Effective date: September 15, 2018
EU Privacy Notice
In this document, “we”, “our”, or “us” refer to Skillsuper
Our Company Number: 10446299, registered in England and Wales.
Registered office: 27 Old Gloucester Street, London, WC1N 3AX, United Kingdom
Contact No: +443330124846
Data Protection in charge email: [email protected]
This page informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Service and the choices you have associated with that data.
We undertake the protection of your privacy and confidentiality seriously. We understand that all visitors to our website are entitled to know that their personal data will not be used for any purpose unintended by them, and will not accidentally fall into the hands of a third party.
We undertake to preserve the confidentiality of all information that is given to us, and hope that you will in return protect the confidentiality of our data.
The law requires us to tell you about your rights and our obligations to you in regards to the processing and control of your personal data. Individuals are entitled to the following rights by the GDPR:
- The right to be informed
- The right of access
- The right to rectification
- The right to erasure
- The right to restrict processing
- The right to data portability
- The right to object
Rights in relation to automated decision-making and profiling
For detailed information on these rights, please read the information provided at www.knowyourprivacyrights.org
As set out below, we do not share, sell, or disclose to a third party, any information collected through our website.
Our policy is in compliance with UK law accordingly implemented, including that required by the EU General Data Protection Regulation (GDPR).
Definitions and interpretation
|Data||collectively all information that you submit to Skillsuper via the Website. This definition incorporates, where applicable, the definitions provided in the Data Protection Laws;|
|Cookies||a small text file placed on your computer by this Website when you visit certain parts of the Website and/or when you use certain features of the Website. Details of the cookies used by this Website are set out in the clause below (Cookies);|
|Data Protection Laws||any applicable law relating to the processing of personal Data, including but not limited to the Directive 96/46/EC (Data Protection Directive) or the GDPR, and any national implementing laws, regulations and secondary legislation, for as long as the GDPR is effective in the UK;|
|GDPR||the General Data Protection Regulation (EU) 2016/679;|
|Skillsuper, or us||Skillsuper, a company incorporated in England and Wales with registered number 10446299 whose registered office is at 27 Old Gloucester Street, London, , United Kingdom , WC1N 3AX;|
|UK and EU Cookie Law||the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended by the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011;|
|User or you||any third party that accesses the Website and is not either (i) employed by Skillsuper and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to Skillsuper and accessing the Website in connection with the provision of such services; and|
|Website||the website that you are currently using, https://skillsuper.com/, and any sub-domains of this site unless expressly excluded by their own terms and conditions.|
- the singular includes the plural and vice versa;
- a reference to a person includes firms, companies, government entities, trusts and partnerships;
- “including” is understood to mean “including without limitation”;
- reference to any statutory provision includes any modification or amendment of it;
- For purposes of the applicable Data Protection Laws, Skillsuper is the “data controller”. This means that Skillsuper determines the purposes for which, and the manner in which, your Data is processed.
While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally identifiable information may include, but is not limited to:
- We may collect the following Data, which includes personal Data, from you:
- date of birth;
- contact Information such as email addresses and telephone numbers;
- demographic information such as postcode, preferences and interests;
- IP address (automatically collected);
- web browser type and version (automatically collected);
- operating system (automatically collected);
- a list of URLs starting with a referring site, your activity on this Website, and the site you exit to (automatically collected);
How we collect Data
- We collect Data in the following ways:
- data is given to us by you;
- data is received from other sources; and
- data is collected automatically.
Data that is given to us by you
- Skillsuper will collect your Data in a number of ways, for example:
- when you contact us through the Website, by telephone, post, e-mail or through any other means;
- when you register with us and set up an account to receive our products/services;
- when you complete surveys that we use for research purposes (although you are not obliged to respond to them);
- when you enter a competition or promotion through a social media channel;
- when you make payments to us, through this Website or otherwise;
- when you elect to receive marketing communications from us;
- when you use our services;
- Social media and univeristies sites ;
Data that is collected automatically
- To the extent that you access the Website, we will collect your Data automatically, for example:
- we automatically collect some information about your visit to the Website. This information helps us to make improvements to Website content and navigation, and includes your IP address, the date, times and frequency with which you access the Website and the way you use and interact with its content.
- we will collect your Data automatically via cookies, in line with the cookie settings on your browser. For more information about cookies, and how we use them on the Website, see the section below, headed “Cookies”.
