FACET5 – PRIVACY PROTECTION POLICY

1 INTRODUCTION

This Privacy Policy describes our policies on the collection, use, and disclosure of information about you in connection with your use of our services, including those offered through the Facet5 website (https://www.facet5global.com) (“Site”) and communications (e.g., emails and phone calls) (collectively, “Service”). The terms “we”, “us”, “our” and “Facet5” refer to: Facet5 Global, with its headquarters in Cambridgeshire, United Kingdom. When you use the Service, you consent to our collection, use, and disclosure of information about you as described in this Privacy Policy, our Terms of Use and our Guidelines.

Facet5 are committed to safeguarding the privacy of our clients, website visitors and service users; in this policy we explain how we will handle your personal data.

We incorporate privacy controls which affect how we will process your personal data. By using the privacy controls on our website (preferences), you can specify whether you would like to receive direct marketing communications and limit the publication of your information.

Throughout this document we refer to Data Protection Legislation this means the Data Protection Act 2018 (DPA2018), United Kingdom General Data Protection Regulation (UK GDPR), the Privacy and Electronic Communications (EC Directive) Regulations 2003 and any legislation implemented in connection with the aforementioned legislation. Where data is processed by a controller or processor established in the European Union or comprises the data of people in the European Union, it also includes the EU General Data Protection Regulation (EU GDPR). This includes any replacement legislation coming into effect from time to time.

We are registered with the Information Commissioner’s Office (the ICO) with registration number ZA065026

You can contact us either by phone, email, or post.

Postal address:
Facet5 Ltd
Mill Yard Offices
Childerley Estates
St Neots Road
Dry Drayton
Cambridgeshire
CB23 8BA

Phone:+44 (0)1954 602460
Email: support@facet5global.com

Our Data Protection contact is:
The Business Operations Manager

Our EU Representative is:
An EU Representative is the person designated, where applicable, to represent companies that are not based in the EU regarding their obligations under the GDPR. Facet5’s EU represented is:
The DPO Centre (Europe) Ltd.
Alexandra House,
Ballsbridge Business Park,
Ballsbridge Park,
Merrion Road,
Dublin DO4 C7H2, Ireland
Phone: +353 1 631 9460
email: eurep@facet5global.com

The hosting facilities for our websites are situated in the Republic of Ireland (EU).

2 ABOUT FACET5

Facet5 is a measure of personality powered by a passion for development. We support individuals,
teams, leaders and businesses to realise their full potential.

Used by organisations and consultancies worldwide, we provide a model and a language to explain
how people differ in their behaviour, motivation, attitudes, preferred ways of working – and most
importantly; what they can achieve.

3 INFORMATION WE COLLECT AND HOW WE USE IT

We only collect personal information that we know we will genuinely use and in accordance with the Data Protection Legislation. We receive, store, and process certain types of personal information about you from your use of the Service and automatic data collection.

4 WHAT CATEGORIES AND TYPES OF INFORMATION DO WE COLLECT

We collect, transmit and store various categories of your personal information in connection with the Service. The type of personal information that we will collect on you, and you voluntarily provide to us, form or service may include some or all of the following:

VariablePurpose  Supplied by
AccessIDUnique identifier  Facet5 System
First nameIdentification  Facet5 User
Family nameIdentification  Facet5 User
Preferred Display nameIdentification  Facet5 User
EmailIdentification  Facet5 User
Date of invitationTo enable follow-up  System
Date of completionTo confirm completion  System
User defined 1 and 2To identify or classify records  Users
Item responses 1 – 106Questionnaire responses  Respondents
Item latencies 1 – 106Question response latencies  Respondents
Raw scoresComputed after completion  System
Derived scoresSten scores Derived from raw  System
LocationNorm Groups  Facet5 User
Age RangeNorm Groups  Facet5 User
GenderNorm Groups  Facet5 User

Facet5 has not collected and does not plan to collect characteristics of protected classifications under applicable laws, biometric information, education information; and sensitive personal information other than account logins and encrypted passwords. Although neither required nor recommended, it is your choice to provide any of the foregoing information in connection with the Service and to make that information public.

