Privacy Policy

SlaveCheck Pty Ltd ACN 634 863 433 (SlaveCheck, we, us, our) respects your right to privacy. This privacy policy explains who we are, how we collect, share and use personal information about you, and how you can exercise your privacy rights. This Privacy Policy applies to personal information that we collect from you, or you provide to us, when you engage with SlaveCheck or our websites, including at www.slavecheck.com and any SlaveCheck subdomains used for products and services (‘Websites’).

If you have any questions or concerns about our use of your personal information, then please contact us using the contact details provided at the bottom of this Privacy Policy.

By using our Websites, subscribing to our products and services, clicking “I agree” (or similar), or using a SlaveCheck product, you acknowledge that you have read and agree to this privacy policy, the website terms, the general terms and conditions and the data processing addendum (each to the extent applicable).

1. What does SlaveCheck do?

SlaveCheck’s purpose is the evidencing, remediation and monitoring of modern slavery (‘Purpose’). SlaveCheck pursues this Purpose via a technology-led, two-part 'profit for purpose’ business model, generating profits from companies using its SaaS platform to simplify and automate modern slavery compliance and reporting; and reinvesting profits into providing technology infrastructure and support at no cost to assist NGOs and other modern slavery stakeholders to lead, coordinate and manage the global collaborations necessary to eliminate modern slavery.

2. What personal information does SlaveCheck collect and why?

The personal information that we may collect about you broadly falls into the following categories. If you don’t provide us with personal information, we are unlikely to be able to provide you with our products and services.

Information that you provide voluntarily

The information we collect from you through our Websites in connection with virtual and in-person events and through correspondence with you, including but not limited to the following:

• your name, email address, phone number, job title, company name and location;
• information you include within any enquiry or request you make to us;
• information about yourself which you provide in correspondence with us; and
• comments and information about yourself which you submit to public areas of our Websites.

We use this information to pursue our Purpose and to:

• conduct our business, including to provide you with information, products or services that you request from us;
• manage products and services we provide to you/your company or products/services you/your company provide to us;
• carry out our obligations under any contracts entered into between you/your company and us; and
• manage our relationship with you/your company;
• improve and optimise our platforms (including our Websites) and products and services;
• conduct internal administrative, research, planning, marketing and product development activities; and
• comply with legal obligations;
• provide you with information or advertising relating to our products or services (including targeted advertisements) or marketing communications we believe may be of interest to you

Information that we collect automatically

When you visit our Websites, we may collect certain information automatically from your device. In some countries, including the United Kingdom (UK) and countries in the European Economic Area (EEA), this information may be considered “personal data” or “personal information” under applicable data protection laws.

Specifically, the information we collect automatically may include information like your IP address, login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform and other technical information. We may also collect information about how your device has interacted with our Websites, including the pages accessed and links clicked. This includes the date and time, products you viewed or searched for, page response times, download errors, length of visits, and page interactions.

We collect this information to:

• administer our Websites and for our internal operations, including troubleshooting, data analytics, testing, research, statistical and survey purposes;
• improve our Websites to ensure the content is presented in the most effective manner for you and for your device;
• allow you to participate in interactive features of our service, if you choose to do so;
• assist in our efforts to keep our Websites safe and secure;
• measure or understand the effectiveness of advertising we serve and deliver relevant advertising to you;
• make suggestions and recommendations to you about goods or services which may be of interest to you.

We may also use this information for any other purpose set out in this privacy policy. Some of this information may be collected using cookies and similar tracking technology, as explained further under the heading “Cookies and similar tracking technology” below.

Information that we obtain from third party sources

From time to time, we may receive personal information about you from third party sources (including our business partners, technical, payment and delivery service contractors, advertising networks, analytics providers, search information providers and credit reference agencies), but only where these third parties have confirmed to us that they either have your consent or are otherwise legally permitted or required to disclose your personal information to us. We use this information to maintain and improve the accuracy of the records we hold about you and to send you personalized content. We may also use this information for any other purpose set out in this privacy policy.  We are not responsible or liable for such third parties use of your personal information, which may be subject to their own privacy policies, as applicable.

