We want you to be fully informed about your rights, and how Geopolitical Intelligence Group uses your data; for example we will cover things such as your user profile, any financial transactions and our interactions with travel management companies and security providers on your behalf.
What is Geopolitical Intelligence Group?
Geopolitical Intelligence Group – which we’ll refer to as ‘Geopolitical Intelligence Group’ or ‘GIG’ in this document – also comprises our subsidiary, Praesidium Advisory Group, is a product and service provider headquartered in Sydney, Australia.
European Residents: The GDPR is the new European Union data privacy law that greatly strengthens data privacy protections for individuals located in the EU. The key obligations under the GDPR include Notice, Individual Rights, and Retention.
Privacy rights under the EU data protection law include:
a) Right of confirmation (to confirm whether or not Personal Information concerning the user is being processed),
b) Right of access (the right to request what Personal Information is stored about the user and obtain a copy of that said information),
c) Right of erasure (the right to request that any Personal Information concerning the user be erased without delay when no longer required, or when the user withdraws consent),
d) Right of rectification (the right to rectify any inaccurate information concerning the user),
e) Right to data portability (the right to receive the Personal Information concerning the user, which was provided to NSI, in a readable format),
f) Right to object (the right to object the processing of the Personal Information concerning the user unless we can demonstrate compelling legitimate grounds for the processing which overrides the interests, rights, and freedoms of the user/data subject, or for the establishment, exercise or defence of legal claims),
g) Right of restriction of processing (the right to restrict processing where the accuracy of the Personal Information is contested by the user/data subject for a period enabling the controller to verify the accuracy of the Personal Information; or the processing is unlawful and the user/data subject opposes the erasure of the Personal Information and requests instead the restriction of their use instead; or we, the controller, no longer need the Personal Information for the purposes of the processing, but they are required by the user/data subject for the establishment, exercise or defence of legal claims), as set out in Articles of the General Data Protection Regulations of the EU.
With most web browsing software, by modifying your browser preferences you have the choice to accept all cookies, to be notified when a cookie is set, or to reject all cookies. If you choose to reject all cookies you will be unable to use those Services from the Company that require registration in order to participate.
California Residents: Under the California Consumer Privacy Act of 2018 (“CCPA“), California residents have certain rights around our collection, use, and sharing of their personal information. Geopolitical Intelligence Group does not sell your personal information and will not do so in the future without providing you with notice and an opportunity to opt-out of such sale as required by law. Similarly, we do not offer financial incentives associated with our collection, use, or disclosure of your personal information. Geopolitical Intelligence Group collects various categories of personal information when you use our website, including contact details and geolocation data.
If you are a resident of California, you have the right to request to know what personal information has been collected about you, and to access that information. You also have the right to request deletion of your personal information, though exceptions under the CCPA may allow Geopolitical Intelligence Group to retain and use certain personal information notwithstanding your deletion request. You may send your request by email to firstname.lastname@example.org. We will not discriminate against you for exercising your rights under the CCPA. An agent may submit a request on your behalf, but you must verify that your agent is authorised to do so.
Separate from the CCPA, California’s Shine the Light law gives California residents the right to ask companies what personal information they share with third parties for those third parties’ direct marketing purposes. We do not disclose your personal information to third parties for the purpose of directly marketing their goods or services to you unless you request such disclosure. If you have any questions regarding this policy, or would like to change your preferences, you may contact us at email@example.com.
Nevada Residents: Under Nevada law (SB 220) there is a requirement for website operators to provide a way for Nevada consumers to opt-out of the sale of certain information that the website operator may collect about them. We do not sell your personal information to third parties as defined in Nevada law, and will not do so in the future without providing you with notice and an opportunity to opt-out of such sale as required by law. If you have any questions regarding our data privacy practices or our compliance with Nevada data privacy law, please contact us at firstname.lastname@example.org.
Reasons we collect data
The law on data protection sets out a number of different reasons for which a company may collect and process your personal data, including:
In specific situations, we can collect and process your data with your consent. For example, when selecting a specific package or subscription. When collecting your personal data, we will always make clear to you which data is necessary in connection with a particular service.
In certain circumstances, we need your personal data to comply with our contractual obligations.