We may, in further dealings with you, extend this personal information to include your address, purchases, services used, records of conversations, any agreements and payment transactions.

You are under no statutory or contractual requirement or obligation to provide us with your personal information; however, we require at least the information above in order for us to deal with you as a prospective client, client or user of Facet5 services, in an efficient and effective manner.

The legal basis for processing your data is based on your legitimate interest that we will have requested at the point the information was initially provided; therefore, we will not store, process or transfer your data unless we have an appropriate lawful reason to do so.

5 WHAT CATEGORIES AND TYPES OF INFORMATION WE COLLECT

We receive your personal information from any one or more of the following sources:

  • Directly from you. When you visit the website, log-in on the portal as a registered user, or provide your information in a form on the Site, direct to the team, we will collect and store that information.
  • Indirectly from you. When you navigate and interact with the website, some information is automatically collected by cookies and similar technologies. Not all information collected may be personal information, and some cookies are necessary to use different functionalities of the Site. The personal information collected may include information about your computer and internet connection, like IP address, operating system, and browser type. For more information about the cookies we use, see our Cookie Policy.
  • From Social Media Networks. When you use a social network login to access the website, you will share certain personal information from your social media account with us. For example, if you connect to the Site through your LinkedIn account, we will receive and store your LinkedIn profile information and LinkedIn connections.

We may, in further dealings with you, extend this personal information to include your address, purchases, services used, and subscriptions, records of conversations and agreements and payment transactions.

  • You are under no statutory or contractual requirement or obligation to provide us with your personal information; however we require at least the information above in order for us to deal with you as a prospective client, client or user of Facet5 services, in an efficient and effective manner.
  • The legal basis for processing your data is based on your legitimate interest that we will have requested at the point the information was initially provided, therefore we will not store, process or transfer your data unless we have an appropriate lawful reason to do so.

6 WHY WE USE PERSONAL INFORMATION

We may use personal information as permitted by law, for the following business purposes:

  • To provide the Service and various functions of the Service. When you are Accredited, we create an account on the portal/myFacet5 for you, we store and use the information you provide during the Accreditation process. This may include your first and last name, email address, the company you work for, and any other information you may provide during the account creation process. We also store and use any preferences you provide to personalise your user experience.
  • To engage in analysis related to the Facet5 Norms. We store and use Raw Data information from the questionnaires to enable the group norms to be used in the services that we offer.
  • To send you emails about Facet5’s products and services. We use your email address to send informational and marketing emails to you about new products and services, or updates to existing products or services. We may also contact you regarding feedback you provide us, or to learn more about your experience using Facet5. Where appropriate, Facet5 will only do this with your consent. We may review statistical analysis and to get feedback from you about our products, websites, and other services and activities. For example, occasionally we may invite you to review a product or service you’ve bought or used from us. If we do, it’s possible that we’ll use independent research and feedback providers to act on our behalf;
  • To comply with legal obligations. We use and share your personal information as necessary to respond to court orders, or other legal process; we also may use and share your personal information to establish or exercise our legal rights, to defend against legal claims, or as otherwise required by law. We may use and share your personal information when we believe it is necessary to investigate, prevent, or take action regarding illegal or suspected illegal activities; to protect and defend the rights, property, or safety of Facet5, our licences, and others.
  • In connection with a business transaction. We may use and share your personal information in connection with a business transaction, such as a merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.
  • To enhance the security of the Service. We store and use information to ensure the security of the Service. For example, we use the information collected by certain cookies to determine if you are logged in and to detect unauthorised access to your account.

Please note that Facet5 does not collect sensitive information.

