees owed or to resolve disputes.
(c) Right to object to processing of your personal information
You have the right to object to processing where we are relying on our legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
(d) Right to restrict the processing of your personal information
This enables you to ask us to suspend the processing of your personal information in the following scenarios:
(i) if you want us to establish the data’s accuracy;
(ii) where our use of the data is unlawful but you do not want us to erase it;
(iii) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
(iv) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
(e) Right to data portability
You have the right to request the transfer of your personal information to you or to a third party. We will provide to you, or a third party you have chosen, your personal information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
(f) Right to withdraw consent to processing
You have the right to withdraw consent at any time where we are relying on consent to process your personal information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you (or the business you work for). We will advise you if this is the case at the time you withdraw your consent.
(g) Right to complain
We welcome the opportunity to attend to any of your concerns or complaints about the way in which we handle your personal data, however you also have the right to make a complaint at any time:
- in the UK, to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues: https://ico.org.uk/global/contact-us/
- in the EEA, to the applicable supervisory authority for your country, a full list of whom is available at: https://www.edpb.europa.eu/about-edpb/about-edpb/members_en
- in Australia, to the Office of the Australian Information Commissioner (OAIC), the Australian supervisory authority for data protection issues: https://www.oaic.gov.au/contact-us in New Zealand, to the Privacy Commissioner:
- https://www.privacy.org.nz/your-rights/making-a-complaint-to-the-privacy-commissioner/
For California residents, see the section below "Additional Information for California Residents"
(h) Updating your information
Please ensure you update your personal information or tell us if it changes or is inaccurate. You can request to update your details, for example, your email address, through the “My Account” or an equivalent section if you are a subscriber. You may also email our Member Services team at [email protected].
(i) Controlling direct marketing
You can change your mind about receiving direct marketing from us by contacting us using the details above or by following the unsubscribe instructions in the communication.
(j) Controlling other communications
You can control communications such as bulletins and other information about your chosen services by following the unsubscribe instructions in the communication. You may still receive other communications that are relevant to your chosen services but do not relate to that specific type of communication. Where this is the case, you will be able to unsubscribe from these communications in the same way.
10. Protecting your information
We are committed to keeping secure the personal information you provide to us. We take all reasonable precautions to protect the personal information we hold about you from misuse and loss and from unauthorised access, modification or disclosure.
Our website may contain links to third-party websites. Whilst such links are provided for your convenience, you should be aware that the information handling practices of the linked websites might not be the same as ours.
11. Automated decision making
No decisions about individuals using their personal data are made by automated processes with relation to our customers, business partners and website visitors.
12. Changes to our Privacy Notice
This policy will be reviewed at least annually and as a result may be updated. All information held by us will be governed by the most recently updated notice.
13. Who to contact
If you have any questions or concerns concerning our Privacy Notice, please contact us by email to [email protected]. Postal addresses can be found on Squiz's website here.
Additional Information for California Residents
In this California-specific section, we provide information as required under California privacy laws, including the California Consumer Privacy Act, as amended by the California Privacy Rights Act (collectively, CCPA), which require that we provide information to California residents about how we handle their personal information (as defined by the CCPA), whether collected online or offline. This section does not address or apply to our handling of publicly available information made lawfully available by state or federal governments or other personal information that is subject to an exemption under California privacy laws.
Categories of Personal Information That We Collect and Disclose. Our collection, use, and disclosure of personal information about a California resident will vary depending upon the circumstances and nature of our interactions or relationship with them. The table below sets out generally the categories of personal information (as defined by the CCPA) about California residents that we collect, use, and disclose to others for a business or commercial purpose.
