RoleWorks
Privacy Policy

This Privacy Policy is current as at 22 June 2018

1. Introduction

1.1    Our Business

RoleWorks Limited is the owner of RoleQ Services, a digital employee feedback platform supplied as a cloud based software subscription service. RoleQ Services lets a customer organisation see what is happening in roles across the organisation. RoleWorks Limited, in addition to the marketing and/or provision of RoleQ Services, provides consulting services to customer organisations.

1.2    Our Privacy Policy

Role Works Limited respects your Personal Information that it collects and uses .This Privacy Policy sets out our, and your, rights and obligations in relation to Personal Information you provide through the use of RoleQ Services or any other form of business engagement between by us, whether face to face, or, by phone, letter, email or through our Website.

Please read this Privacy Policy carefully.

2. Definitions

In this Privacy Policy the following terms are defined:

  • “GDPR” means the General Data Protection Regulation (GDPR) (EU) 2016/679.
  • our “or "we" or "us" means RW.
  • “Personal Information” means information or an opinion about an identified individual or an individual who is reasonably identifiable. Under the GDPR, the similar definition is “Personal Data”.
  • Policy” means this Privacy Policy.
  • RoleQ Services” means a digital employee feedback platform, owned by RW, and supplied as a cloud based software subscription service, that lets a customer organisation see what is happening in roles across the organisation.
  • “RW” means RoleWorks Limited, a company incorporated under the laws of New Zealand (Company number 5776208) with a principal place of business at Gate 5, Oaklands Road, Massey University Ecentre, Albany 0632, Auckland, New Zealand.
  • "Services" means the exchange or interaction between you and us concerning our business services, including in relation to the proposed or actual provision of RoleQ Services or other consulting services or when you access and use our Website or any other incidental activity relating to our business.
  • you" means you where you are any of:
    1. A potential or actual customer of RoleQ Services or consulting services by us to you; or
    2. Personnel of any proposed or actual RoleQ Services reseller or other partner entity that resells or distributes RoleQ Services and /or provides related consulting services; or
    3. A person who visits our Website or subscribes to our newsletter or other publications or downloads our whitepapers, ebooks or other educational or marketing materials; or
    4. Any other person that we engage with in relation to a potential or actual business relationship or engagement including on behalf of a service provider. 
  • "Website" means https://www.roleworks.com.

 

3. What Personal Information we collect

We may collect and hold the following Personal information, as applicable:

  • Your name
  • Country of location
  • Phone number
  • Email address
  • Details of the Web browser used the IP address of your device when connected to the internet, and the record of the pages within our Website that you visit and the date and time of your visits.

 

4. How we collect Personal Information

We may collect:

  1. Personal Information about you:
    1. at the time of registration for RoleQ Services and also when you use RoleQ Services; or
    2. when you subscribe to our newsletter or other periodic publications; or
    3. when you download our whitepapers, e books other educational or marketing materials;
    4. when you apply for employment or we request or you propose a contract for services with RW, we may collect such information from your referees; or
    5. as a consequence of our engagement with you as personnel of a RW reseller or other partner in relation to the proposed or actual sale of RoleQ Services and/or related consulting services; or
    6. in your capacity as personnel of a proposed or actual service provider to RW; or
    7. indirectly, without us asking for it, for example, if you engage with us on the following social media, Facebook ( and Instagram) , Twitter, LinkedIn, Google + and You Tube; or
    8. when you post and or communicate on our Website or the named social network forums or
    9. in any other circumstances including face to face or by email or phone exchange.
    10. Through the use of Mail Chimp (https://mailchimp.com/) (our cloud service provider) we send emails for notification of RoleQ Services commencement, RoleQ Services outage, other support services and on an opt in/ opt out basis certain educational or marketing materials concerning the RoleQ Services . RW stores your contact details by use of the Mail Chimp application:
  1. Aggregate anonymous information generated by our IT systems which tracks and analyses traffic to our Website or that arises from the use of RoleQ Services but do not relate to you personally. This is further described in Section 9.

