Last Updated: 13/04/2023
1. About Forge Studio
Forge Studio, a part of the PROPGEN PTY LTD based in Australia, is committed to protecting the privacy of our users.
2. Commitment to Privacy
This Policy applies to the Personal Data we collect when you purchase or use any of our Products and Services, including visits to our website at forgestudio.global (Website).
In addition, this Policy applies to Personal Data we collect or use about job applicants or employees who are California residents (“Job Applicant and Employee Data”). We collect, use, and disclose Job Applicant and Employee Data for different reasons than other Personal Data we may collect, use, or disclose. For more information about how we collect, use, or disclose Job Applicant and Employee Data, please scroll down to the section titled “Additional Information for Job Applicants and Employees About the CCPA”. If you would like more information, please contact us using the information in section “20. Contact Us” below.
4. What Personal Data Do We Collect About You and Why?
Personal Data We Collect Directly from You.
If you request a document or other specific content, subscribe to our newsletters, or complete the web form on the Contact Us page, we ask you to fill out a brief form that requests information such as your name, company, title, e-mail address, and telephone, as well as your areas of interest and of course the content of any message to us. Similarly, if you provide comments on any blog or community page we may host, you will need to log in – although you may do that via your social network account such as Facebook, Twitter, or LinkedIn.
Of course, we collect information from you when you respond to an online or a telemarketing survey.
Personal Data We Receive from Information Readily Available in the Public Domain.
PROPGEN PTY LTD affirmatively collects and receives BCI from various third-party sources, including our partners. BCI is information pertaining to businesses and individuals that is readily available in the public domain, including but not limited to: business name, first and last name, business telephone number, job titles, work e-mail addresses and location in which a business is located and an individual works. We collect this information to provide our products and services to our customers.
Personal Data We Collect Automatically.
5. How We Use Personal Data
We use Personal Data for the following purposes:
To fulfil or meet the reason you provided the Personal Data. To communicate with you about your purchase or use of our products and services, to respond to your inquiries or request for information, and for other marketing and client service purposes.
To tailor the content and information that we may send through development of your profile, to offer content customisation, and personalised help and instructions, and to otherwise personalise your experiences while visiting our Website and to help connect you with others who may have products or services in which you’ve expressed an interest.
For marketing purposes. For example, we may use your Personal Data, such as your email address or phone number, to send you content, surveys, news and newsletters, or to otherwise contact you about our products and services or information we think may interest you. We may also use automatically collected Personal Data to determine whether and how you have interacted with any email messages we have sent you.
To provide our customers with access to a database of accurate business data records including BCI which enables them to promote their goods and services employing direct marketing to the right people (i.e., decision makers, influencers, champions) in other businesses, and to promote your business so it can be found when it is searched for by other businesses.
To better understand how visitors access and use our Website, both on an aggregated and individualised basis, in order to improve our Website. For testing, research, analysis, and our development of our products and services. To evaluate or conduct a merger, divestiture, restructuring, reorganisation, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by us about our Website users is among the assets transferred.
If we would like to use your Personal Data for any purposes other than those described, we will obtain your prior consent unless there are other lawful bases for processing your Personal Data (please see below at Section 7).How do we collect and use information that is not Personal Data?
We operate statistics gathering software on the website to collect information about the number of visitors coming to the site. Usage data will be collected and correlated between your logged in and logged out sessions. No identifying information is collected by this software. We use this information to improve our own technical structure and performance and to determine which areas of the website are most popular.
From time to time, we may sell or disclose information you provide to us that is not Personal Data (and does not disclose your identity) to any person for any purpose at our sole discretion, including to people or companies located outside Australia. For example, we may sell, disclose or use information you provide to us that is not Personal Information to:
• determine what advertising, promotional materials, products or services are likely to be of most interest to you or other website users and visitors; and
• assist third parties to monitor general consumer trends in various areas.
We may also modify your Personal Data (through encryption or other de-identifying techniques) so that it is in a form from which you cannot be identified and sell or disclose such modified information to any person for any purpose, including to people or companies located outside Australia.
6. How We Disclose Your Personal Data
We may disclose your Personal Data within PROPGEN PTY LTD, and externally with third parties as discussed below.