Categories of Personal Information Collected | Categories of Third Parties to Whom We May Disclose this Information for Business or Commercial Purposes | |
|---|---|---|
| Identifiers | such as name, postal address, phone number, unique personal identifier, online identifier, internet protocol (IP) address, device ID, email address, account name, signature, or other similar identifiers. |
|
| Customer Records | Includes your account and profile information and customer records that contain personal information, such as username, name, demographics and other characteristics or descriptions, email, address, telephone number, and other contact information, account credentials, communications preferences, billing and payment information, customer service and support tickets and records, and other information individuals provide us to register for, access, purchase or use our Services. |
|
| Commercial Information | Includes records of personal property, products or services purchased, obtained, or considered, or other purchasing or use histories or tendencies, such as information about your subscriptions and current and past payments and purchases, products and services you use or are interested in, and your purchase tendencies. |
|
| Internet or Other Electronic Network Activity Information | Includes browsing history, clickstream data, search history, access logs, information regarding your interactions with our websites, mobile applications and other Services and our marketing emails and online ads, and other usage data related to your use of the Services, such as language and preferences, as well as your comments, posts, and interactions in public forums and communities. |
|
| Location Data | Includes location information about a particular individual or device, such as device location information for mobile application users. |
|
| Audio, Video and Electronic Data | Includes audio, electronic, visual or similar information (e.g., pictures, a recording of a customer service call, security video surveillance footage). |
|
| Inferences | Includes inferences drawn from other personal information identified in this table to create a profile based on your account and activities, that reflect your preferences, characteristics, behavior, attitude, and abilities related to the Services. |
|
Protected classification characteristics under | Includes characteristics of protected classifications under applicable laws, such as disability information |
|
Do We “Sell” or “Share” Personal Information? California privacy laws define a “sale” as disclosing or making available to a third party, personal information in exchange for monetary or other valuable consideration, and “sharing” includes disclosing or making available personal information to a third party for purposes of cross-context behavioral advertising. We do not disclose personal information to third parties in exchange for monetary compensation. We may “share” (as defined by the CCPA) Identifiers, Customer Records, Commercial Information and Location Data with our Affiliates. We do not “sell” or “share” (as defined by the CCPA) sensitive personal information, nor do we “sell” or “share” any personal information about individuals who we know are under sixteen years old.
Sources of Personal Information. As noted above, in general, we may collect the categories of personal information identified in the table above directly from you, and automatically related to your use of our Services and interactions with us, as well as from third parties. This may include:
- Our Affiliates and subsidiaries
- Third-party platforms
- Third-party sites and services
- Ad networks
- Analytics providers
- Social networks
- Internet service providers
- Operating systems and platforms
- Our vendors and service providers
- Publicly available information
Purposes for Collecting and Disclosing. As described in more detail in the table above, in general, we collect and otherwise process the personal information identified in the table above to provide our Services to you, respond to and fulfill your orders and requests, as otherwise directed or consented to by you, and for the following business or commercial purposes:
- Providing our Services and related support
- Protecting the integrity of the Services
- Analyzing and improving the Services and our business
- Personalizing the Services
- Advertising, marketing, and promotional purposes
- Securing and protecting our business
- Defending our legal rights
- Auditing, reporting, corporate governance, and internal operations
- Complying with legal obligations.
Retention. We will retain your personal information as long as necessary for the purposes for which the personal information was collected and is used by us, as stated in this Privacy Policy. If you wish to cancel your account, or request that we no longer use your personal information to provide the Services to you, please contact us as set out in the “Who to Contact” section above. However, if you withdraw consent or otherwise object to our collection, use, and disclosure of your personal information, you may not be able to use the Services. Further, to the extent permitted by law, we will retain and use your personal information as necessary to comply with our legal obligations, resolve disputes, maintain appropriate business records, and enforce our agreements.
Sensitive Personal Information. Notwithstanding the purposes described above, we do not collect, use or disclose sensitive personal information about California residents beyond the purposes authorized by the CCPA (pursuant to Cal Civ. Code § 1798.121 and § 7027(l) of the CCPA regulations). Accordingly, we only use and disclose sensitive personal information about California residents as reasonably necessary and proportionate: (i) to perform our services requested by you; (ii) to help ensure security and integrity, including to prevent, detect, and investigate security incidents; (iii) to detect, prevent and respond to malicious, fraudulent, deceptive, or illegal conduct; (iv) to verify or maintain the quality and safety of our services; (v) for compliance with our legal obligations; (vi) to our service providers who perform services on our behalf; and (vii) for purposes other than inferring characteristics about you.
California Residents’ Rights. California residents have the right to receive certain information about how their personal information is used and disclosed and to not be discriminated against for exercising their privacy rights under the CCPA. In addition, California residents have the right to understand the material terms of any “financial incentive” offered to them and to not be included in such without consent.
The CCPA also grants California residents the following rights, in each case subject to certain exceptions:
- Opt out of sales and sharing: the right to opt out of our sale and sharing of their personal information.
- Delete: the right to request deletion of their personal information that we have collected about them.
- Know/access: the right to request and, subject to certain exemptions, receive a copy of the specific personal information that we have collected about them and to have this delivered either (a) by mail or (b) electronically in a portable and, to the extent technically feasible, readily useable format that allows the individual to transmit this information to another entity without hindrance. California residents also have the right to request that we provide them certain information about how we have handled their personal information, including the:
- categories of personal information collected;
- categories of sources of personal information;
- business and/or commercial purposes for collecting, selling, and sharing their personal information;
- categories of third parties with whom we have disclosed or shared their personal information;
- categories of personal information that we have disclosed or shared with a third party for a business purpose; and
- categories of third parties to whom the residents’ personal information has been sold and shared and the specific categories of personal information sold and shared to each category of third party.
