Privacy Policy
1. Introduction
This “Privacy Policy” describes how we collect and use personal information about you when you visit websites, platforms or applications owned and/or operated by UBT Marketing Pty Ltd as trustee of the UBT Marketing Trust and its affiliates (collectively, “UBT“, “We” or “Us“) (collectively, the “Services“).
For the purposes of applicable data protection laws, the primary data controller for your personal data is typically the UBT entity you interact with and its affiliates. If you would like to find out more information regarding the relevant data controller, please contact us using the details set out below.
For the purposes of this Privacy Policy, “Personal Information” means any information or opinion relating to an identified or identifiable living individual or living individual that is reasonably identified (such as a name, email address or unique identifier). Note that the annex to this Privacy Policy contains some jurisdictional specific terms that may be applicable to you depending on where you are located.
We may update this Privacy Policy from time to time. The most current version will be posted on https://ubteam.com/ and is effective from the date of posting.
2. What Information Do We Collect
- Technical Usage Information. We collect certain technical information from you including cookies (see Section 4) when you use our Services. This may include information about the device you are using, information about which pages you visit and which resources you use on our site (and how you got to our site your internet protocol (IP address)), your device’s operating system and platform, the type and version of the browser you are using, browser plug-in types and versions which extend the functionality of your browser, MAC addresses which are used as network addresses for Wi-Fi and Ethernet, geolocation data, time zone settings and weblogs (“Usage Information”). We may send this Usage Information to third party analytics providers who provide us with information about how you use our Services.
- Information that you provide to us.
- We collect Personal Information from you such as your name, postal address, email address and telephone number when you submit it or otherwise provide it to us, such as when you email us, create an account or submit it via an online form or online chatbot. When you make a purchase through one of our Services, your payment details are provided to our third-party e-commerce platform to process the transaction.
- We collect information from prospective personnel seeking employment or engagement with us, and where permitted by applicable privacy laws, contact information, curriculum vitae, current employment information (e.g. job title and employer), professional association memberships, criminal record, health information that you chose to disclose to us during the course of your application, religious beliefs and other information about your suitability for employment with or engagement by us.
- We may also use AI‑based and automated tools, including meeting recording and transcription technologies, to help us document discussions and generate insights such as summaries or reports. This may involve processing personal data shared during meetings, including voice, image and information discussed. These technologies are used to support our operations, service delivery and efficiency.
- You may also provide us with other data about you such as gender, marital status, dietary information, passport and frequent flyer data and information about your religious beliefs, your family photographs.
- Information provided to us by a third party. We may collect Personal Information from third party individuals, business entities and governmental agencies, such as signatories to the GAP Global Limited Amended and Restated Members Agreement (“GAP Global Members“), courts, public and law enforcement agencies, and credit bureaus, regardless of whether such individual, business entity or governmental agency compiled the information itself or received it from other sources. Where we collect Personal Information from a third party, we will handle that information in accordance with applicable local privacy laws, this Privacy Policy and any obligations we have to that third party. If you provide to us Personal Information about another person, you confirm that you have satisfied all requirements to enable us to process the Personal Information for the purpose of collection.
We will only collect, use and disclose information that is considered “sensitive” or “special category” under applicable data protection laws where you have provided your consent to the collection of that information, or where we are required or authorised by law to do so. Such sensitive information may in certain circumstances include biometric data such as biometric facial scans. In providing any consents to the collection or handling of Personal Information (including Sensitive Information), you consent to us collecting, holding, using and disclosing the information you provide in accordance with the terms of those consents and this Privacy Policy.
If you do not provide us with your Personal Information when requested or if you provide us with inaccurate Personal Information, this may limit the assistance we are able to provide to you, including assistance we are contracted to provide on behalf of a third party. For example, we may not be able to provide the Services you may have requested and may not be able to handle enquiries in connection with those Services.
3. How Do We Use Your Information
We collect, hold, use and disclose Personal Information about individuals for a variety of business purposes.
We process your Personal Information to perform our contract with you, such as to:
- facilitate the provision of our Services to our clients and member businesses who have engaged us; and
- register and maintain your account with us.
