Privacy Policy

Headway is committed to the protection of your privacy and personal information.

This Privacy Policy sets out how we, Headway, process your personal data. Your data protection and privacy are the most important things to us, we take it very seriously and all data captured will be used and held in accordance with the Australian Privacy Act, 1988 and the EU General Data Protection Regulation (GDPR).

You own the information you provide Headway

By providing your personal information, you grant permission to Headway, the right to use this information in accordance with the service we provide to you or based on your consent in relation to any marketing activities we undertake.

We will collect this consent when you first provide your personal data and you can withdraw that consent at any time.

Purpose of processing your personal data

Completing a registration form

To establish and maintain a relationship with you an for our internal accounting processes.

Updating your personal profile

You don’t have to provide additional information on your profile; however, profile information helps you to get more from the platform.

Mapping your DNA

To provide you with your 12-month plan and to connect you with people and resources to support you.

Data analytics and profiling

To understand how people use our service so we can improve it.

Collecting Feedback

To improve our service to you such as fixing problems or developing improvements.

Email Notifications

To communicate information related to your account.

Email Marketing

To send you information and marketing messages about our services.

The legal bases on which we rely are:

Contract

Processing of your personal data is necessary for us to administer the relationship between you and us.

Consent

Only with your express consent, will we disclose de-identified or aggregated personal information to third parties who work with us or with you, such as:

  • Your Sponsor
  • Your Headway Administrator, who may be someone in Human Resources, Memberships or Students/Alumni department/organisation, depending on whether you are in a company, an association or an educational institution.
  • Your colleagues and management team
  • Education and training providers
  • Third-party service providers

When we process your personal data based on your consent you have the right to withdraw that consent at any time without reason. You can do so using the facilities in the software, or in the case of marketing communications, via the unsubscribe link or you can contact us via the Contact form.

Legitimate Interest

We will use legitimate interest for profiling and segmentation in order to send relevant, targeted communications. Our legitimate interests are to communicate with our users to keep them informed, to grow our platform and improve it for all our users.

Your rights

Right to be informed

You have the right to be told about the collection and use of the personal data you provide. This privacy policy sets out the purpose for which we process your personal data, the activity by which it is captured, the reason for capturing it and the lawful basis by which we process it.

Right of access

You have the right to know whether we are processing your personal data, and to a copy of that data. We would need as much information as possible to enable us to locate your data. Upon written request we will endeavour to provide this data as soon as we can and within 30 days.

Right to rectification

You have the right to have any incorrect personal data corrected or completed if it is incomplete. If we identify an error, you will be notified within 2 working days. Upon written request we will endeavour to rectify this error as soon as we can and within 30 days.

Right to erasure

This right is often referred to as the right to be forgotten. Upon your request in writing, we will request confirmation using your email address as per our system to verify that this is the action you wish to take as it cannot be undone. Upon positive confirmation we will remove your account from the Headway platform as well as personally identifiable data as soon as we can and within 30 days.

Right to portability

Upon your request in writing (e.g. email or Contact Us form), we will provide an extract of your personal data within 30 days. Extracts will be limited to one of the following structured formats: CSV, XML or JSON. Headway reserves the right to recover costs incurred for multiple requests over a 12 month period.

Right to restrict processing

You have the right to ask us to restrict processing of your data. We will look at any request and inform you of our decision as soon as we can and within 30 days of receiving the request.

Right to object

You have the right to object to our processing of your personal data based on:

  1. Legitimate interests/legal task – your objection should be based on your particular situation. We can continue to process the data if we can demonstrate compelling legitimate grounds which override your interests.
  2. Direct marketing – you have an absolute right to ask us to stop processing for the purposes of direct marketing. We will action your request as soon as possible.
  3. Scientific/historical research and statistics – your objection should be based on your particular situation. If we are conducting research where the processing is necessary for the performance of a public task, we can refuse to comply with your objection.

Legal disclosures

It is possible that we will be required by law to disclose personal information by authorities with jurisdiction over NSW, Australia.

Unless directed not to do so, we will notify you if this has occurred.

Cookies

A cookie is a small piece of information sent by a web server to a web browser, which enables the server to collect information from the browser. Find out more about cookies on allaboutcookies.org.

We use cookies to identify you when you visit this website and to keep track of your browsing patterns.

Our use of cookies also allows registered users to be presented with a personalised version of the site, carry out transactions and have access to features and information about their account.

Most browsers will allow you to turn off cookies. If you want to know how to do this, please refer to the help menu on your browser. Please note however that turning off Headway cookies will prevent you from accessing the platform as we won’t be able to manage your access.

We will acknowledge and investigate any complaint about the way we manage personal information.

Cookies we use

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Google Analytics to track web traffic to and within the site. You can switch this off on your browser witout impact to you.
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Essential to allow the site to recognise your session in the system once logged-in. If you switch this off Headway DNA will not function for you.

Changes to this policy

This privacy policy is regularly reviewed and will be updated when necessary. If we make any significant changes to the policy, we will communicate these to you.

If you have any questions about this Privacy Policy or if you wish to make a complaint about our collection, use or disclosure of your personal information under this Privacy Policy, please get in touch via our contact page or email us at support@headwaygroup.com


Last updated 03 December 2018