Global Scalability Audit

Introduction
At FD Global Connections Pty Ltd we are committed to protecting personal data and to fair and transparent processing. Please read our privacy statement: it will help you to understand how we collect and use personal data from our clients, suppliers, sub-contractors or others during the course of our business. We will only use personal data for the purposes described in this privacy statement or as stated at the point of collection. We regularly review this privacy statement and may make changes at any time without giving notice.

Who We Are
FD Global Connections Pty Ltd is an Australian registered company (Australian Business Number: 61 111 381 929). Our registered office is FD Global Connections Pty Ltd 275 Ryedale Street, Ryedale, New South Wales 2122.

This privacy statement only applies to FD Global Connections Pty Ltd. We are not responsible for the privacy practices of any other organisation our website may link to.

Our Lawful Basis for Processing
We rely on several lawful basis of processing when we collect and use personal data to operate our business and provide products and services to our clients. These include:

• Public interests – where the processing of data is necessary for providing certain services to clients for certain requirements we are subject to.
• Legal obligations – in order to comply with the legal and regulatory obligations
• Contract – in order to perform contractual obligations
• Consent – where an individual has freely given consent at the time their personal data was provided to us.
• Legitimate interests – the legitimate interests can be ours, our clients or other third parties (eg to provide our services, to develop or protect our business, or to keep people informed about relevant products and services) and we always balance the rights of individuals with ours’ and others’ legitimate interests.

Our Clients
We only ask our business clients to share personal data with us where it is necessary in order to provide our services or other agreed purposes. We rely on our clients providing any necessary information to the individuals whose data is shared with us regarding its use.

In providing a range of services to our clients, we may need to process the following categories of personal data including name, contact details, job title and employment related information (company name, position, responsibilities).

For our services we do not expect our  business clients to share special categories of personal data (defined as race or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health, genetic data, biometric data, sex life or sexual orientation) and criminal records. Where this is the case we rely on our clients having gained the explicit consent of individuals, it being a legal obligation or other lawful basis.

Typically, we will collect personal data directly from our clients or from third parties acting on their instructions (eg their suppliers).

We use such personal data collected for the following purposes:

–     Providing professional services: we offer many different services to our clients and many of these services require us to process personal data in order to give advice and deliver reports to our business clients.

–     Managing our business: in order to run our business effectively we may need to process personal data for multiple reasons, including managing our client relationships, developing our business and services, hosting events, and to manage and administer our website, IT systems and applications.

–     Quality, risk and security management systems: to protect our information and our clients’ information (including personal data), we use security measures that involve detecting, investigating and resolving security threats. As a part of the security monitoring we do personal data may be processed (eg automated scanning of emails to identify threats). We monitor the services we provide to our clients for quality purposes this may involve processing personal data held on the relevant client file.

–     Providing information about our services: we may use business contact details to provide information about us, our services and activities, including events that may be of interest.

–     Complying with local legal, regulatory or professional obligations.

Suppliers/Contractors
We only process personal data about our suppliers (this includes subcontractors and any individuals associated with them) where it is necessary for us to receive services, contract, manage our relationship and help provide services to our clients (where relevant).

We use personal data in these circumstances for the following purposes:

–     Providing professional services: where a supplier/contractor helps us to deliver services to our clients, we process the personal data of its people involved to help manage our relationship and to deliver those services to our clients.

–     Managing our business: in order to run our business effectively we may need to process personal data for multiple reasons, including managing our client relationships, developing our business and services, hosting events, and to manage and administer our website, IT systems and applications.

–     Quality, risk and security management systems: to protect our information and our clients’ information (including personal data), we use security measures that involve detecting, investigating and resolving security threats. As a part of the security monitoring we do personal data may be processed (eg automated scanning of emails to identify threats). We monitor the services we provide to our clients for quality purposes this may involve processing personal data held on the relevant client file.

–     Providing information about our services: we may use business contact details to provide information about us, our services and activities, including events that may be of interest.

–     Complying with legal, regulatory or professional obligations.

Clients or Prospective Client Contacts
Using a customer relationship data management system, we process personal data about contacts, these are existing clients, prospective clients and individuals connected with them. This personal data will usually include name, employer identity, job title and business contact details.

Typically, we will collect the personal data directly from the individuals themselves or from public sources such as public registers, social media and professional networking sites, news articles and internet searches.

Such personal data will be accessible and used for the following purposes:

• Developing, managing and administering our business
• Providing information about us and the services we provide
• Identifying the business needs of our clients or prospective clients
• Performing analytics, including producing metrics for our leadership, such as on trends, relationship maps, sales intelligence and progress against account business goals
• Analysing interactions between our people and our contacts to provide information to our management on relationships and trends, including the use of an automated analytical tool to evaluate the frequency and timing of interactions with contacts.