 

5. Online Links to Third Party and Co-Branded websites

We may establish relationships with RW reseller or partners, advertisers, content providers and other third parties that may allow users of RoleQ Services or visitors to our Website to link directly to sites operated by such entities. Some of these sites may be "co-branded" with our trademarks including logos; however, these websites are not operated or maintained by or on our behalf. These sites may collect Personal Information from you that may be shared with us. This Policy will apply to any Personal Information we obtain in this manner.

RW is not responsible for the content or practices of such third parties including their operation of website(s) linked to our Website (if any). These links are meant for the website user convenience only. Links to third party sites do not constitute sponsorship, endorsement or approval by RW of the products, services, other content, policies or practices of those third party websites. Once you have left our Website via such a link, you should check the applicable privacy policy of the third party website.

6. How we use your Personal Information 

6.1    Expected use

We may use the Personal Information we collect from you:

  1. to verify your identity and assist you if you forget your password or registered RoleQ Services user login details; or
  2. to provide you with (and assist you with using) RoleQ Services; or
  3. to technically support and enhance the delivery of RoleQ Services to you; or
  4. to contact you in relation to your proposed or actual use of RoleQ Services; or
  5. specifically to fulfil administrative functions associated with the provision of RoleQ Services and our consulting services , for example,  entering into contracts with you and invoicing; or
  6. to provide you or your organisation with other services (for example, consultancy services) related to RoleQ Services; or
  7. where you have opted in to receiving such information (see Section 12 of this Policy) for marketing, promotional and publicity purposes, including to carry out direct marketing, market research and surveys but only for information that is most relevant to you and your interests; or
  8. for any other use that you expressly authorise by email or our opt-in process (see Section 12 of this Policy);
  9. to comply with the law including where required by a regulator; or
  10. as we determine necessary to prevent illegal activity; or
  11. to protect and/or enforce our legal rights and interests including defending any claim; or
  12. in relation to our relationship with you as an employer.

 

In addition when we collect certain non-Personal Information to optimise RoleQ Services (as stated in Section 3, last bullet point) or concerning the Website pages you visit from your device (e.g. the identity of your Web browser, the type of operating system you use, your IP address and the identity of the host or host's name), we may use such non-Personal Information for internal purposes, including, but not limited to, improving the content of our Website. This information may come from server logs and or cookies (see Section 8).

6.2    GDPR lawful processing grounds

The ‘lawful processing’ grounds on which RW will rely to collect and use Personal Data about you will be (as applicable):

  • in relation to potential or actual contractual engagements for the provision by RW of RoleQ Services and /or related consulting services including incidental activities to that relationship such as service updates.
  • in relation to potential or actual contractual engagements with you as personnel of a service provider to RW or a RW reseller or other partner of RoleQ Services and/ or consulting services.
  • express consent to the proposed use obtained prior to our processing.

 

6.3    Data retention

We will keep Personal Information (or Personal Data) about you, to use for the above purposes, for a reasonable period of time necessary for the operation and management of our business but subject to our obligations under Sections 11 and 12. In particular, in the use of RoleQ Services, RW generates historic reports that are based on aggregated anonymous data of RW customer individual users who may be former employees or consultants of the RW customer. In this context RW stores and processes this data for this business purpose.

7. Will we share your Personal Information with anyone else?

We will only share Personal Information with other organisations or individuals or government agencies in the following limited circumstances:

  1. Where we engage service providers to perform services on our behalf or assist us in providing RoleQ Services. In particular, RW contracts with these cloud service providers:
    1. Microsoft Azure to host and maintain the underlying IT systems that deliver the RoleQ Services and store data.. As at the current date of this Policy, the Microsoft Azure instances for the applicable IT systems are located in Australia;
    2. HubSpot for the hosting and provision of the Website and CRM data storage and processing. As at the current date of this Policy, the Hubspot IT system is located in the USA (AWS);
    3. Mail Chimp (https://mailchimp.com/))-as at the current date of this Policy with its IT database in the USA;and
    4. Xero (https://www.xero.com/nz/)- as at the current date of this Policy with its IT database in the USA

