Changes to privacy policy: September 14th 

This statement describes the types of personal data we may collect and process about you as a user on Equality Check, and as a visitor of our website https://www.equalitycheck.com/. The privacy policy gives you information about what personal data is, how Equality Check processes personal data, what the purpose of processing personal data is, and the legal basis of the processing we do. In addition, we will inform you about your rights according to the current privacy legislation, and what you can do should you wish to act on these rights. All references to “we” and “us” refer to the Norwegian company Equality Check AS (data controller). If you have any further questions after reading this statement, do not hesitate to contact us on hello@equalitycheck.com

Introduction

Personal data is information that can be linked to an identified or identifiable individual. 

Equality Check’s software helps companies harness the power of diversity. By combining industry leading domain expertise with evidence-based frameworks, our data-driven technology offers a proven methodology that companies can leverage to transform their DEI strategy and ease their DEI reporting. We do this by letting companies add structural data about their employees. The respective company is the data controller of said information, and any inquiries regarding structural data shared with Equality Check should be directed at the respective company. We also send out surveys to employees, if the employer shares your contact information with us. Through the survey we gather data about inclusion and belonging, and demographic data about the employee. In this case Equality Check is the data controller of said information, and you will find more information about this below. 

We will also process personal data for other purposes as described below. We do not necessarily process all personal data as listed below, as the processing on personal data depends on how you use the platform, which of our services you use, how you contact us and what your inquiry is about. If we process personal data, the processing will be in accordance with this Privacy Policy.

Depending on the circumstances we may process other personal data than listed below. In this case, the information about data processing will be given to you through other channels than this privacy policy (for example by email or phone). If you want to know more about the kind of personal data we process about you, please email hello@equalitycheck.it.

The data processing: 

If you are an employee responding to a survey:

See our privacy FAQ for employees here. 

We sometimes cooperate with organisations to conduct employee surveys. In such events, we will receive your e-mail from your employer, and we will send you employee surveys regarding equality in your organisation. We will also receive general information about salary and other statistics from the organsiation. Participating in the survey is completely voluntary, and your employer will not know which persons have participated and not. 

Based on your consent we will collect data about your: 

• Age
• Gender
• Nationality
• Family situation (if you have children under 12 years of age) 

We may also process the following personal information defined as “special categories of personal data”. It is completely voluntary to answer these questions.. The legal basis of this processing is your explicit consent. Special categories of personal information that we ask about are as follow:

• Sexuality (sexual orientation)
• Ethnic identity and skin colour
• Health data (disability)
• Gender identity
• Religion

In addition, we will collect data about your response to the survey, such as (but not limited to): 

• If you feel included 
• If you experience equal opportunities 
• If you experience unconscious bias
• If you experience a future potential  

We use the data to provide the organisation where you are employed with information about the equality in the organisation, and to suggest measures to improve equality. We only present the data in a statistical form to your employer, and they will not be able to retrieve specific answers. We never present data in a form that can identify employees. This means that we will only combine data points if there are a sufficient amount of employees in each group. The Norwegian Data Protection Authority recommends group sizes of five people or more, which is also our policy. For example:  if you are the only person with a certain gender and a certain age in your company, we will not show insights combining that specific gender and age. 

We will process the data as long as we have your consent, and until we have shared statistical data with your employer. This means we process data during the time the survey is open. This is usually between 7 and 14 days. After we close the survey, we anonymise the data by deleting the link between email and company name. You may contact us at any time to withdraw your consent, and we will stop the further use of your information (provided we have not already anonymized your data). The withdrawal of your consent will not affect prior processing, such as the previous general statistics provided to your employer. 

If you browse on our website: 

When you visit equalitycheck.com, we use cookies to track your browsing. We use this data to understand how you use the website, and may use it to send you product information and marketing material. The data we collect may be: 

• What you do on our page, which links you click, and how often and how long you visit our page (session data)
• Your approximate position
• Technical information about your browser and operating system 

You can learn more about this in our cookie policy.

We will process your personal data for these purposes based on our legitimate interests in analyzing and improving our services, and to be able to market to you. We have carefully considered that your privacy interest does not outweigh our interest. Among other things, this includes that (i) the processing of personal data is limited and does not include sensitive information, (ii) the processing is done in your best interest, (iii) you can opt out at any time.