When we disclose your Personal Data, we enter into a contractually binding agreement with the recipient of the Personal Data which requires the recipient to comply with the European Union General Data Protection Regulation (“GDPR”), the UK GDPR, the Canadian Personal Data Protection and Electronic Documents Act (“PIPEDA”), as well as any implementing regulation thereof of any jurisdiction, and any applicable data privacy laws and regulations of the United States or any US state, Canada, or any other relevant jurisdictions.
Internally, Within FORGE STUDIO. We may disclose your Personal Data internally, within PROPGEN PTY LTD. This may involve disclosing your Personal Data outside of the EEA and the UK. All PROPGEN PTY LTD subsidiaries and affiliates have entered into an intra-company transfer agreement committing to compliance with the GDPR, UK GDPR, PIPEDA, as well all other applicable data privacy laws.
Other Website Visitors. If you post a comment on the blog pages or any other public area of our Website, your comment and identity will be available to, and searchable by, all users of our Website. This does not apply to any personal data you provide in a Contact Us inquiry.
Upon Your Request or Instruction. When you request content from us or we present you with an online or telemarketing survey, we will typically obtain your direction to disclose limited Personal Data between PROPGEN PTY LTD subsidiaries or affiliates, or specified business customers.
Service Providers. We may disclose the personal data we collect from you to third party vendors, service providers, sub-processors, contractors or agents who perform functions on our behalf. We only disclose Personal Data to our service providers for the purpose of performing services on our behalf. We require that these parties only process the Personal Data for limited and specified purposes consistent with this Policy.
Customers and Partners. We may disclose your Personal Data with our customers and partners under lawful bases, including Consent and/or Legitimate Interest (please see Section 7, below).
Business Transfers. If PROPGEN PTY LTD or any of its subsidiaries or affiliates are acquired by or merged with another organisation, if substantially all of our assets are transferred to another organisation, or as part of a bankruptcy proceeding, we may transfer the personal data we have collected from you to the other organisation.
In Response to Legal Process. We also may disclose the Personal Data we collect from you in order to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a court order or a subpoena.
If we would like to disclose your Personal Data for any purposes other than those described, we will obtain your prior consent, unless there are other lawful bases for processing your Personal Data (please see Section 7, below).
7. Lawful Bases for Processing Personal Data
We process Personal Data in accordance with all applicable data privacy laws and regulations. If you are located in the European Union or Switzerland, the GDPR applies.
If you are located in the UK, the UK GDPR applies. Under either, there are six lawful bases for processing of Personal Data:
• Consent. The processing is based on demonstrable, freely given, informed, and revocable consent for specific purposes.
• Performance of a Contract. The processing is necessary for the performance of a contract.
• Legal Obligation. The processing is necessary to comply with the law.
• Vital Interests. The processing is necessary to protect human lives.
• Public Task. The processing is necessary to perform a task in the public interest.
• Legitimate Interests. The processing is necessary for our legitimate interests, where those interests do not override the data protection interests, rights, and freedoms of the individuals.
Consent, Performance of a Contract, and Legitimate Interests are the three lawful bases that are most appropriate when we process Personal Data:
Generally, Consent is the most appropriate lawful bases when: Individuals freely consent to our processing of their Personal Data after being fully informed (e.g., specific purposes, right to easily withdraw at any time).
Generally, Performance of Contract is the most appropriate lawful bases when: Our Products and Services are purchased and used, we need to process Personal Data to fulfill our obligations under the written agreements.
Generally, Legitimate Interests is the most appropriate lawful bases when:
• Owing to the nature of our business and the size of our databases, it is impractical for us to contact every individual to obtain his/her consent.
• The processing we do is unlikely to affect the fundamental rights and freedoms of the individuals whose data we process and make available to our Customers and Partners because:
1. Under our Business-to-Business (B2B) model, we only process BCI taken from the public domain (e.g., work e-mail addresses);
2. We provide BCI to help our customers promote their offerings to other businesses (i.e., B2B);
3. It is in the interest of the professionals whose BCI we process for us to maintain accurate information so that businesses can better reach the most relevant business contacts, thus promoting the legitimate interests of the individual and our customers; and
4. You always have the right to opt-out and restrict all further processing of your Personal Data.The controllers of our B2B databases are our subsidiary[ies] Leadiro UK Limited and DS Intelligence LLC.
8. How Long We Keep Your Personal Data
We typically only retain your Personal Data for the time necessary to realize our legitimate business purposes and to comply with the law.
