Last updated on November 15, 2018
For the purpose of using our platform, we collect and process data of
- Recipients : employees, officers, consultants or contractors , whom the assessment are sent and asked to complete it by their employer, who is an existing client
- Users: people of administrative roles who are in charge of using the platform on behalf of their employers (existing clients)
- Prospects or future users: prospective clients who will be the users of the platform in the future
‘Personal data’ referred to in this policy means any information relating to you (‘data subject’) who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity. This can also be comments or suggestions made by you or about you.
Please read this policy carefully to understand how your personal data is handled and treated at Peergauge. By visiting https.//peergauge.com or using the platform you agree and consent to the activities and data usage mentioned here.
In the case of Recipients and Users, your employer who has entered into an agreement with Peergauge (the ‘Agreement’) to grant you access to the platform and/or to the assessments filled in on or using the Platform will be the data controller of your personal data. We will process your personal data for your employer and in accordance with its lawful instructions. The information you provide us and/or upload to the Platform will also be governed by the employer agreement.
In the case of Prospects, we are the data controller of your personal data.
We are also the data controller of contact information for each client contact held for account and contract management purposes, including contract queries and billing. The ‘employer’ shall refer to the entity/organisation that entered into the Agreement with us.
What kind of information do we collect?
We collect the following data about you, depending on your use of our Site and/or Platform:
For Recipients and Users,
- you may give us information about you:
when using the Platform in order to fill forms and assessments on or through the Platform in which the extent of information collected is set by your employer. This may include your name age, company email address, contact number, job title, seniority level, department, date of joining, primary office location as well as any opinions you provide us about you, your performance, your employer, your colleagues or third parties during the course of completing the engagement assessments or using the Platform.
When you contact us, e.g., for the support we provide, we may keep a record of that correspondence directly or through our service providers.
- your employer may give us information about you
when a user profile is created for you in order to access the Platform under the Agreement, for trial or full, or to enable us to send engagement assessments and other communications, informations like your name, age, company email address, contact number, job title, department, joining date, office location etc.
Or otherwise in the course of your employer’s use of the Platform.
- Information we automatically collect about you every time you use the Platform or complete an engagement assessment
we keep a record of the usage details including date, time, location, frequency and duration of usage;
if you are a User, using the Platform on behalf of your employer, we may get further information from your employer (e.g. verify your eligibility to access the Platform);
any comments and/or feedback you provide us regarding the Platform or
technical information about your computer or mobile device for system administration and analysis, IP address, URL clickstreams, unique device identifiers, Operating System, network and browser type.
Information about your use of the platform such as pages viewed, duration spent on the Platform and data files you have uploaded to the Platform.
- Information from other sources we receive from the third parties
We work closely with third parties for example, business partners, other companies within our group, subcontractors and analytics providers and may receive information about you from them. Details of third party providers are set out in the section below entitled “Information Disclosure”.
For Prospects/Future Users,
we collect personal data that you provide us when you complete a form in website or sign up for a trial or contact us to request information about our products and services. Informations include your name, employer, work email address, work telephone number and other publically available information such as seniority, years of experience, employment history and similar work-related background from third party service providers who give contact enrichment and lead generation to us.
How your Personal Data is used/treated?
Please note that we are allowed to collect, use, disclose and/or process any information other than personal data, including data sets you upload to the Platform or otherwise provide to us, to the fullest extent permitted by the Employer Agreement.
For recipients and users,
The information you give to us will be used to process your application to become a registered user;
provide your employer with analysis and reports with insights and summarised information during your use of the Platform, including any engagement surveys, combined with information from other employees and personnel, and comparing this data with past or future employee responses and/or industry benchmarks. All survey responses are entirely optional: individual questions or the entire survey may be skipped and there is no requirement for any surveys to be completed;
provide you with information, products and services you request from us. You will not be contacted for promotional/marketing purposes, such as to inform you of new products or services that we offer, unless you specifically consent to this at the time you provide your details to us or you expressly request (or provide explicit consent for) us to do so at a later date;
contact you for your feedback on our services and to help us evaluate and improve our services;
notify you about changes to the Platform and any other services of ours that you use, for e.g., new versions of the Platform and about new features, functionality and service offerings; or
deal with any enquiries, correspondence, concerns or complaints you have raised, or that have been raised by or concerning third parties (such as your employer) involving you and any issues caused by your use of the Platform.
Information we collect about you will be used to administer and improve the Platform and other services, including ensuring that content is presented in the most effective manner for you and for your computer;
to report to your employer relating to the use of the Platform, as may be required under the Employer Agreement;
for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
to allow you to participate in interactive features of the Platform, when you choose to do so;
as part of our efforts to keep the Platform safe and secure; or
to compile reports (which do not personally identify you) of usage of the Platform.
Information we receive from other sources. We may combine information from other sources with the information you give to us or we collect about you and use this information as specified above.
We shall also process your personal data to enable us to perform obligations as per the Agreement, to improve/optimise our services, to ensure security of our systems, to know how the Platform is used and to improve the user experience of the Platform, to protect our legal rights, troubleshooting, data analysis, testing and research purposes. We will not take forward any survey/ analysis to any special categories of personal data such as, ethnicity, religious beliefs, genetic/biometric data, health data, sex life or orientation unless its is requested/set by your employer with explicit consent from you. By providing these data to us without being requested, will be considered as consented to its processing.
Please note that your identity will not be revealed to your employer other than in exceptional circumstances, as explained in the section entitled “Information Disclosure”.
Data collected from you and other employees may be used by us in an anonymised form for benchmarking and/or statistical purposes such as comparisons to other organisations within the same industry.
