Privacy policy

This is the Privacy Policy of Dialogue Consulting Pty Ltd Australian Company Number 153 007 259 (trading as Sked Social) (“Sked Social”, “we”, “us”).

This Privacy Policy has been designed to ensure we clearly communicate to you how we treat your personal information.  We encourage you to read this Privacy Policy carefully.  It will help you make informed decisions about sharing your personal information with us.

Sked Social operates in an increasingly global marketplace where the protection of personal data is of paramount important to us, as we expand our footprint into USA, Europe and beyond.  Accordingly, we have updated this Privacy Policy to take into account the relevant data protection principles in what is widely considered to be the leading standards set by the General Data Protection Regulation (EU) 2016/679 (“GDPR”)[1].

You can access the Sked Social Service through our websites or through applications on devices.

Last updated 26 February 2020. In effect as of 26 February 2020.

Defined terms 

Capitalised terms used but not defined in this Privacy Policy are defined in our Terms of Use. This Privacy Policy is part of the Terms of Use and when you access or use the Service you agree to be bound by the Terms of Use, including this Privacy Policy. In addition, in this Privacy Policy:

  1. “Personal information” is any information or an opinion about an identified individual or an individual who can be reasonably identified from the information or opinion. Information or an opinion may be personal information regardless of whether or not it is true. information we hold which is identifiable as being about you.For the purposes of this Privacy Policy, the terms “personal information” and “personal data” have the same meaning and are used interchangeably.
  2. “Processing”, as that term is used in this Privacy Policy, is defined in Article 4 of the GDPR as:“…any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.”

Sked Social collects Personal Information

Sked Social’s Service enables users (“you”) to appoint us as your agent to schedule and send posts from your Accounts on social media Platforms such as Instagram, Facebook and Twitter. Information about how the Service works for Instagram is set out in this post.

We have several relevant lawful bases for collecting and using the information that you provide

First, we are satisfied that we possess a legitimate business interest in collecting and using your personal information.  We are a commercial enterprise which is constantly innovating and improving the user experience in the social media communications industry. We therefore believe that the collection and collation of core personal information is integral and necessary for our business to function and to provide the Service to our customers. We have also considered alternate modes of operating and weighed the balance of the impacts of our information processing on individuals.  We take the view that there is minimal or no harm to the rights and freedoms of the valued users of our Services but also we are content that this assessment applied to our employees, suppliers and partners whose Personal Information we hold.

Secondly, we are obliged to process much of the personal information we receive in order to fully perform our contractual terms and conditions with our user (customers) and suppliers (as well as with our own employees as their employer). Thirdly, on rare occasions, we will also process personal information where we need to comply with other legal obligations – for example connected with any regulatory requests made of us by a data protection authority or other regulator or perhaps in the conduct of litigation relating to a dispute where data in Sked Social’s possession or control, which may include personal information, is compelled to be provided to assist a Court.

The information we collect and hold will depend upon the services you request from us and may include the information you provide us when you purchase or try our services. This information will include your name, address, contact details, social media handles and profile information from your Accounts and other information that you include in posts on your Accounts (a lot of which would likely be regarded as personal information under the GDPR).

We derive information from communications between us and you

We collect information about you when you download trials from our range of websites (for example skedsocial.com).

The use of the facilities and services available through our websites will determine the amount and type of information we collect. The only personal information we collect when you use our websites without signing up for a service is what you tell us about yourself, for example, by completing an online form when you request information, or when you send us emails and we record your email address. If you sign up for the Service, then other personal information described above will be collected.

We log your interactions with Sked Social

When you use the Service, we automatically record information from your device, including the following (some of which would be likely regarded as Personal Information under the GDPR):

  • your Device’s IP address
  • device screen size and browser type
  • geographic location
  • system configuration information
  • search terms and pages visited
  • date & time stamps associated with transactions
  • the webpage visited before you came to our website

Sked Social tracks your usage patterns

We may use internal and external analytic and product platforms as well as cookies to better understand usage patterns on our websites and the Service so we can improve the design, user experience and relevance of our services and at times to offer additional relevant services.

Sked Social uses cookies

We use cookies primarily for record keeping and to enhance the functionality of our sites.  We may use “persistent cookies” to save your registration ID and login passwords for future logins to the Service. We may use “session ID cookies” to enable certain features of the Service, to better understand how you interact with the Service.  We deploy third party cookies from a number of external service providers such as Google Analytics when we offer the Service.

You are free to choose not to provide your personal information to Sked Social and can set your browser to non-acceptance of cookies, but it may mean that we are unable to provide you with all or some of the Service or the full functionality of our websites.

How Sked Social uses your information

We use the information we collect for the purpose disclosed at the time of collection, or otherwise as set out in this Privacy Policy. We will not use your personal information for any other purpose without first seeking your consent, unless authorised or required by law.

Generally, we will only use and disclose your personal information to:

  • verify your identity
  • establish and maintain your relationship as a customer of Sked Social
  • provide the products and services you have requested from Sked Social
  • administer and manage those products and services
  • answer your enquiries
  • comply with laws and regulations in applicable jurisdictions
  • carry out marketing or training relating to the Service

Sked Social can aggregate your non-personally identifiable information

We may make certain automatically-collected, aggregated, or otherwise non-personally-identifiable information available to third parties for various purposes, including: (i) compliance with various reporting obligations; (ii) for business or marketing purposes; (iii) for industry research or benchmarking; or (iv) anonymous data analytics and reporting and (v) to assist such parties in understanding our customers’ interests, habits, and usage patterns for certain programs, content, services, and/or functionality available through the Service.