Currently, our systems do not recognize browser “do-not-track” requests. You may, however, disable certain tracking as discussed in this section (e.g., by disabling cookies).
What are Cookies and how do they benefit you?
Cookies are small text files that are placed on your computer or mobile device when you browse websites.
Cookies are not actual programs or software. When you visit a website, it stores a snippet of text from your visit; the next time you visit, this text is retrieved by the website, and it enables the website to recognize you. Cookies can be used differently depending on the actual website visited. Cookies allow websites to store such things as user preferences. You can think of cookies as providing a “memory” for the website, enabling it to recognize a user and respond appropriately. Cookies on our Website do NOT store any personally identifiable information such as names, addresses, email addresses or phone numbers.
For more details see: https://www.allaboutcookies.org/
Our cookies help us:
• Make our Website work as you would expect
• Remember your settings during visits
• Allow you to share pages (names/blog articles) with social networks like Facebook or Twitter
• Continuously improve our Website for you
• Directly identify any individual who visits our Website. Any personally identifiable information (e.g., IP addresses and location) is processed anonymously using Google Analytics
• Collect any sensitive information, without your express permission
What information is kept by the cookie?
A cookie will typically hold:
• The name of the website that it has come from
• How long the cookie will stay on your computer or mobile device
• A value – usually a randomly generated unique number
• Website function cookies
• Social media cookies
• Third party and advertising cookies
• Analytics cookies
More about Our Cookies
Website function cookies, such as session or preference cookies:
• These only last until you close your browser
• They are not stored on your hard drive
• They are usually used to track the pages that you visit so that information can be customized for you during that visit
• These are stored on your hard drive until you delete them, or they reach their expiry date
• These may, for example, be used to remember your preferences when you use our Website
• Holding information once you have logged in to save you from having to re-login each time you visit a different page during your session
• Once you log off or close the browser the session cookie will be removed
Our Website, like most websites, includes functionality provided by third parties. A common example is an embedded YouTube or Vimeo video. Disabling these cookies is likely to break the functions offered by these third parties.
Social Media Website Cookies
To facilitate easy sharing or liking of content on social network platforms such Facebook and Twitter, we have included sharing buttons on our Website. The privacy implications on this will vary from social media network to social media network and will be dependent on the privacy settings you have chosen on these networks.
Third Party Analytics: Anonymous Visitor & behaviour Statistics Cookies
• How visitors reached our Website (e.g., from a search engine, an advertisement, from social media site etc.)
• The activity of users on our Website such as the number of pages viewed, time spent on individual pages, the pages visitors exit from our Website
• How often visitors return to our Website
• Visitor technology used (e.g., browser, operating system, device, etc.)
These statistics help us make our Website as user-friendly as possible, to ensure a good experience for all visitors.
• Google Analytics. A program that helps us measure site usage details including the examples above;
• Website Improvement Cookies. We regularly test new designs or site features on our Website. We do this by showing slightly different versions of our Website to different people and anonymously monitoring how visitors respond to these different versions. Ultimately this helps us to offer you a better website;
o Third-party vendors, including Google, show ads on websites on the internet;
• You may opt-out of the DoubleClick cookie by visiting the Google advertising opt-out page or you may opt-out of Google Analytics by visiting the Google Analytics opt-out page.
Third Party Advertising
As you browse our Website, advertising Cookies will be placed on your computer or mobile device so that we can understand your interests. Our display advertising partners then enables us to present you with retargeting advertising on other websites based on your previous interaction with our Website. The techniques our partners employ do NOT collect personal information such as your name, email address, postal address, or telephone number. You can visit this page to opt-out of AdRoll’s and their partner’s targeted advertising.
Turning Cookies Off
You can switch cookies off by adjusting your internet browser settings to stop accepting cookies.
Please be aware though that turning off cookies will impair the performance of many websites and not just ours.
Local Storage Objects. We may use Flash Local Storage Objects (“Flash LSOs”) to store your website preferences and to personalize your visit. Flash LSOs are different from browser cookies because of the amount and type of data stored. Typically, you cannot control, delete, or disable the acceptance of Flash LSOs through your web browser. For more information on Flash LSOs, or to learn how to manage your settings for Flash LSOs, go to the Adobe Flash Player Help Page, choose “Global Storage Settings Panel” and follow the instructions. To see the Flash LSOs currently on your computer, choose “Website Storage Settings Panel” and follow the instructions to review and, if you choose, to delete any specific Flash LSO.
