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6clicks Privacy Policy

Privacy Policy

 

6clicks’ commitment to privacy

6clicks Trading Pty Ltd ACN 634 263 166 and its subsidiaries and affiliates in Australia, the United Kingdom, and the United States of America (6clicks) take your privacy seriously and are committed to responsible privacy practices. 

This document referred to as our Privacy Policy describes how 6clicks manages your personal data including details of what types of personal data 6clicks collects, how 6clicks collects your personal data, the purposes for which 6clicks uses your personal data, and to whom your personal data is disclosed. 

In this Privacy Policy, "we" and "us" refers to 6clicks, and "you" refers to any individual about whom we collect personal data. Terms not otherwise defined in this Privacy Policy have the meaning given to them in the 6clicks EULA General Terms.  

 

6clicks’ roles

6clicks acts in different ways when processing data: 

  • 6clicks acts as a controller of your personal data when you sign up for our products and services, visit our website or interact with us through other channels (for example in person events). We use this data for a variety of purposes, including to provide our products and services to you, contact you about relevant content, and improve and promote our products and services; 

  • 6clicks acts as a processor when our customers use our products and services to collect and process personal data in connection with their business activities. In this case, we act as a processor (or service provider) on behalf of our customers (who are controllers of personal data) under the 6clicks Data Processing Agreement published on our website and included in the EULA General Terms; and 

  • 6clicks also acts as a controller when we collect and process personal data about individuals in their professional capacity, and make that information available to customers for their own business activities. This includes personal data we may collect indirectly about you, such as from publicly available sources, our customers, or other third parties. For more information see the “What types of personal data do we collect?” section below. 

What is personal data?

In this Privacy Policy “personal data” means any information relating to an identified or identifiable individual.  

 

What types of personal data do we collect?

The types of personal data 6clicks collects about you will depend on the purpose for which the information is collected.

Customers and users of our products and services 

6clicks may collect the following types of personal data: 

  • first name and last name;
  • email address;
  • job title; 
  • usage data such as metrics; 
  • your mobile phone information (such as model, version and operating system) where you access our products and services via your mobile phone); 
  • payment information (where you register for paid products/services); and 
  • testimonials or comments you provide us for our website.

Like most websites and technology services delivered over the internet, 6clicks also collects general analytics and other technical information (such as your IP address, device type, unique device identification numbers, browser types, Internet Service Provider details, geolocation data, browsing preferences, searches, and usage of 6clicks’ websites or products) arising from your use of 6clicks’ websites or products. 

 

Information we collect from other sources

We may receive information about you, or users of your 6clicks account (if applicable), from our global network of partners. We may receive this data through a number of ways, including through our deal and lead registration processes. 

We may also collect information about you through our partner co-marketing partnerships. For example, you may sign up to a webinar or download a white paper published by 6clicks and a 6clicks co-marketing partner. 

6clicks may collect personal data about other individuals who are not customers of 6clicks. This includes customers and members of the public who participate in events we are involved with; individual service providers and contractors to 6clicks; and other individuals who interact with 6clicks on a commercial basis.  

The kinds of personal data we collect will depend on the capacity in which you are dealing with 6clicks.  If you are participating in an event we are managing or delivering, we may take images or audio-visual recordings which identify you. 

 

Information we process on behalf of our customers 

When our customers use our products they may process personal data such as first and last name, email address, job title, physical address, phone number, or other information about you. We call the information that our customers submit or collect via the product ‘User Data’ under our EULA General Terms. 

6clicks generally stores and processes information about and on behalf of our customers on our servers as a processor (or service provider) and in accordance with our EULA General Terms and Data Processing Agreement.  Each customer controls and is responsible for the information they process using the Subscription Scope and for complying with any regulations or laws that require providing notice, disclosure, and/or obtaining consent prior to transferring the personal data to 6clicks for processing purposes.

 

Prospective employees/applicants 

We collect personal data when recruiting personnel, such as your name, contact details, qualifications, and work history. Generally, we will collect this information directly from you.  We may also collect personal data from third parties in ways which you would expect (for example, from recruitment agencies or referees you have nominated). Before offering you a position, we may collect additional details such as your tax file number and pension/superannuation information (or their equivalent in your jurisdiction) and other information necessary to conduct background checks to determine your suitability for certain positions. 

