At 9 Spokes, we put trust at the foundation of our client relationships and are committed to protecting the privacy of individuals whose information is in our custody. We take the security of the personal data very seriously and understand that privacy is not just an essential part of what we do, but also a core concern for our business.
9 Spokes’ policy is to comply with local laws, including General Data Protection Regulation (GDPR) to ensure compliant handling and use of personal data is maintained at all times. This includes ensuring:
- We only collect data relevant to providing you the best service
- We secure your data using industry-leading methods
- We are transparent about how we handle, store and use your data
- You are able to access and modify your personal data as needed
- You can contact us about your data at any time at firstname.lastname@example.org
For more information on 9 Spokes GDPR compliance
1. Your privacy
9 Spokes International Limited and its related companies (9 Spokes or company) takes the issue of safeguarding your privacy online seriously. 9 Spokes has created this privacy statement in order to demonstrate the company’s firm commitment to privacy.
The following discloses the company’s information gathering and dissemination practices for the 9 Spokes service (9S Service).
2. Collection of personal information.
The personal information 9 Spokes collects and stores will depend on what products and services you request from the company. This includes (but is not limited to) information provided when you submit names (including employee and subcontractor names), emails, usernames, addresses, country of residence, geographic location, log-in information, other contact details or other personally identifiable information to 9 Spokes, or when you process such information through the 9S Service or any of the Apps.
Use of the 9S Service allows you to personally monitor certain financial, personal and other information about you, your business and/or your customers which you have provided to 9 Spokes and/or an OSP through an App (User Content). To provide this service, 9 Spokes extracts User Content about your business from the Apps. 9 Spokes may also integrate such User Content with other Apps you have signed up to use through the 9S Service.
We will also collect your personal information if you make an enquiry about any aspect of 9 Spokes, if you are an actual or potential investor in 9 Spokes, request information from 9 Spokes, contact 9 Spokes through our network of sites or in any other manner, or access 9 Spokes' network of sites for any reason.
If you choose to pay for the 9S Service by credit card, we will not hold your credit card details. When you submit your details they will be transmitted directly to our secure billing and payment collection service provider, who will handle your data in accordance with its own policies.
3. Where your personal information is stored.
9 Spokes stores your information on infrastructure operated by third party cloud service providers, and maintains an email database for subscribers to company monthly e-newsletters. 9 Spokes also stores investor information with its share registry (Boardroom Pty Limited ABN 14 003 209 836) and securities dealer (Foster Stockbroking Pty Ltd ACN 088 747 148).
4. Ways we use data.
9 Spokes collects your personal information so that it can use it for various internal functions and services. This may include, but is not limited to:
- extracting User Content from any of the Apps you have signed up to use through the 9S Service;
- integrating User Content with other Apps you have signed up to use through the 9S Service;
- providing technical support and other services necessary to ensure your successful use of the 9S Service;
- if you use a Channel Partner (eg, bank or financial service provider) instance of the 9S Service, communicating with and providing assistance to the Channel Partner to ensure your successful use of the 9S Service;
- sending out feedback and surveys and addressing any issues or complaints;
- invoicing and entering into financial transactions with you;
- answering any queries about 9 Spokes and its products and services or any other offering;
- sending newsletters, advertising and promotions;
- sending special deals, promotions and offers based on users interests plus other news on 9 Spokes, including updates of new, or enhanced services;
- purposes relating to your investment in 9 Spokes, including to assess and process your application and to service your needs as an investor and shareholder; and
- confirming receipt of profile changes.
If you do not provide 9 Spokes with your personal information, one or more of the above functions or services may not be able to be provided or performed.
9 Spokes may also modify the content of any User Content by removing from such content all material that could identify you or any other person or organisation (De-identified Content). 9 Spokes may then for benchmarking and other purposes use, reproduce and adapt such De-identified Content to provide gap analysis and trend analysis for customers, as well as wider gap and trend analysis of industry verticals.
