Privacy Policy

This Privacy Policy was last updated on 01 March 2022.

 

Welcome!

 

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). 

 

Some important terms

 

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. 

 

About us 

 

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:  

  • Practice Ignition Limited based in the UK (company number 09361126);
  • Practice Ignition (Canada) Ltd based in Canada, (company number BC1015063);
  • Practice Ignition Inc. based in the US (state file number 5615436);
  • Practice Ignition Limited (NZ) based in New Zealand (NZCN 5834091); and
  • Practice Ignition Pty Limited based in South Africa (Enterprise number: K2019621276),

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.

 

Contacting us

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 Emma Crawford-Falekaono contactable at emma@ignitionapp.com |  +447 4973 36642.

 

 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

 

 

Your legal rights 

 

Under the GDPR, you have the following rights under certain circumstances in relation to your personal data. 

 

  • Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: 
    1. if you want us to establish the data’s accuracy;
    2. where our use of the data is unlawful but you do not want us to erase it;
    3. where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
    4. you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your personal data to you or to a third party. We will provide you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use, or where we used the information to perform a contract with you.
  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdrew your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.

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:

  • The right to be notified that personal data about you is being collected and to be notified when personal data has been accessed or acquired by an unauthorised person;
  • The right to withdraw at any time your consent for Ignition to process your personal data;
  • The right to have your personal data erased from Ignition’s records;
  • The right to access your personal data and any relevant information around its processing and use;
  • The right to have a copy of your personal data given to you in an easy-to-read format so that you can transfer it to another data processor;
  • The right to have your personal data corrected or updated if you believe it is inaccurate or out of date;
  • The right to object, on reasonable grounds, relating to your particular situation, to the processing of your personal data;
  • The right to opt out of marketing communications we send you, at any time;
  • The right to know whether Ignition sells or shares your personal data (and if so, who gets it). Please refer to that information elsewhere in this Policy, though you can contact our Privacy Officer if you need additional information or clarifications;
  • The right to demand that Ignition not sell your personal data;
  • The right to restrict the processing of your personal data if it is inaccurate or if our processing or use of it is against the law;
  • The right to refuse any marketing or advertising targeted at you by Ignition; and
  • The right to institute civil proceedings regarding the alleged interference with the protection of your personal data.


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.

 

The personal data we collect about you 

 

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

 

  • Identity Data includes first name, last name, username or similar identifier, marital status, title, job title, company, location, date of birth and gender.
  • Contact Data includes billing address, email address and telephone numbers.
  • Financial Data includes bank account and payment card details, such as credit card number and expiry date and card security code (CVC).
  • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, access times, webpage from which you came, webpage(s) or content you accessed, time zone settings and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
  • Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
  • Usage Data includes information about how you use our website, products and services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

 

How your personal data is collected

 

We use different methods to collect data from and about you including through: 

  • Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  1. apply for our products or services;
  2. create an account on our website;
  3. give us feedback or contact us; or
  4. request marketing to be sent to you.
  • Automated technologies or interactions. As you interact with the website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data using certain service providers, cookies, server logs/log files and other similar technologies such as tracking pixels, web beacons and tags. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our Cookie Policy for further details.
  • Third parties or publicly available sources. We may receive personal data about you from various third parties (including public sources) worldwide as set out below:
  1. Technical Data from parties such as:
    1. analytics providers;
    2. search information providers; and
    3. advertising networks.
  2. Contact, Financial and Transaction Data from providers of technical and payment services.
  3. Identity and Contact Data from data brokers or aggregators.
  4. Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based in the UK, and similar sources in other jurisdictions (as applicable).
  5. Identity and Contact Data from third party applications, from which Users of the Services may import information about their Clients to send Proposals and facilitate the payment of Professional Services Fees.

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.

 

How we use your personal data 

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: 

  • Where we need to perform the contract we are about to enter into or have entered into with you. This includes processing your data where it is necessary for the performance of a contract to which you are a party, or to take steps at your request before entering into such a contract.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. Legitimate interest means the interest of our business in conducting and managing our business to enable us to give you the best product/service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
  • Where we need to comply with a legal obligation that we are subject to. Under the AU Privacy Act, NZ Privacy Act and PIPEDA, the legal basis for our processing is your informed consent, and by submitting this personal data you acknowledge having granted this consent to Ignition. To the extent that we processed your personal data before the commencement date of the aforementioned data protection legislation (as applicable to your jurisdiction), you consent to us continuing to process such personal data in accordance with this Policy.

