At Flintfox, we take your privacy very seriously. This Policy is designed to tell you how we collect and use “personal information” (as defined below) so you can make an informed decision about using our Site. Please read this statement before using our Site or submitting any personal information to us. We reserve the right to change the provisions of this Policy at any time, but we will alert you that changes have been made by indicating on the Policy the date it was last updated. Your use of the Site following the posting of such changes or revised policy shall constitute your acceptance of any such changes and your consent to the sharing of any personal information as described in the revised Policy, whether such personal information was collected prior to or following such revisions. We encourage you to review this Policy whenever you visit any of our Site to make sure that you understand how any personal information you provide will be used.
What is personal information?
As used herein, the term “personal information” means information that specifically identifies an individual (such as a user’s name, address, telephone number, e-mail address, credit card or other account number) or that is associated with an identifiable person (such as demographic information or information about a person’s activities when such information is linked to personally identifying information). Personal information does not include “aggregate” information, which is data we collect about the use of the Sites or categories of Site users, from which any personal information has been removed. For example, information that forty-seven percent of the Site’s registered users identify themselves as male, but without identifying any specific individuals as male, is aggregate information. We collect aggregate data for a number of purposes, including to help us understand trends and user needs so that we can better consider new publications, products and services, and tailor existing publications, products and services to user desires. This policy in no way limits or restricts our collection of aggregate information.
What personal information do we collect?
Personal information may be collected in a number of ways when you visit our Site. At several places on our Site, we may collect certain personal information you voluntarily provide to us. For example, if you register for the Site, download our content, send us an email, respond to a survey, register for an event, submit a comment or apply for a job through the Site, we may collect personal information such as your name, address, phone and email and other contact information, as well as demographic and other personal information. Personal information may also be collected if you provide it in connection with participating in forums or other interactive features of the Site.
We also collect information using ‘Cookies’. You can find out more about this in the ‘Cookies’ section below.
How do we use the personal information we collect?
In general, we use personal information we collect to facilitate your use of the Site, to process your requests or transactions, to provide you with information, products and services you request, and for the purposes for which the information was provided. We may also use personal information to inform you about other products, services, documents, publications, information, promotions and events we think will be of interest and to administer and assist us with the operation of the Site and of our business.
We may also receive information from third parties with whom we have business relationships, and may combine this information with the other personal information we have about you. In such cases, this Policy governs our use and disclosure of such information. You may opt out of having us use your personal information for marketing purposes as set forth below under “What choices do you have regarding the use of your information?”
We have set out further details as to the way in which we use your personal information, and our lawful basis for doing so, below:
|Personal Information used||Purpose||Lawful basis|
|Business contact information, such as your name, job title, phone number, email address and other contact information.||To send you a welcoming email and to contact you about your use of the Site, such as for administrative purposes or to provide you with customer service.||Consent|
|To request feedback and to enable us to develop, customise and improve the Site and our publications, products and services.||Legitimate Interests|
|To provide you with the services, products or information you requested and to complete any transactions in connection therewith.||Consent; Contractual Necessity|
|To respond to your emails, submissions, comments, requests or complaints.||Consent|
|To contact you about our products, services, training, activities promotions or special events or offers and for other marketing, informational, product development and promotional purposes.||Consent; Legitimate Interests|
|To notify contest winners.||
|For the specific purpose for which the information was provided.||
Consent; Legitimate Interests; Contractual Necessity
|Log and usage data as well as data from support queries (for instance, diagnostic, usage, and performance information collected when you use our Site. This may include the Internet Protocol (IP) address, your location, device information, browser type and settings and information about your activity on the Site (such as the date/ time stamps associated with your usage). This may also include instances where you have received IT support with the Site’s functionality.)||For the management and security of the Site, to provide Site functionality and performance, and to help us improve our Site.||
Where we process your personal information on the basis of ‘Legitimate Interests’, we have balanced your rights and freedoms against our interests, or those of any third parties, and determined your rights are not infringed. Legitimate Interest is where your personal data is processed for either our own interests or the interests of third parties. This can include commercial interests, individual interests or broader societal benefits.
Who do we share your information with?
From time to time, we need to share your personal information with third parties, for example, with:
- Suppliers, including those who help us to manage the Site and other IT systems, or who send marketing emails on our behalf.
- Third parties providing professional services to us (for instance, our auditors or legal advisors).
- Law enforcement bodies, government agencies, regulators, courts, where we are required or permitted to do so.
Where we share your personal information with third parties, we take steps to ensure that they protect your personal information and treat it carefully.
Your personal information may also be transferred to other third parties (where permitted under applicable law) if we sell, merge, purchase or transfer any part or all of our business or assets.
What steps do we take to protect your information online?
We endeavour to secure your personal information from unauthorised access, use or disclosure by putting into place appropriate procedures to safeguard the information we collect through this Site. For example, your account information is accessible online only through the use of a password and access to passwords are restricted to appropriate personnel. Please be aware, however, that despite our efforts, no security measures are perfect or impenetrable. To protect the confidentiality of your personal information, you must keep your password confidential and not disclose it to any other person. You are responsible for all uses of the Site by any person using your password. Please advise us immediately by emailing us at firstname.lastname@example.org if you believe your password has been misused. You should also note that email is not secure, and you should not send any confidential or sensitive information to us via an unsecured email.