      Our third party service providers are bound by contract to only use your Personal Information on our behalf, for the specified purposes and in accordance with their privacy policies; or

  2. We may share your Personal Information with any member of our corporate group (which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in the New Zealand Companies Act 1993) for any of the purposes set out in this Privacy Policy and necessary business purposes; or
  3. Where we (or any of our group companies) sell RW’s business (equity or asset sale), we may provide your Personal Information as part of a database to the buyer, so that they can contact you about any transition  plans for the business but subject to our and the buyer’s privacy policy obligations; or
  4. Where we need to disclose your Personal Information to third parties to satisfy any mandatory applicable law, regulation, judicial or other legal process or government agency request; or
  5. When you post and or communicate on our Website or the named social network forums, this will become public information. While we strive to protect and respect your privacy, we cannot guarantee the security of any information you disclose in these publicly accessible areas.

 

8. Cookies and tracking analytics

8.1    Analytics and performance cookies

We may use cookie files containing information that can identify the computer you are working from (as referred to in Section 3). A cookie file is anonymous and is only used to identify visits from the same web browser.

We may use the information generated by such cookie files to: (a) track traffic patterns to and from the Website; (b) ensure any communications are being shown to the most appropriate person in relation to our business engagement with you; and (c) enable you to enter the Website or use RoleQ Services and visit registered user-only areas of the Website.

8.2    Third Party Cookies

Because RoleWorks has a presence on various social networks (LinkedIn, Facebook (Instagram) Twitter, Google + and YouTube) we try to share content and to see what content is popular on those networks. We add buttons to allow people to easily share to those networks. We also use Facebook to power the commenting functionality on the Website. When we include these social 'plugins', it gives those sites the flexibility to use their own cookies. They can't read any cookies we set from www.roleworks.com, and we can't read any cookies they set, but it lets them do the same kind of traffic measuring that we do on the rest of www.roleworks.com, and it also lets them know whether you're logged into their site. We never know whether you're logged in or not, as you communicate directly with (for example) Facebook, through their plugins on our Website.

Other sites and services (including, for example, advertising networks, providers of external services like web site hosting or  traffic analysis services and content recommendation engines) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

As at 8 June 2018, we disclose we make use of the following third party cookies:

  • Twitter - Advertising Targeting.
  • Facebook Social Graph - Social Comment publishing.
  • Facebook Social Plugins - Advertising Targeting.
  • Facebook Custom Audience - Advertising Targeting.
  • Facebook pixel.
  • com - Video Player.
  • Instagram (via Facebook).
  • Linked-In - Advertising Targeting.
  • HubSpot website tracking cookies.

 

8.3    How to turn Section 8.1 cookies off?

You can choose to refuse cookies by turning them off in your browser and/or deleting them from your hard drive. You do not need to have cookies turned on to use all RoleQ Services but you will need them to access personalised or secure content on the Website. Some pages may not function properly if the cookies are turned off.

9. Aggregated anonymous data analytics

We use software and systems which analyse information provided through the Website and RoleQ Services on an aggregated basis, for example, to derive market insights about roles across various sectors.  This information is collected and aggregated so you cannot be identified personally and no Personal Information is stored about you through these analytics.

10. Security

We use our reasonable commercial efforts to ensure the security, integrity and privacy of your Personal Information and avoid unauthorised loss, use or disclosure. We use a variety of physical measures (for example, restricting physical access to our offices) and electronic security measures  including password protected use of devices, and, in conjunction with our cloud service provider, Microsoft Azure, use of IT firewalls and secure internet connections and databases.