We may also collect information how the Service is accessed and used (“Usage Data”). This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
- Any or all of the above Data may be required by us from time to time in order to provide you with the best possible service and experience when using our Website. Specifically, Data may be used by us for the following reasons:
- internal record keeping;
- improvement of our products / services;
- transmission by email of marketing materials that may be of interest to you;
- contact for market research purposes which may be done using email, telephone, fax or mail. Such information may be used to customise or update the Website;
- marketing services;
- We may use your Data for the above purposes if we deem it necessary to do so for our legitimate interests. If you are not satisfied with this, you have the right to object in certain circumstances (see the section headed “Your rights” below).
- For the delivery of direct marketing to you via e-mail, we’ll need your consent, whether via an opt-in or soft-opt-in:
- soft opt-in consent is a specific type of consent which applies when you have previously engaged with us (for example, you contact us to ask us for more details about a particular product/service, and we are marketing similar products/services). Under “soft opt-in” consent, we will take your consent as given unless you opt-out.
- for other types of e-marketing, we are required to obtain your explicit consent; that is, you need to take positive and affirmative action when consenting by, for example, checking a tick box that we’ll provide.
- if you are not satisfied about our approach to marketing, you have the right to withdraw consent at any time. To find out how to withdraw your consent, see the section headed “Your rights” below.
- When you register with us and set up an account to receive our services, the legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
- We may use your Data to show you Skillsuper adverts and other content on other websites. If you do not want us to use your data to show you Skillsuper adverts and other content on other websites, please turn off the relevant cookies (please refer to the section headed “Cookies” below).
Who we share Data with
- We may share your Data with the following groups of people for the following reasons:
- any of our group companies or affiliates – to ensure the proper administration of your website and business;
- our employees, agents and/or professional advisors – to obtain advice from professional advisers;
- third party service providers who provide services to us which require the processing of personal data – to help third party service providers in receipt of any shared data to perform functions on our behalf to help ensure the website runs smoothly;
- third party payment providers who process payments made over the Website – to enable third party payment providers to process user payments and refunds;
Security Of Data
The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
- We will use technical and organisational measures to safeguard your Data, for example:
- access to your account is controlled by a password and a user name that is unique to you.
- we store your Data on secure servers.
- We are certified to Cloudflare Security Services. This family of standards helps us manage your Data and keep it secure.
- Technical and organisational measures include measures to deal with any suspected data breach. If you suspect any misuse or loss or unauthorised access to your Data, please let us know immediately by contacting us via this e-mail address: [email protected]
- If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
We do not store information about your debit or credit card or other means of payment.
If we ask you questions about your payment information, we only use partial details OR the first four OR the last four digits of the debit or credit card number, so that you can identify the means of payment to which we refer.
At the point of payment, you are transferred to a secure page on the website of PayPal. That page may be branded to look like a page on our website, but it is not controlled by us
Sending a message to our support team
When you contact us, whether by telephone, through our website or by e-mail, we collect the data you have given to us in order to reply with the information you need.
We record your request and our reply in order to increase the accuracy and effectiveness of our business.
We keep personally identifiable information associated with your message, such as your name and email address so that we can track our communications to ensure you are provided with a high quality service.
Affiliate and business partner information
This is information given to us by you in your capacity as an affiliate of ours or as a business partner.
It allows us to recognise visitors that you have referred to us, and to commission your due for such referrals. It also includes information that allows us to transfer commission to you.
The information is not used for any other purpose.
We undertake to preserve the confidentiality of the information and of the terms of our relationship.
We expect any affiliate or partner to agree to and reciprocate this policy.
- Even if we delete your Data, it may persist on backup or archival media for legal, tax or regulatory purposes.
- You have the following rights in relation to your Data:
- Right to access – the right to request (i) copies of the information we hold about you at any time, or (ii) that we modify, update or delete such information. If we provide you with access to the information we hold about you, we will not charge you for this, unless your request is “manifestly unfounded or excessive.” Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why.
- Right to correct – the right to have your Data rectified if it is inaccurate or incomplete.
- Right to erase – the right to request that we delete or remove your Data from our systems.
- Right to restrict our use of your Data – the right to “block” us from using your Data or limit the way in which we can use it.
- Right to data portability – the right to request that we move, copy or transfer your Data.