Clear GIFs, pixel tags and other technologies. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web pages. We may use clear GIFs (a.k.a. web beacons, web bugs or pixel tags), in connection with our Website to, among other things, track the activities of Website visitors, help us manage content, and compile statistics about Website usage. We and our third party service providers also use clear GIFs in HTML e-mails to our customers, to help us track e-mail response rates, identify when our e-mails are viewed, and track whether our e-mails are forwarded.
10. User Generated Content
We invite you to post content on our Website and provide responses to our blog, including your comments, pictures, and any other information that you would like to be available on our Website. If you post content to our Website, all of the information that you post will be available to all visitors to our Website. If you post your own content on our Website, your posting may become public and we cannot prevent such information from being used in a manner that may violate this Policy, the law, or your personal privacy.
11. Third-Party Links
Our Website may contain links to third-party websites and social media. Any access to and use of such linked websites is not governed by this Policy, but instead is governed by the privacy policies of those third-party websites. We are not responsible for the information practices of such third-party websites.
12. Security of My Personal Data
We have implemented technical and organisational measures to protect the information we collect from loss, misuse, and unauthorised access, disclosure, alteration, and destruction. Please be aware that despite our efforts, no data security measures can guarantee 100% security.
You should take steps to protect against unauthorised access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorised password activity.
13. Access to My Personal Data
Consistent with applicable laws or regulations, we make good faith efforts to provide you with access to your Personal Data and either to correct this data if it is inaccurate or to delete such data at your request if it is not otherwise required to be retained by law or for legitimate business purposes.
Consistent with applicable laws or regulations, you may modify Personal Data that you have submitted, or that we have obtained from other sources by contacting us and requesting a copy of whatever identifiable information you have provided to us. Please note that copies of information that you have updated, modified or deleted may remain viewable in cached and archived pages of the Website for a period of time.
14. What Choices Do I Have Regarding Use of My Personal Data?
We may send periodic solicitations or informational emails to you. You may opt-out of such communications by following the opt-out instructions contained in the e-mail. Based on the requirements of data privacy laws (e.g., GDPR), it can take up to 30 business days for us to process opt-out requests. If you opt-out of receiving emails about recommendations or other information we think may interest you, we may still send you e-mails about your account or any services you have requested or received from us.
16. Children’s Privacy
Our Website is not intended for children under the age of 16.
We do not knowingly collect information from children. In the event that we learn that we have collected personal on the Website from a child under age 16, we will delete that information promptly. If you believe that we might have any information from a child under 16, please contact us at email@example.com.
17. Visiting our Website from Outside the United States
If you are visiting our Website from outside the United States, please be aware that your information will typically be transferred to, stored, and processed in the United States, United Kingdom, Ireland, Philippines, New Zealand, Australia and France where our servers are located and our central database is operated. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country. Please be assured that we seek to take reasonable steps to ensure that your Personal Data is protected regardless of where we hold it.
18. Visiting to Our Website from the European Economic Area (EEA) and the United Kingdom (UK)
The Lawful Basis for Processing Personal Data of EEA and UK Residents
When we collect information about you through our Websites, our emails, surveys, and so forth, the lawful basis on which we process your Personal Data is performance of a contract between us, namely, to provide you with the content, to help connect you with relevant vendors, and other information in response to your request.
To the extent that we transfer Personal Data from any legal entity we may have in the EEA or UK to a jurisdiction outside the EEA or UK that has not been adduced by the European Commission as providing adequate data protections, we will ensure that such Personal Data is safeguarded through appropriate contractual terms, and technical and organizational measures.
Rights for EEA and UK Residents
In addition, if you are a resident of the EEA or the UK, you have the right to:
Find out if we use your Personal Data, to access your Personal Data, and receive copies of your Personal Data.
Withdraw any express consent that you have provided to the processing of your Personal Data at any time without penalty.
Access your Personal Data and have it corrected or amended if it is inaccurate or incomplete.
Obtain a transferable copy of some of your Personal Data which can be transferred to another provider when the Personal Data was processed based on your consent.
If you believe your Personal Data is inaccurate, no longer necessary for our business purposes, or if you object to our processing of your Personal Data, you also have the right to request that we restrict the processing of your Personal Data pending our investigation and/or verification of your claim.
