We take your privacy and protection of personal data very seriously
This Privacy Policy was last updated on 03 October 2024.
Welcome to Ignition! We hope you will enjoy and appreciate visiting or using the Website at https://www.ignitionapp.com or any subdomain thereof (the “Website”), or using or purchasing a “Subscription” to our “Services”.
We want you to know that we take your privacy and protection of personal data very seriously. We are providing this Privacy Policy (the “Policy”) to tell you about who we are, what personal data we collect from you and about you, and what we do with your personal data, all while you visit the Website, use the Services or otherwise interact with us. The Policy also explains your privacy and data rights under the law, and how you can contact us and the necessary authorities to enforce those rights.
We ask that you please read this Policy carefully, together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your data. This Policy supplements other notices and privacy policies and is not intended to override them.
By using our Website or Services, you agree to be bound by this Policy and that we proceed to the processing of your personal data on the terms outlined below.
References to “you” or “your” are to you as an individual using our website or otherwise contacting us (whether on behalf of yourself, or another individual, or organisation).
Before we get started with the details, here are a few important terms we think you should know as you read this Policy.
“Data Protection Laws” refers to the laws that are designed to protect your personal data and privacy in the place where you live. These include: (1) the Australian Privacy Act 1988 (as amended, the “AU Privacy Act”); (2) the “GDPR”, the European Data Protection Law which stands for “General Data Protection Regulation”, with the official name Regulation (EU) 2016/679 of the European Parliament and of the Council; (3) “PIPEDA” (Personal Information Protection and Electronic Documents Act), which is the Canadian Data Protection Law that applies to our commercial activities in Canada; (4) the California Consumer Privacy Act (“CCPA”) which applies to our activities in the United States in certain circumstances; (5) South Africa’s Protection of Personal Information Act, 2013 (“POPIA”) which applies to processing of personal data we do within the Republic of South Africa; (6) the “UK GDPR”, United Kingdom’s retained version of the GDPR, which applies to our activities in the United Kingdom; (7) the Data Protection Act 2018 (“DPA”) which also applies to our activities in the United Kingdom; and (8) the New Zealand Privacy Act 2020 (as amended, the “NZ Privacy Act”). Please note that when this Policy refers only to the “GDPR”, this includes the UK GDPR as applicable. Ignition is committed to adhering to these Data Protection laws, and any other applicable Data Protection Laws.
“Personal data” – under the GDPR, personal data is information about an individual from which that person can be identified. It can be as simple as your name or your email, or something more complicated like an online identifier (usually a string of letters and / or numbers) that gets attached to you. Personal data does not include data where the identity has been removed (anonymous data). Under the AU Privacy Act, NZ Privacy Act, PIPEDA, POPIA and the CCPA the equivalent concept is “personal information”, which is roughly the same. Any mention of “personal data” in this Policy shall also mean personal information.
Other terms and definitions used in this Policy may be found in our Terms of Use, and will have the same meaning in this Policy as they do there.
Ignition is made up of Practice Ignition Pty Ltd ACN 153 623 931, a proprietary limited company headquartered in Sydney (Surry Hills) Australia, together with its subsidiaries:
which together form the Practice Ignition Group.
This privacy policy is issued on behalf of the Practice Ignition Group so when we mention “Ignition”, “we”, “us”, or “our”, we are referring to the relevant company in the Practice Ignition Group responsible for processing your data. We will let you know which entity will be the controller for your data when you purchase a product or service with us.
Practice Ignition Pty Ltd, is the controller and is responsible for this Website. Under the GDPR, Ignition is a “data controller”, and under POPIA Ignition is a “responsible party”. Either term means we collect personal data directly from you and determine the purpose and means of “processing” that data. “Processing” is a broad term that means collection, use, storage, transfer or any other action related to your personal data; it is used in this Policy in that way.
We are responsible for your personal data, except where we process your personal data because you use our services as a result of your relationship with a customer who we supply our services to (for example, if you use our services as a result of your being our customer’s employee or client).