As it is in our legitimate interests to be responsive to you and to ensure the proper functioning of the Services, we will use your information to:
- provide the Services and respond to your requests;
- provide you with user support and improve customer service (your information helps us to more effectively respond to your customer service requests and support needs);
- facilitate recruitment and selection of prospective personnel;
- improve, diagnose, and support our Services (including by using AI). We continually strive to improve our Service offerings based on the information and feedback we receive about you, including by monitoring which features of the Services are used most to allow us to determine which features we need to focus on improving;
- analyse how visitors use our Services (including behaviour patterns and the tracking of visits across multiple devices);
- streamline our services by using AI-enabled and automated tools;
- manage risk, or to detect, prevent, and/or remediate fraud or other potentially prohibited or illegal activities;
- manage and protect our information technology infrastructure, enforce our terms of use and policies and comply with our legal and regulatory obligations;
- facilitate conferences, training and education programs, and event management;
- provide and manage charitable assistance; and
- conduct audit, accounting, financial and economic analysis of our business operation for internal business purposes.
Where AI-enabled or automated technologies are used in connection with Personal Information, we seek to implement reasonable measures designed to support responsible and lawful use.
Significant decisions affecting individuals are not made solely by automated means without appropriate human involvement.
We obtain your consent (where required by applicable law) to process your Personal Information for the following reasons:
- share your family photographs and if requested, match your household members photographs with their names;
- sign you up for our newsletters and provide information on church services or other sponsored events; or alerts;
- personalize our services for you (including sending adverts to you); and
- send marketing text messaging and other similar communications.
4. Cookies
Our website uses a technology called “cookies” and web server logs to collect information about how the website is used including, where available, your IP address, browser type and the geographical location of your computer.
We also use Google Analytics to collect details of how you use our site, as well as anonymous data that you enter into our forms. We do this to help us analyse how visitors use our site (including behaviour patterns and the tracking of visits across multiple devices), administer our site and manage your account. Google Analytics doesn’t collect information that identifies a visitor to our site. We do not allow Google to make any attempt to establish the identities of any users of our site.
Please see our cookies policy below on this page.
5. Who Do We Share Your Personal Information With?
To perform activities in connection with the purposes described in this Privacy Policy, we may make Personal Information available to other persons or entities, or disclose it to them, as permitted by applicable privacy laws, including:
- our suppliers and service providers, including those to whom we outsource certain of our information technology functions (e.g. cloud service providers). We authorise our suppliers and service providers to use or disclose your Personal Information only as necessary to provide us with supplies or perform Services on our behalf, or to comply with legal requirements. Where required by law, we will implement appropriate contracts with our service providers to safeguard the privacy and security of Personal Information they process on our behalf;
- any corporate purchaser or prospect to the extent permitted by law as part of any merger, acquisition, sale of our assets, or transition of service to another provider, as well as in the event of insolvency, bankruptcy, or receivership in which Personal Information would be transferred as an asset of us;
- other related bodies corporate;
- government, regulatory, judicial or law enforcement authorities;
- accountants, insurers, auditors, lawyers and our professional advisers; and
- any other third parties notified to you at or around the time we collect your Personal Information.
(together, the Required Recipients).
It may be necessary to transfer Personal Information to GAP Global Members and Required Recipients that are located outside of your jurisdiction. Some of the countries to which information is transferred may not have laws regulating the collection and disclosure of Personal Information, or may not provide an equivalent level of protection as your home jurisdiction. In these circumstances, we will take steps to ensure that the recipients of the Personal Information comply with applicable privacy laws.
For any transfers of data outside the European Economic Area or the UK, the data transfer will be under the European Commission’s standard contractual clauses for the transfer of personal data to third countries or the UK Information Commissioner’s international data transfer addendum to the EU standard contractual clauses, as relevant, unless the data transfer is to a country that has been determined by the European Commission or the relevant UK authorities, as applicable, to provide an adequate level of protection for individuals’ rights and freedoms for their personal data. Please contact at [email protected] should you wish to examine a copy of the EU standard contractual clauses or UK international data transfer addendum.
To the extent permitted by local applicable law or otherwise legally required, your use of our Services or the provision of your Personal Information to us constitutes your consent to the cross-border transfer of your Personal Information and the other activities identified in this Privacy Policy.
6. How Do We Protect Your Personal Information
The security and confidentiality of your Personal Information matters to us. That’s why we maintain commercially reasonable standards of security and confidentiality to protect your Personal Information from misuse and loss, and unauthorised access, modification and disclosure. We also implement measures to limit information access to individuals who need to have such access to perform their responsibilities associated with our Services and the content on our Services. However, the internet and communications and transactions cannot be guaranteed to be secure, and it is possible that others may unlawfully intercept or access information, transmissions, or communications to, from, or within our Services and any information you transmit to UBT you do so at your own risk.