 

Visitors to our website

The way in which we handle the personal data of visitors to our websites is discussed below. 

 

How do we collect personal data?

Often 6clicks will collect your personal information directly from you, including when you:

  • use 6clicks’ website, products or services;
  • apply to work with 6clicks or are engaged by 6clicks as a contractor;
  • communicate with 6clicks by email, by telephone, in person, via a website or otherwise.

In some cases 6clicks may also collect personal data from:

  • 6clicks partners; 
  • our affiliated and related companies;  
  • publicly available sources;
  • third party entities who assist us in operating our business; and
  • other third parties (for example, from referees if you apply for a position as an employee or contractor with us). 

6clicks also collects and uses personal data for market research purposes and to innovate our delivery of products and services. 

 

Why do we collect, use, and disclose personal data? 

6clicks collects personal data reasonably necessary to carry out our business, to assess and manage our customers' needs, and provide services including our governance risk and compliance solution. We may also collect information to fulfill administrative functions associated with these services, for example billing, entering into contracts with you and/or third parties, and managing customer relationships.

6clicks will only collect, use, and disclose personal data about you if it has lawful basis to do so, for example: 

  • where you have given 6clicks your consent;
  • where processing of your personal data is necessary for the performance of a contract with you such as the EULA General Terms in connection with the Subscription Scope; 
  • to meet 6clicks’ legal obligations; and 
  • to pursue 6clicks’ legitimate business interests.

6clicks may use or disclose your personal data: 

  • for the purposes for which 6clicks collected it (and related purposes which would be reasonably expected by you); 
  • for other purposes to which you have consented; and
  • as otherwise authorised or required by law. 

Some of the specific purposes for which 6clicks collects, uses and discloses personal data are as follows: 

  • to provide its products and services to its users; 
  • to enable the proper operation and functionality of its products and services; 
  • to improve its products and services; 
  • to verify your identity (for example, if you request access to the personal data 6clicks holds about you); 
  • to consider you for a job at 6clicks (whether as an employee or contractor) or other relationships with 6clicks; 
  • to provide goods or services to you or to receive goods or services from you; 
  • to address any issues or complaints that 6clicks has or you have regarding our relationship; 
  • to comply with its legal obligations; 
  • to develop and improve the quality of its websites and products and customise its websites and products according to your preferences, tailor search results, and show relevant advertising; 
  • for direct marketing purposes (see the “Direct marketing” section below); and 
  • to contact you regarding the above, including via electronic messaging such as SMS and email, by mail, by phone or in any other lawful manner. 

If 6clicks is unable to collect your personal data then 6clicks may not be able to provide you with the products, services and opportunities that depend on the collection of that information. 

 

To whom do we disclose personal data? 

6clicks may disclose your personal data to third parties in connection with the purposes described above. 

This may include disclosing your personal data to the following types of third parties: 
  • 6clicks related or affiliated companies; 
  • 6clicks partners such as our resellers, referrers, managed service providers and advisors; 
  • third party service providers we use to support our websites, products, and services; 
  • any potential third party acquirer of 6clicks or its business or assets, and advisors to that third party; 
  • its professional advisers (such as lawyers, accountants or auditors) and insurers; 
  • its employees, contractors and third party service providers who assist 6clicks in performing its functions and activities e.g. payment systems operators and financial institutions, cloud service providers, data storage providers, telecommunications providers and IT support services providers; 
  • organisations authorised by 6clicks to conduct promotional, research or marketing activities; 
  • third parties to whom you have authorised 6clicks to disclose your information (e.g. referees); and 
  • any other person as required or permitted by law. 

If 6clicks discloses your personal data to third parties it will use reasonable commercial efforts to ensure that such third parties only use your personal data as reasonably required for the purpose of disclosure and in a manner consistent with applicable laws, for example by (where commercially practical) including suitable privacy and confidentiality clauses in 6clicks’ agreement with a third party service provider to which 6clicks discloses your personal data. 

 

How does 6clicks interact with you via the internet? 

You may visit our websites (https://www.6clicks.com/) without identifying yourself. If you identify yourself (for example, by providing your contact details in an enquiry), any personal data you provide to 6clicks will be managed in accordance with this Privacy Policy. 