Where we process your personal data because you use our services as a result of your relationship with a customer who we supply our services to, we are not the data controller as we would be processing personal data on behalf of our customer as a data processor. In such cases, the privacy policy that you should be referring to would be our customer’s privacy policy. Our customer’s privacy policy should inform you as to how your personal data will be processed.
Ignition is registered as a data controller in England and Wales with the Information Commissioner’s Office (“ICO”), the UK’s independent authority set up to uphold data protection rights. Our ICO registration number is ZA157905.
If you want to ask us anything about what’s in this Policy, or anything else privacy- or data- related, or exercise any of your available privacy rights, you can email:
Ignition Privacy Officer
privacy@ignitionapp.com
Here is the mailing address for you as well:
Ignition Privacy Officer
Level 7, 54-66 Wentworth Ave
Surry Hills, NSW 2010 Australia
In relation to our UK activities specifically, we have appointed a data privacy manager who is responsible for overseeing questions in relation to this Policy. Our data privacy manager is Jack Farrant contactable at jack@ignitionapp.com | +447 9432 91993.
If you are in the Republic of South Africa, we also invite you to contact our Information Officer who is based there, with the following contact information: Will Dutton - will.dutton@ignitionapp.com | +277 6817 4974.
If you have questions about the Website or Services themselves, please email support@ignitionapp.com .
Under the GDPR, you have the following rights under certain circumstances in relation to your personal data.
You may also have the following rights regarding your personal data held by Ignition, and other privacy rights, depending on the Data Protection Laws where you are located that apply to you:
These rights may be exercised without affecting the price you pay for any of the Services. Notwithstanding that, exercising certain of these rights may affect your ability to use some or all of the Services.
If you wish to exercise any of these rights, please contact us.
In relation to our UK activities, you also have the right to make a complaint at any time to the ICO. Please refer to the ‘Supervisory authorities and complaints’ section below for further information. We would, however, appreciate the chance to deal with concerns before you approach the ICO so please contact us in the first instance.
No fee is usually required to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
We may need to request specific information to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally, it could take us longer if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
We use different methods to collect data from and about you including through:
If you are in the Republic of South Africa, then we are processing such information received from third parties as an Operator and not as a Responsible Party (as those terms are defined in POPIA). As Operators, we are obliged under POPIA to process such information only with the knowledge or authorisation of the Responsible Party (being the User who uploaded the personal data), and must not disclose it unless required by law or in the course of the proper performance of our duties. We also undertake to maintain and establish the security measures referred to in section 19 of POPIA when processing such information and to notify the User immediately where there are reasonable grounds to believe that the personal data of a data subject has been accessed or acquired by any unauthorised person.
We will only use your personal data when the law allows us to. Under the GDPR, we will most commonly use your personal data in the following circumstances:
Under the GDPR, we generally do not rely on consent as a legal basis for processing your personal data, although we will get your consent before sending third party direct marketing communication to you. You have the right to withdraw consent to marketing at any time by contacting us.
In the table below, we have set out a description of the ways we plan to use your personal data, and which of the legal bases we rely on to do so under the GDPR and POPIA. We have also identified what our legitimate interests are where appropriate.
We may process your personal data for more than one lawful ground, depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out below.