As no data transmission over the internet can be guaranteed to be completely secure, we cannot ensure the security of any information you transmit or receive through the Website or the use of RoleQ Services. While as stated we take precautions to minimise related risks, you use the internet for transmission at your own risk.

If you post your Personal information on our Website or in any of our social media channels (LinkedIn, Twitter, Facebook (Instragram), Google + or YouTube) you acknowledge and agree that the information you post is publicly available.

11. Your Personal Information rights

11.1  How to access or correct your Personal Information

11.1.1  Subject to applicable laws, you have the right to access your Personal Information and to receive a copy of that information. We may need to verify your identity to respond your access request (and similarly where made under Sections 11.1.2 and 11.2). We will respond to any access request within a reasonable time period. We will give you access in a media form requested provided it is reasonable and practical. We do not expect to need to charge our time for this provided the access request is reasonable. If we cannot give you access, due to legal grounds, then we will inform you of this in writing.  

11.1.2  You also have the right to request the correction of the Personal Information we hold about you. We will take reasonable steps to make appropriate corrections to Personal Information so that it is accurate, complete and up-to-date.  Unless a lawful exception applies, we must update, correct, amend or delete the Personal Information we hold about you within a reasonable time period. If we have shared that Personal Information to others, as contemplated under Section 7, we will use our reasonable commercial efforts to contact them and arrange the relevant change.

We do not charge for making corrections.

To seek access to, or, correction of, your Personal Information, please contact our Data Privacy Officer as set out below in Section 14. 

11.2  GDPR data subjects - exercising your other rights

If you (a data subject under the GDPR) are located in country that is a member of the European Economic Area (EEA) you have a number of other GDPR rights in relation to our collection and use of your Personal Data. You have the right to:

  • opt-out of direct marketing and profiling for marketing- please note Section 12 below.
  • opt-out of processing for research / statistical purposes, or processing on the grounds of ‘public interest’ or ‘legitimate interest’ - please note Section 12 below.
  • erasure of your Personal Data.
  • Personal Data portability.
  • Object to or restrict processing of your Personal Data.

Any request in relation to the exercise any of those rights, please contact our Data Privacy Officer as set out below in Section 14.

12. Opt in/out

12.1 We will give you the option to: (a) opt out and not receive certain email newsletters, promotional material, special offers, surveys and any other related material ; or (b) opt in to agree to be contacted by us in relation to certain matters such as notification of new features to the RoleQ Services, beta testing or email newsletters, promotional activities, special offers, surveys and any other related material.

12.2  RW advises that if you exercise your  opt out rights per Section 12.1 this may result in any of the services and materials referred to in Section 12.1 not being provided or made available to you.

13. Updates

We will review this Policy regularly, and we may update it from time to time by publishing the latest version on our Website or as otherwise notified to you in writing (including by email). You will ensure that you have read the most recent terms posted on the Website or as otherwise notified to you.

14. To contact our Data Privacy Officer

If you have a request or enquiry or a complaint about the way we handle your Personal Information (or Personal Data) or to seek to exercise your privacy rights herein in relation to the Personal Information (or Personal Data) we hold about you, you may contact our Data Privacy Officer as follows:

Name: Olivia Kruger
Title: Client Support Manager, Role Works Limited
Email: olivia.kruger@roleworks.com
Mail: c/o RoleWorks Limited, PO Box 165 Mangawai    

While we endeavor to resolve complaints quickly and informally, if you wish to proceed to a formal privacy complaint, we request that you make your complaint in writing to our Data Privacy Officer, by mail or email as above. We will acknowledge your formal complaint within 10 working days.

If we do not resolve your privacy complaint to your satisfaction, you may lodge a complaint with the New Zealand Privacy Commissioner by making a complaint online at https://www.privacy.org.nz/your-rights/complaint-form/, or writing to them at Privacy Commissioner PO Box 10094, Wellington 6143.

If you are a data subject in the European Economic Area, you can choose to instead lodge a complaint with your local Data Protection Authority (DPA).  The list of DPAs is at http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.