We will combine this personal information with personal information we already hold about you and use this combined information for the purposes set out above.

3. Who does SlaveCheck share my personal information with?

Client Information relating to modern slavery status of its supply chains

All data and information relating to a subscribing client’s supply chain and its modern slavery status - collected by SlaveCheck under Clause 2 for the Purpose - remains the confidential property of the Client. How the Client chooses to make use of the data and information; what they decide to include or not to include in annual modern slavery statements or other communications to their stakeholders; the format and timing of that disclosure; and whom they choose to share the data and information with; is at the sole and exclusive discretion of the Client.

For clarification, SlaveCheck could be described as a ‘messenger’ service. SlaveCheck collects, analyses and relays modern slavery data and information to where Clients intend it to go but SlaveCheck does not perform any policing, law enforcement or whistle-blowing function and at no time does SlaveCheck share or make public any supply chain or modern slavery status data unless expressly authorised to do so by the Client. For more information refer to the SlaveCheck General Terms and Conditions.

Information sharing in order for SlaveCheck to provide the Products and Services

Notwithstanding the above, we may disclose your supply chain, modern slavery status and personal information to the following categories of recipients in order in order to fulfil any of the purposes set out in section 2 of this privacy policy:

• within our group companies;

• to our third party services providers and partners including but not limited to those who provide data processing or other technology services to us (for example, businesses providing information processing; to provide customer service; to conduct customer research, satisfaction surveys and marketing activities, to support the delivery of, provide functionality on, or help to enhance the security of our Websites), or who otherwise process personal information for purposes that are described in this Privacy Policy or notified to you when we collect your personal information.

• to any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, including to enforce our terms of use or any other agreements or (iii) to protect your vital interests or those of any other person;

• to an actual or potential buyer (and its agents and advisers) in connection with any actual or proposed purchase, merger or acquisition of any part of our business; and/or

• to any other person with your consent to the disclosure (to the extent required by applicable law).

4. Legal basis for processing personal information

Relevant to each of the EEA and UK’s General Data Protection Regulation (together, the GDPR), our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.

However, we will normally collect personal information from you only (i) where we need the personal information to perform a contract with you, (ii) where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms, or (iii) where we have your consent to do so. In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person.

If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).

If we collect and use your personal information in reliance on our legitimate interests (or those of any third party), this interest will normally be to operate our Websites and communicate with you as necessary to provide our services to you and for our legitimate commercial interest, for instance, when responding to our queries or improving our Websites. We may have other legitimate interests and if appropriate we will make clear to you at the relevant time what those legitimate interests are.

If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided under the “How to contact us” heading below.

5. Cookies and similar tracking technology

We may use cookies and similar tracking technology (collectively, “Cookies”) to collect and use personal information about you, including to serve interest-based advertising. For further information about the types of Cookies we use, why, and how you can control Cookies, please see our Cookie Notice.

6. How does SlaveCheck keep my personal information secure?

We use various technical and organisational measures to protect the personal information that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information.

Specific measures we use include (amongst others):

• physical security and access to all SlaveCheck premises
• all access to computer hardware is password protected, with encryption and default security firewalls in place;
• transfers of data between your device and our servers are encrypted using SSL and TLS encryption protocols;
• staff access controls to personal information;
• security standards consistent with Payment Card Industry Standard (PCI DSS) for which we are globally certified and undertake annual audits;
• staff data protection training.

As with any content that is published on the Internet, any content, including personal information, that you contribute to be shared, published or transmitted to other users of our Websites, is visible to other users and can be read, collected, or used by them. We urge you to be careful about giving out information in public areas of our Websites. Please note that, even after removal, copies of your content, including personal information, that you contribute to be shared, published or displayed on our Websites, or transmitted to other users of our Websites, may still remain viewable in cached and archived pages, and may have been saved by other users.

7. International data transfers

Your personal information may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country.