6clicks’ websites use cookies. A “cookie” is a small file stored on your computer's browser, which assists in managing customised settings of the website and delivering content. We collect certain information such as your device type, browser type, IP address, pages you have accessed on our websites and on third-party websites. You are not identifiable from such information.  

You can use the settings in your browser to control how your browser deals with cookies. However, in doing so, you may be unable to access certain pages or content on our website. 

6clicks' websites may contain links to third-party websites. 6clicks is not responsible for the content or privacy practices of websites that are linked to our website. 

 

Can you deal with 6clicks anonymously?  

6clicks will provide individuals with the opportunity of remaining anonymous or using a pseudonym in their dealings with us where it is lawful and practicable (for example, when making a general enquiry). Generally, it is not practicable for 6clicks to deal with individuals anonymously or pseudonymously on an ongoing basis. If we do not collect personal data about you, you may be unable to utilise our services or participate in our events, programs or activities we manage or deliver. 

 

Do we disclose your personal data overseas? 

International transfers within the 6clicks group

To facilitate our global operations, we may transfer information that may include personal data to other 6clicks affiliates or related companies who act as subprocessors, where we have operations for the purposes described in this Privacy Policy. 

This Privacy Policy will apply even if we transfer personal data to other countries. We have taken appropriate safeguards to require that your personal data will remain protected wherever it is transferred. When we share personal data of individuals in the European Economic Area ("EEA"), Switzerland or the United Kingdom ("UK") within and among 6clicks’ affiliates, we rely upon the Standard Contractual Clauses (approved by the European Commission and Swiss authorities) and UK Addendum to the Standard Contractual Clauses (approved by the UK authorities) where required.   

We also have additional safeguards where appropriate (such as commercial industry standard secure encryption methods to protect customer data at rest and in transit, TLS for 6clicks hosted sites, web application firewall protection, and other appropriate contractual and organisational measures), as described more in detail in the 6clicks Knowledge Base. 

 

International transfers to third parties 

Some of the third parties described in this Privacy Policy, which provide services to us under contract, are based in other countries that may not have equivalent privacy and data protection laws to the country in which you reside.

When we share personal data of individuals in the EEA, Switzerland or UK with third parties, we use a variety of legal mechanisms to safeguard the transfer including the European Commission-approved Data Privacy Framework Standard Contractual Clauses, as well as additional safeguards where appropriate. For transfers to or from the United Kingdom, we make use of the UK Addendum. 

For transfers to or from Canada, we make use of the standard contractual clauses. With respect to personal data received from or transferred to Canada, 6clicks is subject to the regulatory enforcement powers of the Office of the Privacy Commissioner of Canada. 

 

How do we protect your personal data? 

6clicks uses a variety of security technologies and procedures to help protect your personal data from unauthorised access, use or disclosure. We secure the personal data you provide on computer servers in a controlled, secure environment, protected from unauthorised access, use or disclosure. All personal data is protected using appropriate physical, technical and organisational measures. For more on security at 6clicks please refer to Annexure 2 of our Data Processing Agreement and our security documents and certifications available within the 6clicks Knowledge Base.  

6clicks engages service providers (subprocessors) to facilitate the delivery of our products and services including the storing of your personal data, including Microsoft Azure and Azure Storage.  6clicks recommends that you review these companies’ privacy policies to understand how they use and store your personal data. For more information regarding our subprocessors please refer to Annexure 3 of our Data Processing Agreement.  

 

Direct Marketing

6clicks may use and disclose your personal data for the purpose of direct marketing to you if: 

  • you have consented to 6clicks doing so; or 
  • it is otherwise permitted by law. 

Direct marketing involves communicating directly with you for the purpose of promoting goods or services, upcoming promotions and events, or other opportunities that may interest you.  Direct marketing can be delivered by a range of methods including mail, telephone, email or SMS.   

You can unsubscribe from 6clicks’ direct marketing, or change your contact preferences, by contacting 6clicks (see the “How to contact us” section below). 

 

How long do we keep your Personal Data? 

Generally, 6clicks will retain your personal data where we have an ongoing legitimate business need to do so (for example, as needed to comply with our legal obligations, resolve disputes and enforce our agreements)unless a longer retention period is required by law.  