PERSONAL DATA CATEGORY | WHAT WE USE IT FOR (THE “PURPOSE” OF PROCESSING) | LEGAL BASIS FOR PROCESSING UNDER THE GDPR AND POPIA |
---|---|---|
| To manage our relationship with you and communicate with you generally, for example when we notify you about changes in our privacy policy and ask you to leave a review or take a survey |
|
| To register you as a new customer, communicate with you when you book a demo of the Services through the Website, and customize your demo |
|
| To be responsive as possible to you, for example, when providing support for the Services or answering your customer queries |
|
| To manage your account and Subscription, enable logging in to the Services, and customize your use of the Services |
|
| To process and deliver your order including:
To collect and recover money owed to us |
|
| To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, validating against fraudulent transactions, support, reporting and hosting of data) |
|
| To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you | Necessary for our legitimate interests (for example, to study how customers use our products or services, to develop them, grow our business, and inform our marketing strategy) |
| To use data analytics to improve our website, products/services, marketing, customer relationships and experiences | Necessary for our legitimate interests (for example, to define types of customers for our products/services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
| To make suggestions and recommendations to you about products or services that may be of interest to you, based on your Subscription or any other products/services purchased on our website | Necessary for our legitimate interests (for example, to develop our products/services and grow our business) |
| Companies that use third party software to operate a referral program for Ignition, such as PartnerStack. | Provides us with partner management software solutions. |
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested or withdraw your consent to us processing your personal data (where applicable), we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
Please note that Financial Data collected and processed for billing and payment purposes is never stored on any servers or other equipment controlled by Ignition. While such data is collected through the Services, it is stored on servers and other equipment managed by the Payment Processors and Payment Facilitators, as described further in the ‘Who we transfer your personal data to’ section below.
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data under the UK and/or EU data protection regime (as applicable) as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
We do not collect any of what the GDPR considers Special Categories of Personal Data, which includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data. Under the POPIA, such data is known as “special personal information”, and under the AU Privacy Act, such data is known as “sensitive information”.
We also do not ask you for any information about criminal convictions and offences.
You may choose to voluntarily provide us with Special Categories of Personal Data through your interactions with us, but we strongly encourage you not to do so. If you provide us with such Special Categories of Personal Data, you are giving us your explicit consent to process such data about you to the extent permitted by the UK and/or EU data protection regime (as applicable).
For the purposes set out in the ‘How we use your personal data’ section above, we may share some of your personal data with certain third parties as set out below.
We require all third parties to respect the security of your personal data and to treat it in accordance with applicable laws. We do not allow our third-party service providers to use your personal data for their own purposes and only permit to process your personal data for specified purposes and in accordance with our instructions.
We do not sell or rent your personal data to any third party for direct marketing purposes or any other purpose.
The table below identifies the third parties we may share your personal data with, and what they do with the personal data.
PERSONAL DATA CATEGORY | WHO WE TRANSFER IT TO | WHAT THEY DO WITH IT |
---|---|---|
| Companies that provide email services such as HubSpot and Postmark, as detailed more fully in the ‘Email Communications and Compliance with anti-spam laws’ section below. | Manage our mailing list, send out our newsletters and send out emails relating to our Services |
| Companies providing technical infrastructure and software for the Services such as Amazon AWS, and our CRM provider HubSpot | Store it so that we may retrieve it to contact you
|
| Companies providing customer support and chat services, such as Intercom | Store it so that we may retrieve it to contact you to provide support |
| Companies providing technical infrastructure and software for the Services, such as Amazon AWS and Heroku | Control your logging in to the Services so they can be provided to you, send you emails, and record-keeping |
| Our business partners, specifically Intuit and Xero when you have been referred to us by them | Communicating with you and record-keeping |
| Payment Processors and Payment Facilitators, such as Stripe | Process the payments of your Subscription Fees and Additional Client Fees (if applicable) Process payments or debit payments for the Professional Fees you are paying to a Professional Services Provider via the Services |
| Companies that provide online advertising networks, like Google and Facebook | Show you ads for Ignition and the Services when you are on the internet, as further detailed in the ‘Third-party marketing and advertisements’ section below |
| Companies that provide data analytics, such as HubSpot, Google Analytics and Segment and Snowflake. | Provide us with analytics as to how the Website and Services are used, as further detailed in the ‘Limited gathering of information for statistical, analytical and security purposes’ section below |
Transfer of personal data outside of the European Economic Area (EEA), the UK or the Republic of South Africa
We share your personal data within the Practice Ignition Group. This may involve transferring your data outside the EEA, UK or the Republic of South Africa.
Some of our external third parties are also based in many countries so their processing of your personal data may also involve a transfer and/or storage of personal data worldwide.
