1 PURPOSE OF OUR POLICY

  • 1.1 ISG LLC (“ISG”, “we”, “us” or “our”) provides the suite of tools, applications and services, known together as “ISG GO”.
  • 1.2 This Privacy Policy aims to make it easy for you to understand:
    • 1.2.1 how we collect, use, share and protect the personal information that comes into our possession in the course of:
      • 1.2.1.1 providing the services that we offer; and
      • 1.2.1.2 the normal day-to-day operations of our business, and
    • 1.2.2 your rights regarding the user, access and correction of your personal information.
  • 1.3 This Privacy Policy follows the standards of the General
    Data Protection Regulation (“GDPR”), the EU-wide privacy and data
    protection law, together referred to as “Privacy Standards”.

2 WHO AND WHAT THIS POLICY APPLIES TO

  • 2.1 Our Privacy Policy deals with how we handle ‘personal
    information’ or ‘personal data’ as respectively defined in the Privacy
    Standards (“Personal Information”).
  • 2.2 We handle Personal Information for our own business, as
    well as potentially storing Personal Information in our systems on
    behalf of our users.
  • 2.3 This Privacy Policy does not apply to information we
    process about businesses or companies, but does apply to information
    about the people in those businesses or companies.
  • 2.4 The Privacy Policy applies to all forms of information,
    physical and digital, whether collected or stored electronically or in
    hardcopy.
  • 2.5 If, at any time, an individual provides Personal
    Information or other information about someone other than himself or
    herself, the individual warrants that they have that person’s consent to
    provide such information for the purpose specified.

3 THE INFORMATION WE PROCESS

  • 3.1 In the course of business it is necessary for us to
    process Personal Information. This information allows us to identify who
    an individual is for the purposes of our business, contact the
    individual in the ordinary course of business, transact with the
    individual and otherwise pursue our legitimate interests (where such is
    not overridden by your interests or fundamental rights or freedoms with
    respect to that Personal Information).
  • 3.2 Without limitation, the following are types of information we may process:
    • 3.2.1. Personal Information. We may process personal details such as an individual’s name, location, nationality and other Personal Information;
    • 3.2.2 Contact Information.
      We may process information such as an individual’s email address,
      telephone number, third-party usernames, residential, business and
      postal address and other information that allows us to contact the
      individual;
    • 3.2.3 Financial Information.
      We may process financial information related to an individual such as
      any bank or PayPal details used to transact with us and other
      information that allows us to transact with the individual and/or
      provide them with our services;
    • 3.2.4 Statistical Information.
      We may process information about an individual’s online and offline
      preferences, habits, movements, trends, decisions, associations,
      memberships, finances, purchases and other information for statistical
      purposes; and
    • 3.2.5 Information an individual sends us or elects to store in the ISG GO.
  • 3.3 We may process other Personal Information about an
    individual, which we will maintain in accordance with this Privacy
    Policy.
  • 3.4 We may also process non-Personal Information about an
    individual such as information regarding their computer, network and
    browser and their IP address.
  • 3.5 The Privacy Standards do not apply in relation to information that is not Personal Information.

4 HOW INFORMATION IS COLLECTED

  • 4.1 Most Personal Information will be collected in
    association with an individual’s use of ISG GO, an enquiry about ISG GO, or
    generally dealing with us. However we may also receive Personal
    Information from sources such as advertising, an individual’s own
    promotions, public records, mailing lists, contractors, staff,
    recruitment agencies and our business partners. In particular,
    information is likely to be collected as follows:
    • 4.1.1 Registrations/Subscriptions.
      When an individual registers or subscribes for a service, list,
      account, connection or other process whereby they enter Personal
      Information details in order to receive or access something, including a
      transaction;
    • 4.1.2 Accounts/Memberships. When an individual submits their details to open an account and/or become a member with us;
    • 4.1.3 Supply. When an individual supplies us with goods or services;
    • 4.1.4 Contact. When an individual contacts us in any way;
    • 4.1.5 Access. When
      an individual accesses us physically we may require them to provide us
      with details for us to permit them such access. When an individual
      accesses us through the internet, we may:
      • 4.1.5.1 collect information using cookies (if relevant – an
        individual can adjust their browser’s settings to accept or reject
        cookies) or analytics services;
      • 4.1.5.2 supplement the information provided to us by the
        user with other relevant data sourced from business partners, including
        company names, phone numbers and social media statistics; and/or
      • 4.1.5.3 Pixel Tags. Pixel tags enable us to contact or otherwise engage with users through a variety of media.
  • 4.2 Where we obtain Personal Information without an
    individual’s knowledge (such as by accidental acquisition from a client)
    and not in accordance with this Privacy Policy, we will delete or
    destroy the information.

5 HOW INFORMATION IS USED

  • 5.1 As a general principle, we will not use any Personal
    Information other than for the purpose for which it was collected, as
    determined by the circumstances in which the information was collected
    and/or submitted.
  • 5.2 We will retain Personal Information for the period
    necessary to fulfil the purposes outlined in this Privacy Policy,
    including as long as your account is active or as needed to provide you
    services, to comply with our legal obligations, to resolve disputes and
    to enforce our agreements.
  • 5.3 Information is used to enable us to operate our business, especially as it relates to an individual. This may include:
    • 5.3.1 The provision of goods and services between an individual and us;
    • 5.3.2 Verifying an individual’s identity;
    • 5.3.3 Automated decision making,
      such as using the domain in an email address to infer the individual’s
      affiliation with a company and to tailor that individual’s experience
      with IMS accordingly;
    • 5.3.4 Communicating with an individual about:
      • 5.3.4.1 Their relationship with us;
      • 5.3.4.2 Our goods and services;
      • 5.3.4.3 Our own marketing and promotions to customers and prospects;
      • 5.3.4.4 Competitions, surveys and questionnaires;
      • 5.3.5 Investigating any complaints about or made by an
        individual, or if we have reason to suspect that an individual is in
        breach of any of our terms and conditions or that an individual is or
        has been otherwise engaged in any unlawful activity; and/or
      • 5.3.6 As required or permitted by any applicable law.