5. Disclosure of data.
9 Spokes will share your information with OSPs where it is necessary to do so to provide the 9S Services you have requested from us. If you use a Channel Partner (eg, bank or financial service provider) instance of the 9S Service, we will share your information with the Channel Partner where it is necessary to do so to provide the 9S Services you have requested from us or the Channel Partner.
9 Spokes has established a network of specialist support, business advisors and technical advisors which we refer to as Business Support Partners (BSPs). If you choose to engage with a BSP, they can provide independent advice and support to you. 9 Spokes may share your information with BSPs that you engage, or those BSPs may have access to your information in the course of their supply of services to you.
9 Spokes may also disclose your personal information to its third party service providers as described below:
- third party professional advisors, such as accountants and IT service professionals, that you have appointed, or that you have requested us to appoint;
- an OSP support provider where you have requested support in relation to an App;
- its invoicing and payment collection services to enable 9 Spokes to undertake financial transactions with you, such as invoicing, processing of payments, as well as compliance with any applicable legal, tax or regulatory obligations that may affect you or 9 Spokes;
- any entity to which 9 Spokes is required, or authorised by or under law, to disclose such information, such as responding to a formal request in a court order, judicial proceeding or subpoena;
- protect against misuse or unauthorised use of the 9S Service;
- protect the safety, or property of our stakeholders, or the public;
- in the event of a sale, merger, or acquisition of some, or all of 9 Spokes' assets or shares, your personal information could be disclosed as a part of the proposed transaction;
- where you invest in 9 Spokes, your personal information may be disclosed to 9 Spokes' share registry (Boardroom Pty Limited ABN 14 003 209 836) and securities dealer (Foster Stockbroking Foster Stockbroking Pty Ltd ACN 088 747 148) and regulators;
- printers and other companies for the purposes of preparation and distribution of documents, marketing, and for handling of mail;
- market research companies for the purpose of analysing the 9 Spokes Shareholder base and for product development and planning; and
- legal and accounting firms, auditors, management consultants and other advisers for the purpose of administering and advising on the 9S Service, 9 Spokes' shareholding and shares.
9 Spokes will not share your information with any third parties for their promotional purposes without your permission. However, you should be aware that:
- OSPs may separately collect information from you, and they may use or share that information in accordance with their own policies, which you should review separately; and
Your engagement of a BSP is independent of 9 Spokes, and BSPs may use or share your information in accordance with their own policies, which you should review separately
6. Collection of information other than personal information.
IP addresses: When you visit 9 Spokes’ web site or click on one of the company’s links, the company may automatically record information such as your IP address, operating system, browser version, date and time of your visit, pages you accessed and information you downloaded. This information may be used to generate usage statistics, ensure that the company’s site and emails are accessible to the widest possible audience and to assist in improving the quality and usability of the company’s website. 9 Spokes may also use IP addresses to track abuse of our system.
Links: When 9 Spokes provides you with links in emails, they may include a special tracking code unique to you, which allows 9 Spokes to determine which content and advertisements are most popular. This data may be shared in aggregate form; however, it will never be shared in individual form.
If you have chosen to identify yourself to 9 Spokes, the Company uses session cookies containing encrypted information to allow the Company to uniquely identify you. Each time you log into the Services, a session cookie containing an encrypted, unique identifier that is tied to your account is placed your browser. These session cookies allow the Company to uniquely identify you when you are logged into the Services and to process your online transactions and requests. Session cookies are required to use the Services.
9 Spokes uses persistent cookies that only the Company can read and use to identify browsers that have previously visited the Company’s Web site. When you purchase the Services or provide the Company with personal information, a unique identifier is assigned you. This unique identifier is associated with a persistent cookie that the Company places on your Web browser. The Company is especially careful about the security and confidentiality of the information stored in persistent cookies. For example, the Company does not store account numbers or passwords in persistent cookies. If you disable your Web browser’s ability to accept cookies, you will be able to navigate the Company’s Web site, but you will not be able to successfully use the Services.