Request your Personal Data be deleted or restricted under certain circumstances. For example, if we are processing your Personal Data on the lawful basis of your consent and have no other lawful basis to process such, you may request your personal data be deleted when you withdraw your consent.
If you wish to exercise any of these rights or raise a complaint on how we have handled your Personal Data, please first contact us at the Contact Us details below. If you wish to make a complaint with a supervisory authority, their contact information may be found at https://edpb.europa.eu/about-edpb/about-edpb/members_en (if in the European Union) or https://ico.org.uk/make-a-complaint/ (if in the UK).
19. California Residents
California “Shine The Light” law
Pursuant to California’s “Shine The Light” law (California Civil Code § 1798.83), California residents are entitled to request, once a year and free of charge, certain information regarding what types of their Personal Data may be disclosed to third parties and, in some cases, affiliates, for those third parties’ and affiliates’ own direct marketing purposes. Under this law, a business is to either provide California customers certain information upon request or permit California customers to opt-out of this type of disclosure. You may request this information by contacting us at firstname.lastname@example.org and indicate in the e-mail subject line, “California Shine The Light Request.” Please include your mailing address, state of residence and e-mail address with your request.
The California Consumer Privacy Act (CCPA)
The California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act, gives California residents enhanced rights with respect to their Personal Data that is collected by businesses.
First, California residents may opt-out of having their Personal Data sold to other persons or parties.
Second, California residents have a right to know:
What specific pieces of information a business has about the resident;
Categories of Personal Data it has collected about the resident;
Categories of sources from which the Personal Data is collected;
Categories of Personal Data that the business sold, shared, or disclosed for a business purpose about the resident;
Categories of third parties to whom the Personal Data was sold, shared, or disclosed for a business purpose; and
The business or commercial purpose for collecting, selling, or sharing Personal Data.
Third, California residents can request that the Personal Data a business has collected from them be deleted from the business’s systems and records, subject to certain exceptions.
Fourth, California residents can request that inaccurate Personal Data a business maintains about them be corrected.
PROPGEN PTY LTD is covered under the CCPA as we collect and process the Personal Data of California residents. This Policy provides the required notices to California residents. The CCPA also prohibits covered businesses from providing discriminatory treatment to California residents if they exercise their rights under the Act.
PROPGEN PTY LTD may sell or share Personal Data of California residents. You can request to opt-out of the sale or sharing of your Personal Data at any time by completing the online form (available at https://forgestudio.global/ccpa/) or by sending us an e-mail at email@example.com. Under the CCPA, we have 15 days after receipt to implement a request to opt-out. The CCPA requires us to state that we do not have actual knowledge that we have sold or shared the Personal Data of California residents under 16 years of age.
To make a “request to know,” “request to delete,” or “request to correct” your Personal Data, send us an e-mail at firstname.lastname@example.org . (Please put “Request to Know,” “Request to Delete,” or “Request to Correct” in the subject heading of your email.) You may also submit these requests via Do Not Sell My Personal Information or by mailing your request to address in the United States to:
PROPGEN PTY LTD
29/30 Spruce Street,
Rockport, ME 04856
We will honour these requests for individuals in the United States whether or not you would qualify as a California resident under the CCPA.
We will confirm receipt of your request to know, delete, or correct within 10 days along with a description of what steps we will take to verify and respond. We must provide the requested information or delete your Personal Data within 45 days of receipt of your request but can use an additional 45 days, but we will let you know additional time is needed.
When contacting us, we may ask you to provide certain, limited Personal Data, such as your name, e-mail address and/or username to verify your request and to match with our records and systems. We will not retain this Personal Data or use it for any other purpose. Residents of other states may also have similar rights to request information about or delete their Personal Data. To inquire about exercising these rights, please contact us at email@example.com.
Additional Information for Job Applicants and Employees About the CCPA
This subsection contains information about how we may collect, use, and disclose the Personal Data about California residents related to any job application or employment with us. This subsection does not contain information about how we may collect, use, and disclose Personal Data about California residents not related to any job application or employment with us, which is described in the remainder of this Policy. This subsection does not apply to non-California residents.
20. Contact Us
PROPGEN PTY LTD
Level 2/81 Ryrie St,
Geelong VIC 3220