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 CATEGORYWHAT WE USE IT FOR (THE “PURPOSE” OF PROCESSING)LEGAL BASIS FOR PROCESSING UNDER THE GDPR AND POPIA
  • Identity Data
  • Contact Data
  • Profile Data
  • Marketing and Communications Data
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
  • Performance of a contract with you
  • Necessary for our legitimate interests (for example, to keep our records updated and to study how customers use our products or services)
  • Your consent in giving us this information
  • Identity Data
  • Contact Data
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
  • Performance of a contract with you
  • Your consent in giving us this information
  • Identity Data
  • Contact Data
  • Profile Data
  • Technical Data
  • Usage Data
  • Marketing and Communications Data
To be responsive as possible to you, for example, when providing support for the Services or answering your customer queries 
  • Necessary for our legitimate interests (for example, providing you with a good service) and for your legitimate interests (for example, to receive assistance promptly)
  • Your consent in giving us this information
  • Identity Data
  • Contact Data
  • Profile Data
  • Marketing and Communications Data
To manage your account and Subscription, enable logging in to the Services, and customize your use of the Services
  • Performance of a contract with you
  • Your consent in giving us this information
  • Identity Data
  • Contact Data
  • Financial Data
  • Transaction Data
  • Marketing and Communications Data

 

To process and deliver your order including:

  • Managing the payments of your Subscription Fees and Additional Client Fees (if applicable)
  • Processing payments or debit payments for the Professional Fees, in order to transfer the Professional Fees to the Professional Services Provider

To collect and recover money owed to us

  • Performance of a contract with you
  • Necessary for our legitimate interests (for example, to recover debts due to us)
  • Your consent in giving us this information
  • Identity Data
  • Contact Data
  • Technical Data
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)
  • Necessary for our legitimate interests (for example, running our business, providing and administering IT services, and preventing fraud)
  • Necessary to comply with our legal obligations
  • Identity Data
  • Contact Data
  • Profile Data
  • Usage Data
  • Marketing and Communications Data
  • Technical Data
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to youNecessary 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)
  • Technical Data
  • Usage Data
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)
  • Identity Data
  • Contact Data
  • Technical Data
  • Usage Data
  • Profile Data
  • Marketing and Communications Data
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 websiteNecessary for our legitimate interests (for example, to develop our products/services and grow our business)

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. 

 

Change of purpose 

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.

 

Aggregated Data 

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. 

 

Special Categories of Personal Data

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).

 

Who we transfer your personal data to

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. 

  • External third parties including:
  1. professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK, EU/EEA, Australia, South Africa, Canada (or any other jurisdiction as applicable) who provide consultancy, banking, legal, insurance, and accounting services;
  2. law enforcement, regulators or other public authorities based in the UK, EU/EEA, Australia, South Africa, Canada (or any other jurisdiction as applicable) if, for example:
    1. we are required by applicable law in response to lawful requests, including to meet national security or law enforcement requirements;
    2. we believe it is necessary in order to investigate, prevent, or take action regarding illegal activities, fraud, or situations involving potential threats to the safety of any person, or any violation of Ignition’s Terms of Use;
    3. we believe it is necessary to investigate, prevent, or take action regarding situations that involve abuse of the Services infrastructure or the Internet in general (such as voluminous spamming or denial of service attacks); and
  3. our service providers acting as sub-processors which we use for time to time, as set out in the table below.  A full list of all the sub-processors used by Ignition along with their security accreditations can be found on our website.
  • Internal third parties within the Practice Ignition Group (including a parent company, subsidiaries, joint ventures, or other companies under common control with Ignition) acting as joint controllers or processors and provide services including IT and system administrative services and undertake certain reporting functions.
  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change of ownership or restructuring happens to our business, then the new owners may use your personal data in the same way as set out in this Policy. It may also be the case that a new privacy policy may apply to you, in which case we will inform you accordingly.