7. Children
Our Services are intended for use only by individuals who are at least 17 years old (or the age of majority in your jurisdiction). We do not permit access by individuals under 17 years of age. This restriction helps us comply with data protection requirements. By accessing or using our Services, you confirm that you meet this age requirement.
8. Your Rights
Depending on where you live, you may have some or all the rights listed below in relation to the Personal Information that we have collected about you. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law:
- The right to correct, delete, restrict (stop any active) or object to the processing of your Personal Information, to obtain the Personal Information you provide to us in a machine-readable format and to ask us to share (port) this data to another organization.
- The right to withdraw your consent, so that we no longer process Personal Information in way that you previously consented to.
- You can unsubscribe from our marketing messages at any time by following the instructions in the email sent.
- To notify us of changes to or errors in Personal Information that we hold about you, please contact us at [email protected] and we will amend our records accordingly.
In certain instances, we may require that you provide additional information to verify your identity before we process your requests. We will respond to your requests within a reasonable time period, in accordance with applicable laws.
If you are in New Zealand or Australia, to provide us with a statement of correction (Statement of Correction) sought to your Personal Information and request that we attach the Statement of Correction to your Personal Information if we do not make the correction sought.
9. Enquiries & Complaints
If you wish to make an enquiry or complaint to us regarding privacy matters, please email us at [email protected]. We will endeavour to respond to your enquiry or complaint within 30 days, or as otherwise required pursuant to applicable law. Depending on where you are located you may also have the right to lodge a complaint with the competent data protection supervisory authority. Depending on where you are located you may also have the right to lodge a complaint with the competent data protection supervisory authority. We will endeavour to respond to your enquiry or complaint within 30 days, or as otherwise required pursuant to applicable law.
10. Third Party Sites
Please remember that when you use a link to go from our website, platform or application to another website, this Privacy Policy is no longer in effect. Your browsing and interaction on any other website, including websites which are linked to our website, platform or application is subject to that website’s own rules and policies. We are not responsible for the content or the conduct of the organisations accessed via links to such third-party websites.
11. Contact Us
You may contact us in relation to privacy matters at:
Postal Address: The Precinct, Level 6, 10 Herb Elliott Ave, Sydney Olympic Park, NSW 2127, Australia
Email: [email protected]
All correspondence attention: Privacy Officer
12. Supplemental Terms – Jurisdiction Specific
The following are specific provisions which modify the Privacy Policy for certain jurisdictions. The Supplemental Terms should be read together with the Privacy Policy. In the event of a conflict or inconsistency between the provisions of the Supplemental Terms and the Privacy Policy, the Supplemental Terms applicable to you will prevail.
All definitions used in the Supplemental Terms are given the meanings contained in the Privacy Policy.
12.1 ARGENTINA
If you are an individual and legal entity residing in Argentina, the provisions outlined below are exclusively applicable to you:
- By browsing and/or registering and/or using our website and any other platforms or applications we may offer, and/or by providing Personal Information to us, you expressly accept and consent to this updated Privacy Policy. If you do not accept this updated Privacy Policy, you must not browse, register in, or use our website and any other platforms or applications we may offer, nor provide Personal Information to us.
- The location of the databases where your Personal Information is stored is the United Kingdom, United States, Australia and New Zealand.
- “Personal Information” means information of any kind related to an identified or identifiable individual or legal entity.
- “Sensitive Information” means Personal Information revealing racial and ethnic origin, political opinions, religious, philosophical or moral beliefs, labour union membership, and information concerning health conditions or sexual habits or behaviour.
- Providing inaccurate Personal Information will have the consequences stated under Section 2 of the Privacy Policy.
- It is expressly stated that some jurisdictions under Section 5 of the Privacy Policy may not offer levels of personal data protection equivalent to those offered by Argentine regulations, and you expressly consent that we can share your Personal Information with the GAP Global Members and Required Recipients, even if they are located in those countries that afford a lower level of protection.
- In addition to the rights detailed under Section 8 of the Privacy Policy you have, among others, the right to request the suppression of your Personal Information from our databases.