6 WHEN INFORMATION IS DISCLOSED

  • 6.1 We may disclose Personal Information to third parties
    who provide services that enable and enhance our business activities,
    insofar as such disclosure of information is required. Examples of such
    services include:
    • 6.1.1 Payment processing
    • 6.1.2 Providing customer service
    • 6.1.3 Sending marketing communications
    • 6.1.4 Conducting research and analysis
    • 6.1.5 Providing cloud computing infrastructure
  • 6.2 We take reasonable steps to ensure the disclosure of
    Personal Information to any third party, including any entity outside of
    Australia and the European Union, will not be made until that entity
    has agreed in writing that its own data processing activities are not
    inconsistent with the Privacy Standards.
  • 6.3 There are certain circumstances in which we will be required to disclose Personal Information, namely:
    • 6.3.1 where we reasonably believe
      that an individual may be engaged in fraudulent, deceptive or unlawful
      activity that a governmental authority should be made aware of;
    • 6.3.2 as required by any applicable law; or
    • 6.3.3 in order to sell our business or assets (in which case we may need to transfer Personal Information to a new owner).
  • 6.4 Except as otherwise provided for in this Privacy Policy,
    we do not sell, rent or share Personal Information with third parties
    without your prior consent.

7 RIGHTS TO INFORMATION

  • 7.1 Individuals have a number of rights that may be
    exercised in relation to their Personal Information subject to
    exceptions and limitations provided for in the Privacy Standards.
  • 7.2 Individuals have a right to confirm whether ISG is
    processing their Personal Information and, if so, obtain access to that
    information as well as information concerning:
    • 7.2.1 the purposes of the processing;
    • 7.2.2 the categories of relevant data;
    • 7.2.3 the recipients or categories of recipients to whom the data have been or will be disclosed;
    • 7.2.4 the envisaged period over which the data will be stored or, if not possible, the criteria used to determine this; and
    • 7.2.5 the existence of any
      automated individual profiling, including the logic involved and the
      significance or envisaged consequences of this.
  • 7.3 Individuals have a right to object to certain processing
    operations on their Personal Information on legitimate grounds, and
    thus cause us to cease such processing.
  • 7.4 Individuals have a right to have inaccurate Personal
    Information rectified, incomplete Personal Information completed, and
    otherwise have their Personal Information erased.
  • 7.5 Individuals have a right to request and receive their
    Personal Information in a structured, commonly-used and machine-readable
    format.
  • 7.6 We will endeavour to act on valid
    requests to exercise these rights within a reasonable timeframe, and in
    any event within 30 days of our receipt of such requests.

8 THE SAFETY & SECURITY OF PERSONAL INFORMATION

  • 8.1 We may appoint a Privacy Officer to oversee the
    management of this Privacy Policy and compliance with the Privacy
    Standards. This officer may have other duties within our business and
    also be assisted by internal and external professionals and advisors.
  • 8.2 We will take all reasonable precautions to protect an
    individual’s Personal Information from unauthorised access. This
    includes appropriately securing our physical facilities and electronic
    networks.
  • 8.3 The security of online transactions and the security of
    communications sent by electronic means or by post cannot be guaranteed.
    Each individual that provides information to us via the internet or by
    post does so at their own risk. We cannot accept responsibility for
    misuse or loss of, or unauthorised access to, Personal Information where
    the security of information is not within our control.
  • 8.4 We are not responsible for the privacy or security
    practices of any third party (including third parties that we are
    permitted to disclose an individual’s Personal Information to in
    accordance with this Privacy Policy or any applicable laws). The
    collection and use of an individual’s information by such third parties
    may be subject to separate privacy and security policies.
  • 8.5 If an individual suspects any misuse or loss of, or
    unauthorised access to, their Personal Information, they should let us
    know immediately.
  • 8.6 We are not liable for any loss, damage or claim arising
    out of another person’s use of the Personal Information where we were
    authorised to provide that person with the Personal Information.

9 COMPLAINTS AND DISPUTES

  • 9.1 If an individual has a complaint about our handling of their Personal Information:
    • 9.1.1 they should in the first instance address their complaint in writing to us through the contact details below; and
    • 9.1.2 they have the right to submit a complaint to a relevant supervisory authority under the Privacy Standards.
  • 9.2 If we become aware of any unauthorised access to an
    individual’s Personal Information, we will inform them at the earliest
    practical opportunity once we have established what was accessed and how
    it was accessed.

10 CONTACTING INDIVIDUALS

  • 10.1 From time to time, we may send an individual important
    notices, such as changes to our terms, conditions and policies and
    changes affecting our services. Because this information is important to
    the individual’s interaction with us, they may not opt out of receiving
    these communications.

11 CONTACTING US

  • 11.1 All correspondence with regards to privacy should be addressed to:
    • The Privacy Officer
    • ISG, LLC
    • 12298 Selma Road
    • Middlesex, NC 27557
    • USA

You may contact the Privacy Officer by email in the first instance.

12 CHANGES TO THIS POLICY

  • 12.1 We may do things in addition to what is stated
    in this Privacy Policy to comply with the Privacy Standards, and nothing
    in this Privacy Policy shall deem us to have not complied with the
    Privacy Standards.

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