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 CATEGORYWHO WE TRANSFER IT TOWHAT THEY DO WITH IT
  • Identity Data
  • Contact Data
  • Profile Data
  • Marketing and Communications Data
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
  • Identity Data
  • Contact Data
  • Profile Data
  • Marketing and Communications Data
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


 

  • Identity Data
  • Contact Data
  • Profile Data
  • Technical Data
  • Usage Data
  • Marketing and Communications Data
Companies providing customer support and chat services, such as  IntercomStore it so that we may retrieve it to contact you to provide support
  • Identity Data
  • Contact Data
  • Profile Data
  • Technical Data
  • Usage Data
  • Marketing and Communications Data
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
  • Identity Data
  • Contact Data
  • Profile Data
  • Marketing and Communications Data
Our business partners, specifically Intuit and Xero when you have been referred to us by themCommunicating with you and record-keeping
  • Identity Data
  • Contact Data
  • Financial Data
  • Transaction Data
  • Marketing and Communications Data
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

  • Identity Data
  • Contact Data
  • Profile Data
  • Usage Data
  • Marketing and Communications Data
  • Technical Data
Companies that provide online advertising networks, like Google and FacebookShow 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
  • Technical Data
  • Usage Data
Companies that provide data analytics, such as  HubSpotGoogle 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:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
  • If we transfer your personal data to any other country which is not subject to an adequacy decision of the UK or the European Commission (as applicable) regarding an adequate level of protection of personal data, we will ensure that there is a legal basis and, if required, a relevant safeguard method for such data transfer so that your personal data are treated in a manner that is consistent with, and respects the applicable laws and regulations on data protection in the UK or the EEA (as applicable).
  • Where we use certain service providers outside of the UK and/or the EEA (as applicable), we may use specific contracts approved for use in the UK and/or the EEA (as applicable) which give personal data the same protection it has in the UK and/or the EEA (as applicable).

The following safeguards are applicable to transfer of your personal data to the following limited countries: 

  • The United States. Your personal data is only transferred to companies in the United States that: (1) have signed agreements with us or have informed us that they are GDPR-compliant; and (2) have concluded the Standard Contractual Clauses for the transfer of personal data outside the EEA.
  • Canada. We may transfer personal data to our operations in Canada, but Canada has been determined to have an “adequate level of protection” for your personal data under European data protection law.
  • Australia. We may transfer personal data to our operations in Australia, but when we do so we rely on binding corporate rules to protect your personal data.


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 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. 

 

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:

  • Google AdWords and Display Network. Ignition uses the remarketing features of interest-based advertising of Google AdWords that delivers you advertisements that will be of particular interest to you, based on your browsing and activity history interacting with the Website and Services. These advertisements will appear on third-party websites around the web. Google uses specific cookies to allow them to serve these ads around the web, and you may prevent this type of advertising by deleting the appropriate Google cookie through your browser, though this may not be permanent. For a more permanent solution, you may opt out of such Google advertising by adjusting your Google ad settings or using the WebChoices online opt-out tool.
  • Facebook Custom Audience. Ignition uses Facebook Custom Audience to display advertisements to you on Facebook or in Facebook Messenger that will be of interest to you, and by visiting or using the Website you consent to this use. Facebook may collect or receive information from the Website and Services and other applications and websites and use that information to provide measurement services and targeted ads. If you do not want to receive such Facebook advertisements, you can opt-out of such advertising by adjusting your Ad Preferences settings while logged in to Facebook.
  • LinkedIn Advertising. Ignition uses LinkedIn Advertising to display advertisements to you on LinkedIn that will be of interest to you, and by visiting or using the Website you consent to this use. LinkedIn may collect or receive information from our and use that information to provide measurement services and targeted ads. If you do not want to receive such LinkedIn advertisements, you can opt-out of such advertising by following LinkedIn's instructions or using the WebChoices online opt-out tool.

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 HubSpotGoogle AnalyticsSegment 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:

  • Obtain an explanation about any decision taken as a result of automated decision-making and express your point of view regarding such a decision;
  • Challenge such a decision by asking us to reconsider a decision or take a new decision on a different basis; or
  • Request and obtain human intervention on such processing.

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.