If the law requires us to, we may need to collect and process your data. For example, in matters relating to fraud, we can pass on details to law enforcement.
In specific situations, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests, such as marketing or client feedback requests.
When do we collect your personal data?
a) When you visit any of our websites.
b) When you make an online purchase (Intelligence Package/Subscription).
c) When you create a user login and profile.
d) When you pay an invoice for a product or service by phone.
f) When you engage with us on social media.
g) When you contact us by any means with queries, complaints etc.
h) When you ask us to email you information about a product or service.
i) When you book any kind of appointment with us or book to attend a Geopolitical Intelligence Group event.
j) When you choose to complete any surveys or feedback requests we may send you.
k) When you comment on or review our products and services online, by phone or email.
l) Any individual may access personal data related to them, including opinions. So if your comment or review includes information about the individual/third party supplier who provided that service, it may be passed on to them if requested.
m) When you fill in any forms. For example, contact forms on our website.
n) When you’ve given a third-party permission to share with us information they hold about you.
o) We may collect data from publicly-available sources (such as Credit Reference Agencies) when you have given your consent to share information or where the information is made public as a matter of law.
p) When you use our offices which usually has CCTV systems operated for the security of both us and our visitors. These systems may record your image during your visit.
What sort of personal data do we collect?
a) If you have a user profile: your name, contact details, email address, location, IP address and travel itinerary and booking details. For your security, we’ll also keep an encrypted record of your login password.
b) Details of your interactions with us through our Global Security Operations Centre, Account Managers, online, email and telephone.
c) Copies of documents you provide to prove your age or identity (where the law requires this), which in the case of your passport will include details of your full name, date of birth, place of birth, gender, nationality and facial image.
d) Details of your visits to our websites, and which site you came from to ours.
e) Data from publicly available lists and third parties that you have agreed can share data with us.
f) Your comments and product or service reviews.
g) To deliver the best possible web experience, we collect technical information about your internet connection and browser as well as the country and telephone code where your computer is located (IP address), the web pages viewed during your visit, and any search terms you entered.
h) Your social media username, if you interact with us through those channels, to help us respond to your comments, questions or feedback.
We’ll only ask for and use your personal data collected for delivering the services we are contractually obliged to do, recommending products and services of interest and to improve your browsing and internet interactions with us. It is always your choice whether you share such details with us.
How and why do we use your personal data?
To provide the best possible customer experience, we need to get the richest picture we can of who you are by combining the data we have about you. We then use this to offer you products and services that are most relevant to you.
The data privacy law allows this as part of our legitimate interest in understanding our customers and providing the highest levels of service.
Remember, if you choose not to share your personal data with us, or refuse certain contact permissions, we might not be able to provide some services you’ve asked for or we are contractually obliged to deliver.
Here’s how we’ll use your personal data and why:
a) To process any orders that you make by email, website, app or by phone. If we don’t collect your personal data for payment, we won’t be able to process your order and comply with our contractual obligations. (Details may be passed to a third party to process a payment or supply a service that you have ordered, and as such, we may need to keep your details in order to fulfil contractual obligations such as a refund).
b) To respond to your queries, refund requests and complaints. Handling the information you sent enables us to respond. We may also keep a record of these to inform any future communication with us and to demonstrate how we communicated with you throughout. We do this on the basis of our contractual obligations to you, our legal obligations and our legitimate interests in providing you with the best service and understanding how we can improve our service based on your experience.
c) To protect our business and you from fraud and other illegal activities. This includes using your personal data to maintain, update and safeguard your platform user profile. We’ll also monitor your browsing activity with us to quickly identify and resolve any problems and protect the integrity of our websites. We’ll do all of this as part of our legitimate interest.
d) To protect people, premises, assets and our business from crime, a CCTV system is operated which records images for security. This is done on the basis of a legitimate business interest.
e) To process payments and to prevent fraudulent transactions. We do this on the basis of our legitimate business interests. This also helps to protect our customers from fraud.
f) If we discover any criminal activity or alleged criminal activity through use of CCTV, fraud monitoring and suspicious transaction monitoring, we will process this data for the purposes of preventing or detecting unlawful acts. We aim is to protect the individuals we interact with from criminal activities.
g) With your consent, we will use your personal data, preferences and details of your transactions to keep you informed by email, web, text, telephone about relevant products and services including tailored special offers, discounts, promotions, events, competitions and so on.
