Privacy Policy

Your employer has set up Track 360 Feedback for your use. By using this app, you are consenting to your data being used as you have agreed with your employer.

Please contact your employer if you have any questions about the use of your data.

TRACK 360 FEEDBACK PRIVACY POLICY

Summary

At Track Surveys we believe in the importance of looking after your information and ensuring you have maximum control over it, we've summarised the key points from within our Privacy Policy - but of course we suggest reading it in full.

1. Only those within your organisation with the appropriate access level are able to view your information & we restrict access on our end.
2. If you'd like to access, amend or delete any information please contact your employer's relevant HR department.
3. If at any time you are concerned or have questions about how we might be handling your data, please contact your employer's HR department.

IF YOU DO NOT ACCEPT AND AGREE WITH OUR PRIVACY POLICY THEN YOU MUST NOT ACCESS OR USE TRACK 360 FEEDBACK.

Track Surveys Limited ("Track Surveys", "We", "Us" and "Our") remain fully committed to the protection of your privacy at all times. The information contained in this policy has been published to inform you of the way in which any Personal Data (as defined below) you provide us with or we collect from you will be used. Please read this information carefully in order to fully understand how we treat such Personal Data.

When you access or use Track 360 Feedback, you agree to our privacy policy and you consent to our collection, storage, use and disclosure of your Personal Data for the purpose of making Track 360 Feedback available to you, in accordance with this policy.

We will collect, store, use and disclose Personal Data in accordance with all applicable laws relating to the protection of Personal Data, including the EU Data Protection Directive 95/46/EC, the EU General Data Protection Regulation 2016/679, the EU ePrivacy Directive 2002/58/EC as amended by Directive 2009/136/EC, as amended or superseded from time to time, and any national implementing legislation ("Data Protection Laws").

For the purpose of Data Protection Laws, in relation to any Personal Data you or any Users submit to our platform, your employer will be the data controller and we will be a data processor of such Personal Data.

PERSONAL DATA WE MAY OBTAIN FROM YOU

"Personal Data" means any information relating to an identified or identifiable natural person; an identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Please note that only data requested and/or authorised by your employer will be collected. We may obtain, from your employer or from you, and use, the following Personal Data about you and anyone you choose to add to Track 360 Feedback to request feedback or for any other authorised purpose:

• First and last name
• Title
• Position
• Employer
• Contact information (company, email, phone, physical business address)
• ID data
• Professional life data
• Localisation data
• Any correspondence we have with you should you contact us for information or support.
• Data you or your colleagues provide when you fill out forms or feedback on Track 360 Feedback, including but not limited to data you provide when you register to become a user of the Service.
• Data and information you or your colleagues submit or upload to Track 360 Feedback, including employee data not listed above, if these details are requested by your employer.
• Details of transactions made by you through Track 360 Feedback.
• Responses to optional research surveys we ask you or Users to complete.
• Details of your visits to Track 360 Feedback, which includes without limitation location and traffic data, weblogs, resources you access and other communication data.

COOKIES AND IP ADDRESSES

We may obtain information about your computer, which includes your and your IP address, browser type and operating system where available. This accumulation of data is used to assist system administration.

We use the following cookies:

1. Strictly necessary cookies. These are cookies that are required for the operation of our Website/Portal and Service. They include, for example, cookies that enable you to log into secure areas of Track 360 Feedback.

WHERE WE STORE PERSONAL DATA

Personal Data we obtain from you and/or your employer will not be processed, moved to, or stored at a destination outside the UK/EEA.

We store the Personal Data you and/or your employer provide us with on our secure servers, which are hosted in the UK. In the event of us giving you a password which grants you/them access to specific areas within Track 360 Feedback, it remains your responsibility to maintain the confidentiality of this password. This includes the responsibility to refrain from sharing your password with other parties.

As the transmission of data via the Internet cannot be assumed completely secure, we cannot guarantee the security of any of your data transmitted to Track 360 Feedback; you are therefore responsible for any risk associated with such transmission. We will however at all times take all reasonable steps to ensure the transmission of your data is executed as securely as possible, and upon receipt of your/their data we will continue at all times to enforce strict security procedures and features in an attempt to prevent any unauthorised access.

HOW WE PROTECT YOUR PERSONAL DATA

We will take reasonable steps to maintain appropriate technical and organisational measures to protect the Personal Data you provide to us against accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to your Personal Data.

HOW WE USE YOUR PERSONAL DATA

The Personal Data we hold about you may be used in any of the following ways:

• To enable you to use Track 360 Feedback as determined by your employer.
• To provide you with user support.
• For research and analytics purposes (for example, to provide aggregate reporting to your employer).
• To ensure security for you
• To comply with applicable Laws, court orders, government and law enforcement agencies' requests.
• To fulfil the obligations we have in relation to any contracts we have in place with your employer.
• To provide you with notification about any changes to the service.

We will never supply your Personal Data to third parties. Notwithstanding the foregoing, you acknowledge and agree that we may aggregate and anonymise your Personal Data (excluding, for the avoidance of doubt, Sensitive Personal Data) and use and share such aggregated and anonymised Personal Data with your employer only, for statistical purposes, and for the purpose of data analytics, product development, and/or service improvement.

DISCLOSURE OF YOUR INFORMATION

Disclosure of your and your Users' Personal Data (including, without limitation, Client Data) to third parties will only occur in any of the following events:

• We sell or purchase any business or assets. In such case, we may authorise the disclosure of your personal data to prospective sellers or buyers of such business or assets.
• All or the substantial majority of our assets are sold to a third party. In such case, your personal data may be one of the transferred assets.

You acknowledge and agree that we may also disclose Personal Data with: (i) our service providers involved in the provision, distribution, delivery and support of the Service; (ii) fraud prevention agencies; (iii) law enforcement agencies, regulators, courts and public authorities; and (iv) emergency services. Our service providers have to follow our express instructions when processing the Personal Data you provide and must have in place appropriate technical and organisational security measures to safeguard such Personal Data, and we do not allow them to use this information for their own commercial purposes.

THIRD PARTY CONSULTANTS

Where your employer has contracted with a third-party consultant to provide services that use Track 360 Feedback, your data will be used by that third-party consultant as agreed with your employer.

You also consent to that third party sharing your final report and other data with your employer.

YOUR RIGHTS

You retain at all times the right to access / amend / delete any Personal Data we hold about you or to exercise your right of data portability or to object to, or restrict, the purposes for which your Personal Data is processed on certain grounds. You may exercise this right by making a request to your employer's relevant HR department. You may also lodge a complaint with the UK data protection regulator, the Information Commissioner should you be dissatisfied with the way that we handle your Personal Data.

HOW LONG WE KEEP PERSONAL DATA FOR

We will keep your Personal Data for the duration of the service and in accordance with your employer's instructions or for such periods as may be required by law.

CHANGES TO OUR PRIVACY POLICY

If at any time we make a change to this policy, we will update this page to reflect such change. Where we feel it appropriate, we will notify you by email, however we recommend you review this page periodically to ensure you remain happy with the latest version.

QUESTIONS, COMMENTS AND GETTING IN TOUCH

If you have any questions or comments in relation to this privacy policy, please contact your employer's relevant HR department in the first instance.