7 HOW WE KEEP YOU UPDATED ON OUR PRODUCTS AND SERVICES

We may share your personal data with other organisations in the following circumstances:

We will send you relevant offers and news about our products and services in a number of ways including by email, but only if you have previously consented to receive these marketing communications. When you register with Facet5 we will ask if you would like to receive marketing communications, and you can change your marketing choices online, over the phone or in writing at any time.

If you wish to amend your marketing preferences, you can do so by updating your preferences on our website or via email to support@facet5global.com

8 YOUR DATA PRIVACY RIGHTS

Depending on where you are located and/or live, you may exercise certain data privacy rights, and Facet5 will facilitate the exercise of those rights.

9 EUROPEAN PRIVACY RIGHTS

If you are a resident or are otherwise located in the European Union (“EU”) or the United Kingdom (“UK”), this section provides additional details about the personal data we collect about you, and your rights granted by the EU and UK General Data Protection Regulations, as applicable (“GDPR”).

Subject to certain limitations, the GDPR provides you the following privacy rights:

  • Transparency and the right to information. Through this Privacy Policy we explain how we use and share your personal information. However, if you have questions or concerns you can contact us at support@facet5global.com
  • Right of access, objection, restriction of processing, correction, erasure, and portability. You can make a request to access, object, restrict, correct, erase, or transfer any of your personal information. You also have the right to withdraw your consent when we process your personal information based on your consent.
  • Right to opt-out from direct marketing. You have the right to opt-out from receiving marketing materials from us by following the opt-out instructions in our commercial emails, by contacting us, or by adjusting your preferences under your profile details on the website. Please note that we reserve the right to send you other communications, including transactional emails, service announcements and administrative messages relating to your Facet5 account, without offering you the opportunity to opt out of receiving them.
  • Right to lodge a complaint with a supervisory authority. If you consider that the processing of your personal information infringes your GDPR privacy rights, you have the right to lodge a complaint with a supervisory authority, in the member state of your habitual residence, place of work, or place of the alleged infringement. Contact details for the EU data protection authorities can be found at: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm. For users located in the UK, you can contact the Information Commissioner’s Office (ICO). Contact details for the ICO can be found at https://ico.org.uk/global/contact-us/.

If you would like to submit a request to Facet5 to exercise your EU or UK privacy rights under the GDPR, you may do so by submitting a request via support @facet5global.com

10 LEGAL BASIS FOR PROCESSING
(EEA, Switzerland and United Kingdom only)

Our legal basis for collecting and using your personal information will depend on the type of information and the context in which we collect it.

However, we will normally collect personal information from you only in the following circumstances:

  • We have your express consent to do so;
  • We need the personal data to perform a contract with you; or
  • Processing is in our legitimate interests and is not overridden by your data protection interests or fundamental rights and freedoms.

If we ask you to provide personal information to comply with a legal requirement or to set up your portal to Facet5 with you, we will identify such basis for processing at the relevant time and let you know if the provision of your personal information is mandatory or not (as well as the possible consequences associated with not providing such information).

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 at support@facet5global.com

11 INTERNATIONAL TRANSFERS

Our servers are located in the Republic of Ireland Carlow is the main server with a backup server in Dublin.

Your personal information will be processed in the Republic of Ireland and may be outside your jurisdiction, including in countries and jurisdictions that are not subject to an adequacy decision by the European Commission or your local legislature or regulator. We ensure that your personal information is encrypted in transit and offers an adequate level of protection and security, and, if required, standard contractual clauses or an alternative mechanism for the transfer of data as approved by the European Commission (Art. 46 GDPR) or other applicable regulators or legislators. Where required by applicable law, we will only share, transfer or store your personal information outside of your jurisdiction with your prior consent.

12 DATA RETENTION

We retain a record your personal information in order to provide you with a high quality and consistent service. We will always retain your personal information in accordance with the Data Protection Legislation. Unless otherwise required by law, your data will be stored indefinitely to ensure your Facet5 Profile information is available to you at all times, unless your right to erasure is executed, at which point it will be deleted.