- Right to object – the right to object to our use of your Data including where we use it for our legitimate interests.
- To make enquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your Data (where consent is our legal basis for processing your Data), please contact us via this e-mail address: [email protected]
- If you are not satisfied with the way a complaint you make in relation to your Data is handled by us, you may be able to refer your complaint to the relevant data protection authority. For the UK, this is the Information Commissioner’s Office (ICO). The ICO’s contact details can be found on their website at https://ico.org.uk/.
- It is important that the Data we hold about you is accurate and current. Please keep us informed if your Data changes during the period for which we hold it.
Transfer Of Data
Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.
If you are located outside United Kingdom and choose to provide information to us, please note that we transfer the data, including Personal Data, to United Kingdom and process it there.
Transfers outside the European Economic Area
- Data which we collect from you may be stored and processed in and transferred to countries outside of the European Economic Area (EEA). For example, this could occur if our servers are located in a country outside the EEA or one of our service providers is situated in a country outside the EEA.
- We will only transfer Data outside the EEA where it is compliant with data protection legislation and the means of transfer provides adequate safeguards in relation to your data, eg by way of data transfer agreement, incorporating the current standard contractual clauses adopted by the European Commission, or by signing up to the EU-US Privacy Shield Framework, in the event that the organisation in receipt of the Data is based in the United States of America.
- To ensure that your Data receives an adequate level of protection, we have put in place appropriate safeguards and procedures with the third parties we share your Data with. This ensures your Data is treated by those third parties in a way that is consistent with the Data Protection Laws.
We may employ third party companies and individuals to facilitate our Service (“Service Providers”), to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used.
These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
We may use third-party Service Providers to monitor and analyze the use of our Service.
For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en
Links to other websites
Changes of business ownership and control
- We may also disclose Data to a prospective purchaser of our business or any part of it.
- In the above instances, we will take steps with the aim of ensuring your privacy is protected.
Tracking & Cookies Data
Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze our Service.
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.
- to track how you use our website and to record whether you have seen specific messages we display on our website
- to keep you signed into our site and to record your answers to surveys and questionnaires on our site while you complete them
- to record the conversation thread during a live chat with our support team
You can find a list of Cookies that we use in the Cookies Schedule.
- You can choose to enable or disable Cookies in your internet browser. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser.
- You can choose to delete Cookies at any time; however you may lose any information that enables you to access the Website more quickly and efficiently including, but not limited to, personalisation settings.
- It is recommended that you ensure that your internet browser is up-to-date and that you consult the help and guidance provided by the developer of your internet browser if you are unsure about adjusting your privacy settings.
- For more information generally on cookies, including how to disable them, please refer to aboutcookies.org. You will also find details on how to delete cookies from your computer.
Our use of re-marketing
Re-marketing involves placing a cookie on your computer when you browse our website in order to be able to serve to you an advert for our products or services when you visit some other website.
Our use of profiling, automated decision-making and targeted display advertising
We may use profiling, automated decision-making and targeted display advertising from time to time in order to provide you with a more customised and personalised experience; in addition we offer you products and services that directly relate to your specific needs.
Access to your personal information
At any time you may request to review or update personally identifiable information that we hold about you, you can contact us at [email protected]
To obtain a copy of any information that is not provided on our website, including your personal data, you may send us a request at [email protected]
Upon receiving the request, we will inform you when we expect to provide you with the information, and whether a fee may be required for providing it. We will endeavour to provide this information to you without unnecessary delay.
Removal of your information
If you wish us to remove/delete any personally identifiable information from our website or that we hold, you may contact us at [email protected]
This may limit the services and products we can provide to you.
Verification of your information
When we receive any request to access, edit or delete personal identifiable information we shall first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.
- Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.
- This Agreement will be governed by and interpreted according to the law of England and Wales. All disputes arising under the Agreement will be subject to the exclusive jurisdiction of the English and Welsh courts.
Our Service does not address anyone under the age of 18 (“Children”).
We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Children has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.
Compliance with the law
However, ultimately it is your choice as to whether you wish to use our website.
We may update this privacy notice from time to time and as and when it is required. The terms that apply to you are those posted here on our website on the day you use our website. It is advisable that you print a copy for your own safekeeping.
- By email: [email protected]
- By visiting this page on our website: https://skillsuper.com/contact/
- By phone number: +443330124846