We will not share or include your personal information in such aggregated data with any other third party unless we have your express consent to do so.

Where we store your personal information

Personal information held within the Service is stored on secure Amazon Web Services cloud services located mostly in the United States. The privacy of this data is covered by our service provider’s privacy policy.

If you do not want your personal information to be transferred to a server located in the United States, or at other secure sites nominated by Sked Social from time to time, you should not provide Sked Social with your personal information or use the Service. In future we may be able to provide alternate locations and domiciles for the storage of key servers and data sets.  If you are interested in learning more about these alternate locations, please contact us at the address below.

You may request access to your Personal Information

In most cases, you can gain access to the personal information that Sked Social holds about you, subject to some exceptions allowed by law. If you would like to check or amend your contact details, please contact us. We will deal with all good faith requests for access to personal information as quickly as possible.

Sked Social takes steps to protect your Personal Information (Security)

Sked Social is committed to protecting the security of your personal information.  We have invested resources into designing and maintaining what the GDPR rules refer to as “organisational and technical measures” – such measures help us to take reasonable precautions to protect your personal information from unauthorised access, modification or disclosure.

Your data is stored on secure servers, and all data transferred between you and the Service is encrypted. Passwords are also used internally within the business and we encourage regular updating and changing of these among our staff.

Please note that  the internet is not always a secure method of transmitting information.

Transmission of personal information over the internet is at your own risk, and you should only enter personal information to the Service within a secure environment.

In line with our security breach protocols, we will advise you at the first reasonable opportunity upon discovering or being advised of a security breach where your privacy rights and freedoms are prejudiced or compromised.

Sked Social does not store your credit card details

Sked Social’s credit card payment processors are Chargebee, Stripe and Pin Payments, which are certified to PCI Service Provider Level 1 standards.

You should refer to Stripe’s Privacy Policy, Pin Payments’ Privacy Policy and Chargebee’s Privacy Policy to ensure you are happy with them.

Sked Social never requests sensitive credit card data from our customers.  All payment card related data is sent direct from the customer’s browser to Chargebee and from there to Stripe’s or Pin Payments’ API over encrypted connections.

Our use of your personal information

We use your personal information for the following non-exhaustive list of purposes.

Providing our services

We use the information that we collect, including personal information, in order to provide our services to you, including:

  • to carry out our obligations as a result of any contract entered into between you and us and to provide you with the information and services that you request from us;
  • to provide you with marketing communications about our products and service offering;
  • to notify you about changes to the services that we offer and to directly market these services to you;
  • to administer our websites for internal operations, including troubleshooting, information analysis, testing, research, statistical and survey purposes;
  • as part of our efforts to keep our services safe and secure;
  • to measure or understand the effectiveness of our advertising and marketing;
  • for statistical and research purposes (including market research, marketing and information analysis purposes);
  • to ensure the effective operation of software and IT services procured by us (including disaster recovery); and
  • for other reasons with your consent.

How long do we keep your personal information?

We will only retain your personal information for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal information for a longer period in the event of a complaint, regulatory request to us, or if we reasonably believe there is a prospect of litigation in connection with the data we hold.

To determine the appropriate retention periods for each kind of data, we consider (i) the amount, nature and sensitivity of the personal information, (ii) the potential risk of harm from unauthorised use or disclosure of those personal details, (iii) the purposes for which they are processed, (iv) whether we can achieve those purposes through other means, and (v) the applicable legal, regulatory, tax, accounting or other requirements.

Your rights under modern data protection principles

Article 5 of the GDPR codifies several key principles which provide you the individual, with key rights.  Principles such as purpose-limitation, storage-limitation, data accuracy, data security and integrity and data minimisation are honoured by Sked Social as follows expression of your rights:

  • The right to request a copy of any Personal Information that we hold about you (essentially your “subject access rights”);
  • The right to be told, where any information is not collected directly by us, what available information exists as to the source of the information about you;
  • The right to be told of the existence of automated decision-making (and any personal profiling which we conduct for the purposes of matching people with the right recruitment opportunities);
  • The right to object to the processing of data where the processing is based on either the conditions of public interest or our legitimate business interests;
  • The right to have all personal information erased (in other words, the right to be forgotten) which practically involves the removal of your data and any account you may have with us (but please be aware it will be impossible to use the Service once you trigger such rights);
  • The right to restrict processing where you have objected to the processing;
  • The right to have inaccurate data amended or destroyed; and
  • The right to prevent processing that is likely to cause unwarranted substantial damage or distress to you.

In applying the spirit of the GDPR to all our users, employees and partners as we do, we fully expect to honour your right to ask for a copy of any personal information that Sked Social holds about you in our records, to correct any inaccuracies and to update any out-of-date information. We will provide you with a copy of the personal information undergoing processing in electronic emailable form.    Any additional copies will incur a fee to cover our reasonable costs (including our employees’ time to assist with this additional work).

This policy may be updated from time to time

Sked Social reserves the right to take professional advice, review and revise our Privacy Policy at any time, and any amended Privacy Policy is effective when we upload it onto our website or otherwise communicate it to you (potentially as part of our Terms of Use and any update to these).

How to contact our privacy officer

If you would like any further information, or have any queries, problems or complaints in relation to this Privacy Policy or our information handling practices in general, please contact our privacy officer at privacy@skedsocial.com

[1] GDPR has an extra-territorial application and as such applies to the protection of personal data relating to EU citizens wherever they may be located in the world.  Sked Social as a corporately responsible organisation is content to apply GDPR as a high general standard for our entire business, as supplemented and refined by the data protection laws applying in the specific jurisdictions and territories in which we operate.

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