You are free to opt out of hearing from us by all or any of these channels at any time.
a) To send you communications required by law or which are necessary to inform you about our changes to the services we provide you. (Related to updates to products or services and other notices that relate to your purchase).
b) To administer any of our marketing promotions or competitions which you enter based on your consent given at the time of entering.
c) To develop, test and improve the systems, services and products we provide to you. We’ll do this on the basis of our legitimate business interests.
d) To comply with our contractual or legal obligations to share data with law enforcement.
e) To send you survey and feedback requests to help improve our services. These messages will not include any promotional content and do not require prior consent when sent by email or text message. We have a legitimate interest to do so as this helps make our products or services more relevant to you.
You are free to opt out of receiving these requests from us at any time by notifying us at email@example.com. To process your security support requests (for example in the event of an SOS – emergency evacuation). Sometimes, we’ll need to share your details with a third party that is providing a service (such as an executive protection service provider, airline or hotel). We do so to deliver our contractual obligations with you, and without sharing your personal data we’d be unable to fulfil your request.
Combining your data for personalised direct marketing
We want to bring you offers and promotions that are most relevant to your interests at particular times. We do this by combining your personal data gathered across Geopolitical Intelligence Group as described above. For this purpose we also combine the data that we collect directly from you with data that we obtain from third parties to whom you have given your consent to pass that data onto us – such as the publicly available data lists mentioned above.
How we protect your personal data
We take the protection of data seriously and apply strict counterespionage methodologies to protect data and our website. We know how much data security matters to all our customers. We will treat your data with the utmost care and take all appropriate steps to safeguard it.
We secure access to our websites using ‘HTTPS’ technology and access to your personal data is password-protected and secured by SSL encryption. We regularly monitor our system for possible vulnerabilities and attacks, and we carry out penetration testing to identify ways to further strengthen security.
How long will we keep your personal data?
Whenever we collect or process your personal data, we’ll only keep it for as long as is necessary for the purpose for which it was collected.
At the end of that retention period, your data will either be deleted or anonymised, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning.
Who do we share your personal data with?
We sometimes share your personal data with trusted third parties such as payment transaction providers, security service providers, for fraud management, email marketing companies for the management of communications, and so on.
Here’s the policy we apply to those organisations to keep your data safe and protect your privacy:
a) We provide only the information they need to perform their specific services.
b) They may only use your data for the exact purposes we specify in our contract with them.
c) We work closely with them to ensure that your privacy is respected and protected at all times.
d) Data may be released to a third party in fulfilment of our contract with that third party in a situation where you are a data subject for an organisation that has a contract with the third party and that third party has sub-contracted all or part of that service to us.
e) If we stop using their services, any of your data held by them will either be deleted or rendered anonymous.
Sharing your data with third parties for their own purposes:
We will only do this in very specific circumstances, for example:
a) With your consent, given at the time you supply your personal data, we may pass that data to a third party for their direct marketing purposes.
b) For fraud management, we may share information about fraudulent or potentially fraudulent activity in our premises or systems. This may include sharing data about individuals with law enforcement bodies.
c) We may also be required to disclose your personal data to the police or other enforcement, regulatory or Government body, in your country of origin or elsewhere, upon a valid request to do so. These requests are assessed on a case-by-case basis and take the privacy of our clients into consideration.
e) For further information please contact us at firstname.lastname@example.org.
Where your personal data may be processed
Sometimes we will need to share your personal data with third parties and suppliers outside Australia.
If you are based outside Australia and place an order with us, we will transfer the personal data that we collect from you to Geopolitical Intelligence Group in Australia in accordance with the Australian Privacy Principals.
European Residence: Protecting your data outside the EEA
The EEA includes all EU Member countries as well as Iceland, Liechtenstein and Norway. We may transfer personal data that we collect from you to third-party data sub-processors in countries that are outside the EEA.
If we do this, we have procedures in place to ensure your data receives the same protection as if it were being processed inside the EEA. For example, our contracts with third parties stipulate the standards they must follow at all times. If you wish for more information about these contracts, please contact us at email@example.com.