- Correct: the right to request that a business that maintains inaccurate personal information about the resident correct that personal information.
- Limit use or disclosure of sensitive personal information: the right to limit the use or disclosure of sensitive personal information to those uses authorized by California privacy laws. However, we do not use or disclose sensitive personal information except for the purposes described above under “Sensitive Personal Information,” as authorized by California privacy laws.
Submitting CCPA Requests to Know, Correct, and Delete. California residents may submit a request to exercise their CCPA rights to know, correct, and delete by emailing [email protected]. Postal addresses can be found on Squiz's website here.
When you submit a request to know, to correct, or to delete, we will take steps to verify your request by matching the information provided by you with the information that we have in our records. You must provide us with this information, e.g., via email and verify your access to the registered email address for your account, to validate your request. In some cases, we may request additional information to validate your request or where necessary to process your request. If we are unable to adequately verify a request, we will notify the requestor. Authorized agents may initiate a request on behalf of another individual by contacting us in writing at the contact information set forth in the “Who to Contact” section above. Authorized agents will be required to provide proof of their authorization and we may also require that the relevant consumer directly verify their identity and the authority of the authorized agent. We will respond to verifiable requests received from California residents as required by law.
Requests to Opt Out of Sales and Sharing. California residents may submit requests to opt out of “sales” and “sharing” as set forth below:
- Browser Opt Out: You may opt out of “sales” and “sharing” (if applicable) via your browser on our websites by:
- Turning on “global privacy control”—or GPC—signals for your browser. If we recognize that your browser is transmitting a GPC signal, we will opt that browser out of “sales” and “sharing.”
- Turning off Sales and Sharing of Personal Information under the Cookie Preferences and Opt Out settings for that website.
Your opt out is browser specific and applies to “sales” and “sharing” on the website you are browsing (i.e., via cookies). If you come to the website from a different device or a different browser on the same device, you will need to apply your preferences or turn on GPC for that browser or device as well. More information on GPC is available at https://globalprivacycontrol.org/.
Do-Not-Track Signals. Please note that our websites do not recognize or respond to any signal which your browser might transmit through the so-called “Do Not Track” feature your browser might have.
Rights Under California's Shine-the-Light Law. If you are a California resident, you may contact us by requesting a list of any third parties to which we have disclosed personally identifiable information about you for their own direct marketing purposes. You may make one request per year. In your request, please attest to the fact that you are a California resident and provide a current California address for your response. You may request this information in writing via the contact details set out in the “Who to Contact” section above.
For more information about our privacy practices, you may contact us as set out in the “Who to contact” section above.
Other U.S. State Privacy Laws
Residents of certain U.S. states (including Virginia, Colorado, and Connecticut) have additional privacy rights under applicable privacy laws, subject to certain limitation, including:
- Right to Correct: to correct inaccurate personal information, taking into account the nature and purposes of the processing of the personal information.
- Right to Delete: to delete personal information provided to or obtained by us.
- Right of Access: to confirm whether we are processing personal information and to obtain a copy of personal information in a portable and, to the extent is is technically feasible, a readily usable format.
- Rights to Opt Out: to opt out of certain types of processing, including:
- to opt out of the “sale” of personal information by us
- to opt out of the use and disclosure of personal information for the purposes of targeted advertising (i.e., cross-contextual behavioral advertising).
- to opt out of processing (if any) of personal information for purposes of making decisions that produce legal or similarly significant effects.
- to opt out of certain uses and disclosures of sensitive personal information by us.
We will respond to your request as required under the applicable privacy law(s).
In addition, you can also set your browser to transmit a “global privacy control” (GPC) signal or another approved “universal opt-out mechanism” to opt out of targeted advertising and sales (as defined under applicable law). If we detect that your browser is transmitting a GPC or other recognized universal opt-out signal when you visit one of our websites, we will opt that browser on your device out of targeting cookies on that website. Please note that if you come back to that website from a different device or from a different browser on the same device, you will need to apply the signal for that browser and/or device as well.
If we deny your request, you may appeal our decision by contacting us as set out in the “Who to contact” section above.
If you wish to submit a complaint about the way in which we have handled your data, please do so to the California Privacy Protection Agency (CPPA): https://cppa.ca.gov/webapplications/complaint.
Last updated: 5 November 2024