If you sign up for receiving information: 

If you sign up for our newsletter or other marketing channels, we will process your personal data to send newsletters and other marketing material. If you contact us through email, book a demo or a sales meeting, we will process your personal data to reply to your enquiry. The personal data we collect will vary depending on the situation, and will typically be: 

• Name 
• Email 
• Phone number 
• Company name 
• Whether a newsletter has been opened, what parts of the newsletter was clicked on and the time of access of links in the newsletter
  

We will process your personal data for these purposes based on your consent. You can always opt out by sending us an email or click the opt-out link that you find at the bottom of our emails. Note that we may use data processors outside the EU/EEA area, and that they do not necessarily provide the same level of protection of your personal data as afforded to you under the GDPR. 

When you use our service on behalf of an organisation: 

When you have created a profile on behalf of an organisation that has become a client, we process personal data to be able to deliver our product/service to your company and to be able to respond to queries you have, we process this data as a data processor on behalf of the organisation. In addition we process the following data in order to claim payment for the service and to improve our service as a data controller.

The personal data we collect will vary depending on the situation, and will typically be: 

• Name
• Company Name 
• Phone number 
• Email address 
• Billing information      

We will process your personal data for these purposes to fulfill our agreement with your organisation. In addition we will collect the following data:

• Usage data such as pages or screens viewed, how long you spent on a page or screen, button clicks, unique user identifier, and other similar information.

You can always opt out of the latter by sending us an email and delete your profile. We process usage data based on our legitimate interest in gathering data about how the service is used, and to improve our service and our customer relationship.

To perform research and improve our services

We process data or for our own purposes, in order to improve the services provided by Equality Check, and to promote the value of equity, diversity and inclusion. When we use the data for our own purposes, we will always anonymize the data. The data we anonymize include data provided by the organisation (Name, ID, Gender, Compensation, Information about your role) and data provided by employees of this organisation through our surveys (see our description above). 

We may perform analysis on the data using a third-party researcher.

The processing of anonymizing the data is based on our legitimate interest, except for special categories of personal data which is based on statistical purposes. We have carefully considered that your privacy interest does not outweigh our interest. Among other things, this includes that (i) the processing of personal data is limited, (ii) the processing is done in the best interest of the society, (iii) you can opt out at any time by sending us an e-mail.

Storage time

Your personal data will be deleted when the data is no longer needed for the processing purposes specified above. We may however store data for a longer period if it is necessary to establish, exercise or defend a legal claim, e.g. if there is an on-going dispute or a crime has been reported to the police. We may also store data if we are required by law, i.e. to comply with bookkeeping legislation. 

We perform regular disposals and erase data that is no longer necessary to process.

Third party data processors

We may have to share your personal data with our data processors (subcontractors) in order to provide the service. We require all third parties to respect the security of your personal data and to treat it in accordance with GDPR, and we only permit them to process your personal data for specified purposes and in accordance with our instructions. 

If your personal data is transferred outside of the EU/EEA, we guarantee an adequate measure of security by forwarding them to countries that have an appropriate level of protection based on confirmation by the European Commission, or by concluding an appropriately formulated contract between us and the legal person outside of the EU/EEA who receives the data.

The personal data may also be transferred to a third party in the event of a merger, demerger or a similar event.

Our data processors can be found here. 

Your rights as a data subject

You have the right to request:

• Access to all the personal data we have stored about you
• Correction of any errors in the personal data we have stored about you
• Deletion of your personal data

If the data processing is based on your consent, you have the right to withdraw your consent at any time. If the processing is based on our legitimate interest, you may protest the processing.  In certain cases, you may also request data portability of the information we keep about you.

If you have any concerns about how we process your personal data, you are welcome to file a complaint to the Norwegian Data Protection Authority (Datatilsynet) or the relevant data protection authority in your country.

Changes

We are constantly working on improving and developing our products and websites, so we may change this privacy policy from time to time. We will not diminish your rights under this privacy policy. If the changes are significant, we will provide a more prominent notice, when we are required to do so by applicable law. Please review this Privacy Policy from time to time to stay updated on any changes.