Unless we have the consent of the individual we do not sell or otherwise release any personal data collected for purposes above.

Cookies

What is a cookie?
A cookie is a small piece of data or message that is sent from an organisation’s web server to your web browser and is then stored on your hard drive. Cookies can’t read data off your hard drive or cookie files created by other sites, and do not damage your system.

However, you can reset your browser so as to refuse any cookie or to alert you to when a cookie is being sent. Web browsers allow you to control cookies stored on your hard drive through the web browser settings. To find out more about cookies, including what cookies have been set and how to manage and delete them, visit http://www.allaboutcookies.org.

At FD Global Connections Pty Ltd we only use cookies to monitor the performance of our website and to improve user experience.

If you choose not to accept our cookies, some of the features of our site may not work as well as we intend.

How We Keep Data Secure
Security is of the upmost importance to us. Whilst no data transmission over the internet or any other network can be guaranteed as 100% secure, we take all reasonable steps to safeguard the personal data we hold and we have in place appropriate technical and organisational measures.

Who We Share Data With
We only share personal data with others when absolutely necessary for the purposes for which we hold it and where appropriate contractual arrangements and security mechanisms are in place. We may pass your personal data to:
– suppliers that support us and help provide services to our clients, such 3^rd party contractors, providers of cloud-based software, IT systems, security, archiving storage, recruitment, marketing and payment services
– law enforcement or other government and regulatory agencies or to other third parties, where we are required by law, the courts or any legal or regulatory authority we are subject to. We will only provide personal data in this circumstance where permitted or there is a legal requirement.

How long do we keep personal data?
We keep personal data only for as long as necessary and this will reflect the requirements of:

• the activity or service for which it is being processed
• any legal, regulatory or contractual requirements
• the time in which any litigation or investigations might arise from providing a service.

Individuals’ rights
Individuals have certain rights over their personal data that we process as data controllers.

If we process your personal data and you exercise any of your rights we will aim to respond promptly and within any required time limit. However, please note that the length of time it will take us to respond will be dependent on the nature and extent of your request. You have a right to:

• access – you can ask us for a copy of the personal data that we hold on you
• rectification – if you become aware of any errors or inaccuracies concerning your personal data, please let us know by contacting us
• withdraw consent – where we process personal data based on consent, you have a right to withdraw consent at any time. To stop receiving direct marketing emails from please click on the “unsubscribe” link on such emails. For any other withdrawals of consent please contact us
• erasure/deletion- you can ask us to erase or delete your personal data when we no longer need it for the purposes it was obtained
• unsubscribe – you can ask to restrict or object to our processing of your personal data (eg removal from a marketing subscription list).

LIABILITY DISCLAIMER
THE INFORMATION, SOFTWARE, PRODUCTS, AND SERVICES INCLUDED IN OR AVAILABLE THROUGH THE FD GLOBAL CONNECTIONS WEB SITE MAY INCLUDE INACCURACIES OR TYPOGRAPHICAL ERRORS. CHANGES ARE PERIODICALLY ADDED TO THE INFORMATION HEREIN. FD GLOBAL CONNECTIONS AND/OR ITS SUPPLIERS MAY MAKE IMPROVEMENTS AND/OR CHANGES IN THE FD GLOBAL CONNECTIONS WEB SITE AT ANY TIME. ADVICE RECEIVED VIA THE FD GLOBAL CONNECTIONS WEB SITE SHOULD NOT BE RELIED UPON FOR PERSONAL, MEDICAL, LEGAL OR FINANCIAL DECISIONS AND YOU SHOULD CONSULT AN APPROPRIATE PROFESSIONAL FOR SPECIFIC ADVICE TAILORED TO YOUR SITUATION.

FD GLOBAL CONNECTIONS AND/OR ITS SUPPLIERS MAKE NO REPRESENTATIONS ABOUT THE SUITABILITY, RELIABILITY, AVAILABILITY, TIMELINESS, AND ACCURACY OF THE INFORMATION, SOFTWARE, PRODUCTS, SERVICES AND RELATED GRAPHICS CONTAINED ON THE FD GLOBAL CONNECTIONS WEB SITE FOR ANY PURPOSE. TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, ALL SUCH INFORMATION, SOFTWARE, PRODUCTS, SERVICES AND RELATED GRAPHICS ARE PROVIDED “AS IS” WITHOUT WARRANTY OR CONDITION OF ANY KIND. FD GLOBAL CONNECTIONS AND/OR ITS SUPPLIERS HEREBY DISCLAIM ALL WARRANTIES AND CONDITIONS WITH REGARD TO THIS INFORMATION, SOFTWARE, PRODUCTS, SERVICES AND RELATED GRAPHICS, INCLUDING ALL IMPLIED WARRANTIES OR CONDITIONS OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, TITLE AND NON- INFRINGEMENT.

TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, IN NO EVENT SHALL FD GLOBAL CONNECTIONS AND/OR ITS SUPPLIERS BE LIABLE FOR ANY DIRECT, INDIRECT, PUNITIVE, INCIDENTAL, SPECIAL, CONSEQUENTIAL DAMAGES OR ANY DAMAGES WHATSOEVER INCLUDING, WITHOUT LIMITATION, DAMAGES FOR LOSS OF USE, DATA OR PROFITS, ARISING OUT OF OR IN ANY WAY CONNECTED WITH THE USE OR PERFORMANCE OF THE FD GLOBAL CONNECTIONS WEB SITE, WITH THE DELAY OR INABILITY TO USE THE FD GLOBAL CONNECTIONS WEB SITE OR RELATED SERVICES, THE PROVISION OF OR FAILURE TO PROVIDE SERVICES, OR FOR ANY INFORMATION, SOFTWARE,

PRODUCTS, SERVICES AND RELATED GRAPHICS OBTAINED THROUGH THE FD GLOBAL CONNECTIONS WEB SITE, OR OTHERWISE ARISING OUT OF THE USE OF THE FD GLOBAL CONNECTIONS SITE, WHETHER BASED ON CONTRACT, TORT, NEGLIGENCE, STRICT LIABILITY OR OTHERWISE, EVEN IF FD GLOBAL CONNECTIONS OR ANY OF ITS SUPPLIERS HAS BEEN ADVISED OF THE POSSIBILITY OF DAMAGES. BECAUSE SOME STATES/JURISDICTIONS DO NOT ALLOW THE EXCLUSION OR LIMITATION OF LIABILITY FOR CONSEQUENTIAL OR INCIDENTAL DAMAGES, THE ABOVE LIMITATION MAY NOT APPLY TO YOU. IF YOU ARE DISSATISFIED WITH ANY PORTION OF THE FD GLOBAL CONNECTIONS WEB SITE, OR WITH ANY OF THESE TERMS OF USE, YOUR SOLE AND EXCLUSIVE REMEDY IS TO DISCONTINUE USING THE FD GLOBAL CONNECTIONS WEB SITE.

Termination/Access Restriction
FD Global Connections reserves the right, in its sole discretion, to terminate your access to the FD Global Connections Web Site and the related services or any portion thereof at any time, without notice.

To the maximum extent permitted by law, this agreement is governed by the laws of the State of New South Wales without regard to its conflict of law provisions. You and FD Global Connections agree to submit to the personal and exclusive jurisdiction of the courts located within the city of Sydney, New South Wales.

Statute of Limitations – You agree that regardless of any statute or law to the contrary, any claim or cause of action arising out of or related to use of the Service or the TOU must be filed within one (1) year after such claim or cause of action arose or be forever barred.

Trademarks
The names of actual companies and products mentioned herein may be the trademarks of their respective owners. The example companies, organisations, products, people and events depicted herein are fictitious. No association with any real company, organisation, product, person, or event is intended or should be inferred. Any rights not expressly granted herein are reserved.

Notices and Procedure for making Claims of Copyright Infringement
FD Global Connections makes no representations or warranties with respect to the ownership of, or copyright in, content on this website uploaded, linked or otherwise disseminated by users of our service and in no way represent others who claim to be authors, creators or owners of copyright or other rights thereto. You shall obtain all permission(s) when required and are solely responsible for determining the existence of such rights, satisfying any copyright or other use restrictions, intangible rights, or related interests for obtaining any and all permissions and releases, for guarding against the infringement of those rights that may be held elsewhere, and for paying any associated fees necessary for the reproduction or use of the materials and for rights to any proprietary material depicted, and you expressly assume all responsibility for observing applicable laws of copyright, literary right, trespass, conversion, property right, privacy, publicity and defamation.

Special Admonitions for International Use
Recognising the global nature of the Internet, you agree to comply with all local rules regarding online conduct and acceptable content.

Who to contact
If you have any questions about this privacy statement, wish to complain about our use of personal data or exercise one of your rights, please send your correspondence to our Data Protection Officer:

Data Protection Officer
FD Global Connections Pty Ltd
275 Ryedale Street,
Eastwood
New South Wales
Australia 2122

Email: enquiry@fdglobal.com.au with subject “Urgent: Data Privacy”. Note: This emailed is monitored Monday – Friday: 9am – 5pm (Australian Eastern Standard Time).