Our group companies and third party service providers and partners operate in Australia and around the world. We have taken appropriate safeguards to require that your personal information will remain protected. For example, we implement Standard Contractual Clauses for transfers of personal information between our group companies, which require all group companies to protect personal information they process which is received from the UK or EEA in accordance with UK and/or European Union data protection law, as applicable.

Our Standard Contractual Clauses can be provided on request.

8. Data retention

We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements).

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

9. Access and correction

We will take all reasonable steps to ensure any personal data we collect, use or disclose is up to date and accurate. If you believe personal information that we hold about you is not up to date or accurate, you may ask us to correct it.

You may ask us to provide you with details of the personal information we hold about you, and copies of that information. We will respond to your request and attempt to provide you with the data within 30 days of receipt of your request.

If we provide you with copies of the information you have requested, to the extent permitted by law, we may charge you a reasonable fee to cover the administrative costs of providing you with that information.

Please direct all request for access and correction to us using the details set out under the “How to contact us” heading below.

10. Marketing

You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact us using the contact details provided under the “How to contact us” heading below.

11. Your data protection rights

Where you are located in the UK or EEA, you have additional data protection rights, including as follows.

• To request deletion of your personal information in certain circumstances. You can also request that we restrict or suspend the processing of your personal information . If you do so, note that we will then most likely be unable to provide our goods and services to you.

• To object to processing of your personal information, including to ask us to restrict processing of your personal information or request portability of your personal information. Again, you can exercise these rights by contacting us using the contact details provided under the “How to contact us” heading below.

• To withdraw your consent to the extent at any time we have collected and process your personal information with your consent. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.

For more information, please contact your local data protection authority.

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. If you wish to exercise any of these rights, please contact us using the contact details provided under the “How to contact us” heading below.

12. How SlaveCheck handles complaints

All complaints regarding SlaveCheck’s handling of personal information under this Policy and/or Australian Privacy laws should be made by email in the first instance to: privacy.officer@slavecheck.com

Otherwise in writing to:

The Privacy Officer
SlaveCheck Pty Ltd
43 Figtree Avenue
Randwick NSW 2031 Australia

When SlaveCheck receives a complaint, we will acknowledge receipt of that complaint within 30 days. In the event that we cannot resolve a complaint within a reasonable time thereafter, we will provide you with reasons for the delay and the time at which we expect to be able to resolve the complaint.

Additionally, if you are located in Australia you may wish to contact the Office of the Australian Information Commissioner (OAIC) in relation to the handing of your personal information on:

Phone:
1300 363 992

Post:  
Office of the Australian Information Commissioner
GPO Box 5218
Sydney NSW 2001

To the extent you are located in the EEA, you can contact your relevant local data protection authority, which can be located at via the European Data Protection Supervisor and/or this link. UK based individuals may contact their local supervisory authority, the Information Commissioner’s Office (see here).

13. Children’s information

We do not knowingly collect or solicit personal information from anyone under the age of 18. If you are under 18, please do not register in SlaveCheck or send any personal information about yourself without your parent’s or legal guardian’s express consent. If we learn that we have collected personal information from a child under the age of 18 without consent from the parent or legal guardian, we will investigate and delete that information as soon as reasonably practicable.

If you believe that a child under 18 may have provided us personal information, please contact us using the contact information in the ‘How to contact us’ section.

14. Third party links

Our Websites may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

15. Updates to this Privacy Policy

We may update this Privacy Policy from time to time in response to changing legal, technical or business developments. When we update our Privacy Policy, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will provide notice and/or obtain your consent to any material Privacy Policy changes if and where this is required by applicable data protection laws.

This Privacy Policy was last updated at the date displayed at the top of this Privacy Policy.

16. How to contact us

If you have any questions or concerns about our use of your personal information, please contact us using the following details: privacy.officer@slavecheck.com

You can also contact us at:

SlaveCheck Pty Ltd, a company registered in Australia (ACN 634 863 433) with our registered office at 43 Figtree Avenue, Randwick NSW 2000 Australia.

The data controller operating the Websites is SlaveCheck Pty Ltd. Other entities within the SlaveCheck group may also be controllers of your personal information, depending on your location and the type of product or service provided.

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