With respect to personal information that has been collected using cookies and similar tracing technologies, you can view retention periods in our Cookie Policy, as well as adjust and/or disable certain tracking. Information that you submit through your user profile is retained for the lifetime of your account with us. Please note that software product and service providers listed on the Site cannot remove their profile page, ratings, or reviews by closing their accounts.

Note once data has been removed you will no longer be able to access your Facet5 information.

13 Third Party Websites and social media

Our website may include hyperlinks to, and details of, third party websites or social media links.

We have no control over, and are not responsible for, the privacy policies and practices of third parties.

14 GIVING YOUR REVIEWS AND SHARING YOUR THOUGHTS

When using our websites, you may be able to share information through social networks like Facebook and Twitter. For example, when you ‘like’, ‘share’ or review our Services. When doing this, your personal information may be visible to the providers of those social networks and/or their other users. Please remember it is your responsibility to set appropriate privacy settings on your social network accounts, so you are comfortable with how your information is used and shared on them.

15 PERSONAL DATA OF CHILDREN

The Site is a general audience site and does not offer services directed to individuals under 18 years of age.

No one under the age of 18 may provide any information to or on the Site. We do not knowingly collect or share personal information from individuals under 18.

If you are under 18, do not use or provide any information on the Site or on or through any of its features, do not register with us, do not use any of the interactive or comment features of the Site, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. Should an individual whom we know to be under the age of 18 send personal information to us, we will delete or destroy such information as soon as reasonably possible. If you believe we might have this type of information, please contact us.

16 UPDATING INFORMATION

Please let us know if the personal information that we hold about you needs to be corrected or updated,  particularly if you are Accredited and change employer as we will need to keep you updated with Accreditation News.

17 SECURITY

We have implemented appropriate administrative, technical, and physical security procedures to help protect your personal information.

For example, only authorised employees are permitted to access personal, and they only may do so for permitted business functions. Our security and privacy policies are periodically reviewed and enhanced as necessary. In addition, we use encryption when transmitting your personal information between your system and ours, and we employ firewalls and intrusion detection systems to help prevent unauthorised persons from gaining access to your non-public information.

Please bear in mind that submission of information over the Internet is never entirely secure. We cannot guarantee the security of information you submit via the website while it is in transit over the Internet, and any such submission is at your own risk.

18 WHAT HAPPENS IF OUR BUSINESS CHANGES HANDS

Should Facet5 sell and/or the transfer control of all or part of our business, any personal data that you have provided will, where it is relevant to any part of our business that is being transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use that data only for the purposes for which it was originally collected by us.

19 CHANGES TO THIS PRIVACY POLICY

This Privacy Policy is current as of the last updated date set forth above. Facet5 may, in its sole and absolute discretion, update this Privacy Policy from time to time. Facet5 will post its updated Privacy Policy to the website. You acknowledge that your continued use of the Site and/or continued provision of personal information to Facet5 after we publish an updated Privacy Policy will be considered acceptance of any changes to this Privacy Policy. We encourage you to periodically review this Privacy Policy for any changes. You can see when this Privacy Policy was last updated by checking the “Effective From” date displayed at the top of this Privacy Policy.

20 HOW TO CONTACT US

If you would like to exercise one of your rights as set out above, or you have a question or a complaint about this policy, the way your personal information is processed, please contact us by one of the following means:

By email:
support@facet5global.com

By post:
Facet5 Ltd
Mill Yard Offices
Childerley Estates
St Neots Road
Dry Drayton
Cambridgeshire
CB253 8BA

EU Representative
The DPO Centre (Europe) Ltd.
Alexandra House,
Ballsbridge Business Park,
Ballsbridge Park,
Merrion Road,
Dublin DO4 C7H2, Ireland

Phone: +353 1 631 9460

email: eurep@facet5global.com

Thank you for taking the time to read our Privacy Policy.

This Policy was last updated on February 2023