Whenever we transfer your personal data out of the UK and/or EEA (as applicable), we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
The following safeguards are applicable to transfer of your personal data to the following limited countries:
That’s it! You have the right, however, to refuse to have your data transferred outside the EEA or the U.K. or the Republic of South Africa (as applicable). Please contact our Privacy Officer to make that request. Please note that making this request may prevent you from being able to use a portion or all of the Services.
Marketing and promotional material from us
We may send you marketing communications by email, telephone, SMS or mail. We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant to you (we call this marketing).
You may receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing. You can always ask us to stop sending you marketing messages at any time by contacting us.
All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.
Third-party marketing and advertisements
Ignition is continuously evaluating and modifying our use of various advertising networks, which may change from time to time. In this section you will find all the advertising networks that Ignition currently uses and instructions for opting out of them. If we do additional advertising in the future, this section will be updated.
We will get your opt-in consent before we share your personal data with any third party for marketing purposes.
We use the following advertising networks from time to time:
Please also see our Cookie Policy for further information relating to the use of cookies in advertising.
Opting out
As described in the above sections, you can always ask us or third parties to stop sending you marketing communications.
Where you opt out of receiving marketing messages, this will not apply to personal data you provided to us as a result of a product/service purchase, product/service experience or other transactions
If you choose to object to the communications, unsubscribe or withdraw your consent, this will not make our processing of your personal data before you withdrew your consent unlawful.
Tracking technology (“cookies” and other similar technologies)
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies and other similar technologies we use, please see our Cookie Policy.
Limited gathering of personal data for statistical, analytical and security purposes
As previously set out in this Policy, we automatically collect personal data, such as Technical Data and Usage Data, using service providers such as HubSpot, Google Analytics, Segment and Snowflake (“Third-Party Analytics Programs”) to help us better understand your needs and the needs of Website visitors and Services Users in the aggregate. We also process such data for statistical purposes to keep track of the number of visits to the Website, the specific pages of the Website, and Users with a view to introducing improvements to the Website and Services.
The Technical Data collected using these Third-Party Analytics Programs may also be used to trace any fraudulent or criminal activity, or any activity in violation of our Terms of Use.
Email communications and compliance with anti-spam laws
Ignition uses HubSpot to manage our mailing list and send out our newsletter, and Postmark to send out emails related to various Services functions (HubSpot and Postmark, collectively the “Email Service Providers”). Personal data is transferred to the Email Service Providers in order to manage the mailing list and for the emails to be sent out properly. As described in the ‘Who we transfer your personal data to’ section above, Email Service Providers will only use your personal data for specified purposes and in accordance with our instructions. They will not transfer or sell your personal data to any other third party.
You may unsubscribe from Ignition’s mailing list at any time, by following the link at the bottom of all Ignition emails. Other types of emails, such as transactional, relational, and other emails related to certain Services functions will not have an opt-out option as they are necessary for the use of the Services.
Ignition’s practices in regards to its email are designed to be compliant with anti-spam laws, including Australia’s Spam Act 2003, New Zealand’s Unsolicited Electronic Messages Act 2007, the American CAN-SPAM Act, and the law unofficially called “CASL”, or Canada’s Anti-Spam Law (S.C. 2010, c. 23). If you believe you have received email in violation of these laws or any other anti-spam law, please contact us using the contact information further up in this Policy.
Push notifications and email notifications
This website may send you email notifications via Chatbot and/or HubSpot, to achieve the purposes outlined in this Policy.
You may opt-out of receiving email notifications by visiting your device settings.
How we protect your personal data
We have implemented very strict technical and organisational procedures for ensuring that, by default, only the personal data which is necessary for each specific purpose of the processing are processed by us. These procedures prevent your personal data from being lost; or used or accessed in any unauthorised way.
In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable supervisory authority of a suspected data security breach where the Data Protection Laws requires us to do so, and within the time frame required by the applicable Data Protection Law.