We endeavour to secure your personal information by encrypting the Site and using secure, encrypted platforms to store your personal information.
Where do we store your personal information?
We store your personal information in New Zealand. This means that we may transfer your personal information from the United Kingdom and/or the European Union to servers or databases inside New Zealand (which has been deemed ‘Adequate’ by the European Union and the United Kingdom). Please note that data may also be stored on multiple servers and so multiple locations, including third-party server providers such as Microsoft Azure Cloud, Marketo and D365. Data stored on the Azure Cloud will be kept on servers located in New Zealand, Australia or North America.
Regardless of where your personal information is stored, we treat all personal information in line with applicable law, and this Policy.
What choices do you have regarding the use of your information?
You may “opt out” of receiving marketing or promotional communications from us or from having us share personal information with our marketing partners by emailing us at email@example.com or updating your preferences on our subscriptions page.
Your Data Rights
Depending on your location, you may also have the following rights
- Right to access and/or correct your personal information: You have the right to request access to a copy of the personal information we hold about you. You also have the right to request correction of any information we hold about you that is inaccurate.
- Right to request deletion of your personal information: You have the right to request that we delete your personal information, particularly where we no longer need to retain it. You may also delete certain information by closing your account.
- Right to withdraw your consent: You can withdraw your consent at any time (although it is important to note that withdrawing consent does not affect our use of your personal information before that point).
In addition, Site visitors in the UK and EU may specifically have the following rights:
- Right to object to our use of your personal information: For instance, you may object to our use of your personal information for marketing purposes, and you can request that we stop using your personal information for this purpose.
- Right to restrict our use of your personal information: For instance, if you believe that personal information we hold about you is inaccurate, you can request that we do not use your personal information until we have verified the accuracy or corrected your personal information.
- Right to request data portability: You can request that we transmit to another organisation all personal information you have provided to us in a structured, commonly used, and machine-readable format, where technically feasible.
If you wish to exercise the rights described above (if they are applicable to you, based on your location), please contact us at firstname.lastname@example.org. Please note that we may not always be in a position to comply with your request. In certain circumstances, we may not be able to remove or change certain information, even in the event an account is closed. For example, we may be required to retain certain information, such as credit card billing information, for a certain period of time, and it may be necessary to retain certain information in order to complete any services or transactions with us.
Finally, you have the right to complain to the data privacy regulator in the country where you live.
How long will your personal information be stored for?
We will retain your personal information for as long as required to perform the purposes for which the data was collected. For instance, if we are providing you with services, we will retain your personal information for the duration of our relationship with you. For example, we may be required to retain certain information, such as credit card billing information, for a certain period of time, and it may be necessary to retain certain information in order to complete any services or transactions with us.
In addition, we may be required to retain personal information in order to comply with tax and company laws and regulations, as well as statute of limitation periods.
In some instances, you may also withdraw your consent from us keeping your personal information or request deletion of your personal information gathered from the Site, and we may delete data on that basis (See the ‘’What choices do you have regarding the use of your information?’’ section above’).
What are cookies?
Cookies are small data files that are stored on a user’s hard drive at the request of a Web site to enable the site to recognise users who have previously visited them and retain certain information such as customer preferences and history. When you visit our Site, some information is automatically collected through the use of log files, such as your computer’s Internet Protocol (IP) address, your computer’s operating system, the browser type, the address of a referring web site and your activity on the Site. We use this information for purposes such as analysing trends, administering the Sites, improving customer service, diagnosing problems with our servers, tracking user movement, and gathering broad demographic information for aggregate use. We also automatically collect certain information through the use of “cookies.”
We use the following third party analytics and advertising features on our Site:
Google Analytics to enable data collection for website performance and Site visitor behavioural analysis;
Google Tag Manager to enable data collection for search and display advertising purposes;
Marketo: We use Marketo cookies so we have information on email ‘’open rates’’ and ‘’click through’’ rates This helps us to assess the effectiveness of our marketing campaigns. We also use Marketo cookies to track activity on our website. For example, if you download ebooks or videos from the Site, we use Marketo cookies to see who does this and if they then visit other parts of our website;
Facebook Pixel: We use the Facebook Pixel to connect data from the Facebook advertising network with actions performed on our Site, in order to track performance and effectiveness of campaigns.
HubSpot to enable data collection and management of personal information for marketing purposes.
This technology allows third-party vendors, including Google, Facebook, HubSpot and Marketo to reconnect with visitors who have already visited our Site to provide targeted Search and Display Network advertising and/or provide a consistent repeat visitor experience. Wherever possible, information generated by these cookies are anonymised as part of these third-party data protection provisions and are not combined by any other data. If we combine cookies with or link them to any of the personally identifying information, we would treat this information as personal information. For example, information collected by Marketo cookies is not anonymised and therefore we treat this as personal information.
However, if a browser is set not to accept cookies or if a user rejects a cookie, this will not alter user experience on the Site.
How can you obtain additional information?
If you have any questions or comments about this Policy or the practices relating to this Site, please contact us at email@example.com, and we will endeavour to respond to your inquiry.
In lieu of email, you may also contact us by mail at the following address:
Flintfox International Limited
Attn: Chief Marketing Officer
5 Omega Street
PO Box 305-499
Updated: January, 2022