In case of the Prospect/Future Users,
we will collect and use data to contact you of about our news, updates, events, developments, products and services from time to time and for the purposes of entering into discussions with you in connection with your purchase of licences from us to use or have access to the Platform. This data is processed by us on the basis that it is necessary for the purposes of our legitimate interests, namely undertaking targeted marketing and business development activities in connection with our business.
We may share your personal data in the course of undertaking marketing activities and to third parties such as IT service providers, business partners, suppliers, sub-contractors for better performance based on the Agreement entered, such as:
- Microsoft Corporation who provide cloud hosted infrastructure and services used by us to operate the Platform as a hosted solution;
- Google LLC, Drift.com, Inc. who provide product tools and functionality used by us in delivery of the Platform and associated services; and
- Hubspot, Inc and Sendgrid, who provide CRM management and e-mail delivery services.
- Paddle Inc, who provide us with payment methods.
Analytics and search engine providers that assist us in the improvement and optimisation of our marketing activities and the analysis of data supplied via the Platform for contact enrichment and lead generation purposes, including Google Analytics, LinkedIn, Facebook and Twitter; and government or other law enforcement agencies, in connection with the investigation of unlawful activities or for other legal reasons (this may include your location information).
We require all third party services to take security measures to protect your personal data and not to use it for their own purposes. We may disclose your personal data to prospective or actual buyer, seller or investor if we receive investment or buy/sell business assets, in case of an acquisition or to legal advisors if they need this data to advise us on legal rights and obligations. If we are under a duty to disclose your personal data to comply with any legal obligation, or in order to enforce/apply our Terms and Conditions or other contracts between us and you or your employer; or to protect our rights, property or safety or of our customers or others.
If you are a Recipient, your feedback and comments provided during engagement assessments are collected and reported to your employer in an aggregated/anonymised form. As such, your anonymity as a Recipient is protected by default.
If we receive a request from your employer to disclose your identity or if we consider it appropriate to disclosure your identity in the absence of such a request. We will consider this in accordance with our internal policy on revealing identity, which will in general only be disclosed to your employer where it is necessary to do so for valid reasons. This is only likely to occur in exceptional circumstances such as physical, mental, emotional and self harm risks or detect unlawful acts.
Other than explained above, your personal data will not be disclosed to any third parties for any other purpose unless there is a legal right or obligation to do so.
International data transfers
Since some of our service providers are based outside of the ‘European Economic Area’, we may transfer your personal data to them to provide our services via the Platform or to perform marketing activities, ensuring that your data is treated by these parties respection the EU data protection laws.For further information about these protective measures, please contact us at [email protected].
In order to complete an assessment, you will not normally require a username or password to gain access to the Platform. Where we have given you a username, password and/or security information which enables you to access particular features of the Platform (for example, as an administrator or senior manager of your employer), you are responsible for keeping these access credentials confidential. You must not share these details with anyone, or store them in a way that may allow a third party to access them. Please see the Terms and Conditions. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted via internet to the Platform and you acknowledge that any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access or disclosure, which may include two factor authentication and end-to-end encryption.
Where consent is required for our use of your personal data, by ticking the consent box or otherwise communicating your consent to us (whether by phone, email or other), you consent to our use of that personal data as set out in this policy. If you disclose someone else’s personal data to us, you confirm that you have their consent and for us to use and disclose it in accordance with this policy.
Retaining your information:
Your personal data will not be stored for longer than is reasonably necessary to use it in accordance with this policy or with our legal rights and obligations. But, aggregated and anonymised data and any information other than personal data can be stored indefinitely.
For Recipients and Users, we will retain your personal data for a period of 5 years or until six months after our relationship with your employer has ended (whichever is sooner) and deleted after this.
For Prospect user, your personal data will be stored for a period for so long as necessary to continue to provide you with updates or other marketing emails or communications in circumstances in which you have consented (where necessary) or else not unsubscribed to receiving such communications, in which we have a continued interest in undertaking that marketing.
What are your rights and obligations?
You are entitled to:
Access to your Data
In particular to: (i) request information about the purpose of their processing, (ii) categories of processed Data, (iii) identifying the recipient to whom the Data are to be provided, and (iv) duration of processing and collecting your Data.
Correction of your Data
You have the right to request if we are processing incorrect data about you to inform us about this matter and we shall correct such uncorrect data without undue delay.
Erasure of your Data (Right to be forgotten)
Restriction of Data processing
You have the right to restriction of your personal data processing if: (i) the accuracy of your data is contested by you for a period which shall enable us to verify the accuracy of your data, (ii) the processing of your data is unlawful and you request restriction of such data use instead of erasure.
You are entitled to receive your personal data processed by us in a structured, commonly used and machine-readable format for the purpose of transmitting such data to another data controller.
Object Data processing
You have the right to object the processing of your data based on the grounds of legitimate interest, marketing purposes, profiling related to direct marketing.
Change of Preferences
You can change your data processing preferences at any time. For example, if you have given your consent to direct marketing, you can opt out of receiving marketing communications later by emailing us at [email protected] or clicking the relevant link in any communication you receive.
Lodge a complaint with a supervisory authority
If you consider that your rights relating to the processing of your data have been infringed you have the right to lodge a complaint with a supervisory authority.
You will not have to pay a fee to access your personal data but, if your request is excessive or unfounded. We may request specific information from you to confirm your identity and right to restrict or stop processing or delete personal data or direct marketing.
For more information or further queries please contact our Data Protection Officer (DPO) at [email protected]