What are your rights over your personal data and how do I exercise them?
An overview of your different rights
You have the right to request:
b) Access to the personal data we hold about you; there may be a small administrative charge.
c) The correction of your personal data when incorrect, out of date or incomplete.
d) Erasure of your data (also known as the right to be forgotten).
e) That we stop using your personal data for direct marketing (either through specific channels, or all channels).
f) That we stop any consent-based processing of your personal data after you withdraw that consent.
You have the right to request a copy of any information about you that Geopolitical Intelligence Group holds at any time and also to have that information corrected if it is inaccurate.
If we choose not to action your request, we will explain to you the reasons for our refusal.
Your right to withdraw consent
Whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent.
Where we rely on our legitimate interest
In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data.
You have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels. We must always comply with your request.
Checking your identity
How can you stop the use of your personal data for direct marketing?
There are the ways you can stop direct marketing communications from us: Click the ‘unsubscribe’ or ‘opt-out’ link in any email communication that we send you. We will then stop any further emails from that division; or write to Data Protection Officer, Geopolitical Intelligence Group, PO BOX 471, Parramatta NSW 2124 Australia.
Please note that you may continue to receive communications for a short period after changing your preferences while our systems are fully updated.
Contacting the Information Commissioner
If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint in Australia with the Office of the Australian Information Commissioner.
You can contact them by calling +61 1300 363 992 or go online to https://www.oaic.gov.au/privacy/privacy-complaints/ (opens in a new window; please note we can’t be responsible for the content of external websites).
If you are based outside Australia, you have the right to lodge your complaint with the relevant data protection regulator in your country of residence.
If you live outside Australia
Geopolitical Intelligence Group is a corporation headquartered in Sydney, Australia. If you are visiting our website outside of Australia, please be aware that your information will be transferred to, stored, and processed in Australia where our servers are located, and our central database is operated. We may also need to share information with internal personnel located in different geographic locations in order to achieve our contractual and legal responsibilities.
We may also share, as controller or as processor performing at the direction of our clients, your personal data with third parties (within or outside your country of residence) who perform services on our behalf, including without limitation out technology partners, payment processors, administrative personnel, providers and professional advisors. This is to enable us to supply the goods or services you have requested.
The data protection and other laws of Australia and other countries might not be as comprehensive as those in your country. By visiting and using our services or providing your personal data to us, you expressly consent to the processing of your personal data by us or on our behalf.
By dealing with us, you are giving your consent to this overseas use, transfer and disclosure of your personal data outside your country of residence for our ordinary business purposes.
This may occur because our information technology storage facilities and backup servers are located outside your country of residence and could include storage of your personal data on servers in Australia.
Google Analytics provides us with an evaluation about how the site is being used to enable Geopolitical Intelligence Group to compile reports on how the site is being used in order to assist us to deliver more meaningful content for the visitors to our site. We do not collect (nor allow any third party to collect using the site) personally identifiable information or associate any data gathered with any personally identifiable information, nor link or seek to link any cookie information with any IP address or with the identity of visitors to the site. Google Analytics does not identify who you are, it only tracks your movements on the Geopolitical Intelligence Group’s website. More information can be found at: https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage.
We may use advertising cookies to deliver ads that we believe are more relevant to you and your interests. These cookies remember what you have looked at on the site and other sites and may be combined with other information acquired from third parties. For more information about targeting and advertising cookies and how you can opt-out, visit http://www.google.com.au/policies/technologies/ads/.
The Web Site is a general audience site and does not offer Services directed at children. Should an individual whom we know to be a child under age 18 send personal information to us, we will delete or destroy such information as soon as reasonably possible. We do not knowingly collect Personal Information from children under the age of 18. By providing an y Personal Information to us, you represent and warrant that you are at least 18 years of age. If you are under the age of 18, we require that you do not provide any Personal Information to us. If you are a parent or guardian of a child under the age of 18 who has provided information to our site, please contact us at firstname.lastname@example.org.
How to contact us
Or write to us at Data Protection Officer, Geopolitical Intelligence Group, PO BOX 471, Parramatta NSW 2124 Australia