If you have elected to receive marketing communications from us, we retain information about your marketing preferences for a reasonable period of time from the date you last expressed interest in our content, products, or services, such as when you last opened an email from us or ceased using your 6clicks account.  We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created. 

The data we process on behalf of customers connection with the Subscription Scope is stored and secured according to the 6clicks EULA General Terms and the 6clicks Data Processing Agreement. 

6clicks may retain your personal data for a longer period of time if it is reasonably necessary to comply with 6clicks’ legal obligations, resolve a dispute or maintain security. 

When personal data is no longer required, 6clicks will take reasonable steps to delete the personal data from 6clicks’ systems or de-identify the personal data. We will delete this information at an earlier date if you so request, as described in the "Your Rights and Choices" section. 

 

Your Rights and Choices

Depending on your location and applicable laws, you may have the following data protection rights: 

  • Access, Correction or Deletion: You can request access, correction, updates or deletion of your personal data; 
  • Objection or Restriction: You can object to our processing of your personal data, ask us to restrict processing of your personal data or request portability of your personal data; and 
  • Withdraw Consent. If we have collected and processed your personal data with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal data conducted in reliance on lawful processing grounds other than consent. 

To exercise any of these rights, please contact 6clicks as described in the “How to contact us” section below. 

 

How you can access and seek correction of your Personal Data?

We will take reasonable steps to ensure that the personal data we collect, use or disclose is accurate, complete and up-to-date. You can help us to do this by letting us know if you notice errors or discrepancies in information we hold about you and letting us know if your personal details change.  

However, if you consider any personal data we hold about you is inaccurate, out-of-date, incomplete, irrelevant or misleading you are entitled to request correction of the information. Please contact 6clicks as described in the “How to contact us” section below. After receiving a request from you, we will take reasonable steps to correct your information. 

You may seek access to personal data 6clicks holds about you by contacting 6clicks as described in the “How to contact us” section below.   

6clicks will provide access to that information in accordance with applicable legal requirements, subject to certain exemptions which may apply.  6clicks may require that the person requesting access provide suitable identification and where permitted by law 6clicks may charge a fee for giving access to your personal data. 

If you’d like your information to be removed from our commercial dataset, or would like to opt out from the sharing of your Personal Data for our advertising and marketing activities, please contact 6clicks as described in the “How to contact us” section below. 

 

How can you complain about a privacy issue? 

You may make a privacy complaint in relation to personal data 6clicks holds about you by contacting 6clicks as described in the “How to contact us” section below.  

If you make a privacy complaint, 6clicks’ Data Protection Officer or another suitable staff member of 6clicks will investigate the matter and attempt to resolve it as soon as reasonably possible. 

The 6clicks Data Protection Officer will first consider your complaint to determine whether there are simple or immediate steps which can be taken to resolve the complaint. We will generally respond to your complaint within a week. 

If your complaint requires more detailed consideration or investigation, we will acknowledge receipt of your complaint within a week and endeavor to complete our investigation into your complaint promptly. We may ask you to provide further information about your complaint and the outcome you are seeking. We will then typically gather relevant facts, locate and review relevant documents, and speak with individuals involved. 

In most cases, we will investigate and respond to a complaint within 30 days of receipt of the complaint. If the matter is more complex or our investigation may take longer, we will let you know. 

If you consider your privacy concerns have not been resolved satisfactorily by 6clicks, or you wish to obtain more information on privacy requirements: 

 

Changes to this policy

6clicks may change this policy from time to time at its discretion.  This policy was last updated in October 2024.  If 6clicks makes further updates to this policy, 6clicks will post the amended policy on its websites and, if the changes are material, notify you directly (for example, by sending you an email notification).  Your continued dealings with 6clicks, for example use of its websites, products or services, will signify your agreement to this policy as amended. 

 

How to contact us

If you have a query, concern, or complaint about the manner in which your personal data has been collected or handled by 6clicks or would like to request access to or correction of the personal data 6clicks holds about you please contact 6clicks’ Data Protection Officer via email to support@6clicks.io.

 

 

Data Processing Agreement

  Download a copy of our Data Processing Agreement here.