Ignition uses only industry best practices (physical, electronic and procedural) in keeping any data collected (including personal data) secure. In addition, we use third-party vendors and hosting partners to provide the necessary hardware, software, networking, storage, and related technology required to operate the Website and Services, and these third parties have been selected for their high standards of security, both electronic and physical. For example, Ignition uses Amazon AWS, a recognized leader in secure data, for hosting of the Website and Services and related data, and storage of data including personal data.
All information, including personal data, is transferred with encryption using Secure Sockets Layer (“SSL”) or Transport Layer Security (“TLS”), robust security standards for Internet data transfer and transactions. You can use your browser to check Ignition’s valid SSL security certificates on the Website.
Ignition uses Stripe for processing of secured credit card payments for payments of Subscription Fees and Professional Services Fees made through the Services. Stripe is certified as a PCI-DSS (Payment Card Industry Data Security Standard) Service Provider Level 1, the highest-volume level for credit card transaction companies.
For more details about how we protect your personal data, please visit our dedicated security page.
Supervisory authorities and complaints
Under the UK and/or EU data protection regime (as applicable), you have the right to make a complaint to the appropriate supervisory authority. If you are not satisfied with the response received or the actions taken by our Privacy Officer, or if you would like to make a complaint directly about Ignition’s data practises, we invite you to contact the supervisory authority in your country.
For example, if you are in the UK, you should contact the ICO. You can reach them in a variety of ways, including by phone (0303 123 1113 in the UK) and mail (Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF).
If you are in France, you should contact the Commission Nationale de l'Informatique et des Libertés who is the supervisory authority there. Their contact information can be found here.
The full listing of all Data Protection Authorities (the supervisory authorities) across the EEA can be found here.
If you are in Australia, you can make a complaint to the Office of the Australian Information Commissioner here. If you are in Canada, you can make a complaint to the Office of the Privacy Commissioner here. If you are in the Republic of South Africa, you have the right under POPIA to make a complaint to the Information Regulator (South Africa), whose contact information can be found here.
If you are in New Zealand, and you feel that we may have breached our obligations to you under the NZ Privacy Act, please contact the Privacy Officer in writing at the details set out above and we will work with you to resolve the issue. If you are not satisfied with the actions taken by the Privacy Officer, you can make a complaint to the Office of the New Zealand Privacy Commissioner here.
Data retention
Your personal data will only be kept for as long as reasonably necessary for the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
In some circumstances you can ask us to delete your data. Please see the section on ‘Your legal rights’ above for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Automated decision-making
Automated decisions are made by technological means, mostly based on algorithms subject to predefined criteria. Such automated decision-making, taken solely by technological means without any human intervention, may have legal effects or similarly significant effects on you.
By using our Website and/or our Services, you are giving us explicit consent to make automated decisions. If you do not consent to our making automated decisions, you must not use our Website or Services.
We may, from time to time, use automated decision-making in deciding what types of promotions to offer you. Our rationale for making automated decisions is so that we can deliver our Services to you efficiently, to enable or otherwise improve our decision-making process, and to reduce the potential harm derived from human error and/or personal bias.
Where you are subject to automated decision-making processes, you would have the right to:
Please contact us if you want to find out more about our making of automated decisions.
Changes to this Policy and your duty to inform us of changes
The date at the top of this page indicates when this Policy was last updated. Every now and then, we will have to update this Policy, and we will update it no less than once every 12 months. You can always find the most updated version at this URL, and we will always post a notice on the Website and Services if we make significant changes. If you have an account, we will also email you to tell you the Policy has been updated, and what the important changes are.
Historic versions of our privacy policy can be obtained by contacting us.
We reserve the right to make amendments to our privacy policy at any time.
Unless otherwise provided in this Policy, it is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Children’s privacy statement
The Website and Services are not intended for children under the age of 18. We do not knowingly collect any personal data from a child under 18. If we become aware that we have inadvertently received personal data from a person under the age of 18 through the Services, we will delete such information from our records.
Third party links
This website may include links to third-party websites, plug-ins, and applications. Clicking on third-party links or enabling third-party connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.