Third Party Cookies: 9 Spokes engages third parties to track and analyse usage and volume statistical information from individuals who visit the Company’s Web site. 9 Spokes may also use other third-party cookies to track the performance of Company advertisements. The information provided to third parties does not include personal information, but this information may be re-associated with personal information after the Company receives it.
9 Spokes may also contract with third-party advertising networks that collect IP addresses and other Web Site Navigational Information on the Company’s Web site and emails and on third-party Web sites.
Pixel Tags: A pixel tag, also known as a clear GIF or web beacon, is an invisible tag placed on certain pages of our website but not on your computer. When you access these pages, pixel tags generate a generic notice of that visit. They usually work in conjunction with cookies, registering when a particular computer visits a particular page. If you turn off cookies the pixel tag will simply detect an anonymous website visit.
Cookies help us enhance navigation and the functionality of our website, to securely maintain a session for existing clients accessing password-protected areas, and to personalize aspects of a visitor's experience.
7. Overseas disclosure.
We are likely to disclose your personal information to our related bodies corporate in Australia, New Zealand and other territories for the purposes set out above. Where required to provide the 9S Services you have requested from us, we may also disclose your personal information to OSPs in the country in which they are located. As you may choose to use a range of Apps available through the 9S Service, and as we may change those Apps from time to time to provide you with the most effective service, we cannot list the countries in which those OSPs may be located. We will use all reasonable efforts to provide the location in which a particular OSP is located if you make such a request.
We and our related bodies corporate will handle your personal information in compliance with the law of the jurisdictions from which your personal information is disclosed and received. For example, if personal information is disclosed from Australia to New Zealand, that personal information will be handled in compliance with the Australian Privacy Act 1988 (Cth) and the Australian Privacy Principles, and the New Zealand Privacy Act 1993 and the Information Privacy Principles.
Some of the countries to which we may disclose personal information, and some of the countries in which an OSPs are located, may not have the same or substantially similar privacy laws to those in the jurisdiction from which you provided your personal information to us.
If we disclose your personal information to organisations located in a jurisdiction other than the jurisdiction from which you provided your personal information, we may not require organisations to which we disclose that personal information to comply with similar privacy laws to the jurisdiction from which you provided your personal information, and accordingly your personal information may not receive the same protections that it would in the jurisdiction from which you provided your personal information to us.
By providing your personal information to us, you consent to our disclosure of your personal information to organisations in those countries even though it may not receive the same protections that it would in the jurisdiction from which you provided your personal information to us. You may request us not to transfer your personal information to the countries listed above, or a country in which a relevant OSP is located, but if you do so we may not be able to provide the 9S Services.
8. Third-party links.
This site (and 9 Spokes emails) contains links to other sites, including to those of the OSPs. 9 Spokes is not responsible for the privacy practices or the content of such websites.
We store personal information in electronic storage facilities, and use some physical records. We have taken numerous steps to protect your personal information from misuse, interference and loss, and unauthorised access, modification or disclosure.
While 9 Spokes uses encryption technology and a range of other security measures to protect your information, please be aware no security mechanism is 100% secure.
9 Spokes provides users with an opportunity to let it know about their experience; we may post their first name with their review without obtaining their consent and without reviewing the material. 9 Spokes is not responsible for any personal information that a user selects to include within their review.
11. Access and correction of your personal information.
\You can ask to obtain access to your personal information that 9 Spokes holds, although where permitted under applicable law we may not provide such information to you. It is important to 9 Spokes that the personal information held about you is accurate, complete and up to date. If you would like your personal information corrected or deleted, please email email@example.com with your updated information. If you are an investor in 9 Spokes, please contact Boardroom Pty Limited to access and/or update personal information associated with your shareholding in 9 Spokes.
12. Data retention.
9 Spokes will retain your information for as long as needed to provide the 9S Services to you. If you wish to request that we no longer use your information to provide you with services, contact us at firstname.lastname@example.org. 9 Spokes will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
13. Contacting us.
Last reviewed: August 2016.