- Also, we hereby inform you that: “In Argentina the data owner is entitled to exercise the right of access to his/her/its personal data free of charge at intervals of not less than six months, unless a legitimate interest to that effect is established in accordance with article 14, paragraph 3 of Law No. 25,326. THE PUBLIC INFORMATION ACCESS AGENCY, in its capacity as the Control Entity of Law No. 25,326, has the power to attend complaints and claims filed by those whose rights are affected due to breaches to applicable regulations on personal data protection. The data owner may at any time request the removal or blocking of his/her/its name from the databases referred to in this article. Every communication with advertising purposes that is carried out by mail, telephone, email, Internet or any other future remote mean, shall state expressly and prominently the possibility of the data owner to request the withdrawal or blockage, in whole or in part, of his/her/it name from the database. At the request of the interested party, the name of the person responsible or user of the database that provided the information must be reported.”
12.2 USA
12.2.1 California
- If you are a resident of California, we are required by the California Consumer Privacy Act (“CCPA”), as amended by the California Privacy Rights Act (“CPRA”) (collectively, “California Privacy Law”) to provide you with information about how we use and disclose your Personal Information, and you may have certain rights with regard to your Personal Information. We have included this California-specific information below.
- CA Personal Information. Depending on your online and offline interactions with us, we may collect and process the following categories of personal information (“CA Personal Information”).
- Identifiers: including contact details such as name, address, email address, phone number, age, and gender.
- Professional or employment-related information: including title and organization information;
- Educational information: including professional qualifications.
- Internet or other electronic network activity information: including your interactions with our Site.
- Audio, electronic, visual, or similar information: including phone, audio, or video calls, texts and other digital messaging, emails, and any in-person conversations you have with us.
- Geolocation data: including IP address.
- Commercial information: including purchasing history.
- Inferences: drawn from the information collected.
- Other: including assistance information as information about you that is linked to the CA Personal Information above, such as inquiry and communication information when you contact us.
- Certain CA Personal Information that we collect about you may be considered Sensitive Personal Information within the meaning of the California Consumer Privacy Act, as amended by the California Privacy Rights Act (“California Privacy Law”), including: Date of birth, government identifiers, Precise geolocation information and Social security, driver’s license, state identification card, or passport number that we collect to manage our Customer relationships. We only use and disclose such data for purposes of compliance with Federal and other laws, and as otherwise permitted by California Privacy Law.
- Sources. We generally source the categories of CA Personal Information identified above directly from you (for instance, when you provide information as part of a business transaction or otherwise), third-party IT service providers, analytics service providers, and social media networks.
- Purposes of collection and use. We use CA Personal Information for:
- Business Purposes, including:
- improving our Services;
- operating our websites;
- providing you with information and Services you request from us, or we think you may be interested in;
- providing you with location services (only if you ask or allow us to);
- carrying out and complying with our agreement with service providers;
- administering and managing our product offering tiers and fees, invoicing, and billing; and
- complying with our legal obligations, including carrying out required checks on new customers, and to prevent money laundering or fraud.
- Commercial Purposes, including:
- marketing communications (including direct marketing);
- customer service;
- providing you with special offers and other information we believe will be of interest to you; and
- inviting you to participate in surveys and provide feedback to us.
- Business Purposes, including:
- Disclosure of CA Personal Information. We do not sell your CA Personal Information as that term is traditionally understood. However, some of our disclosures of CA Personal Information may be considered a “sale” or “share” as those terms are defined under California Privacy Law. Under California Privacy Law a “sale” is broadly defined to include a disclosure for something of value, and a “share” is broadly defined under to include a disclosure for cross-context behavioural advertising. We disclose your CA Personal Information as follows:
- Disclosing your CA Personal Information for Business Purposes. We may disclose the above categories of CA Personal Information to third-party partners, third party applications; and other third parties, such as market research firms and data aggregators, as required by law, related to a legal proceeding, related to a transactional business event, or with your consent, for any of the Business Purposes described above.
- Disclosing your CA Personal Information for Commercial Purposes. We may share the above categories of CA Personal Information with third-party partners; third party applications; business partners; or other third parties with your consent, such as market research firms and data aggregators, for any of the Commercial Purposes described above.
We do not knowingly disclose the CA Personal Information of individuals under 16 years of age, in a manner that constitutes a “sale” under California law.
- Retention of CA Personal Information. We typically retain your CA Personal Information related to marketing activities for as long as you accept marketing communications from us, and upon request we will securely delete such data in accordance with applicable law. For CA Personal Information that we collect and process for other purposes described above, we typically retain such CA Personal Information for no longer than for the period necessary to fulfill the purposes outlined in this California Privacy Policy and as otherwise needed to address tax, corporate, compliance, litigation, and other legal rights and obligations, issues related to the exercise or defence of legal claims, and legitimate business needs.
- Your Rights under California Privacy Law. Subject to certain exceptions detailed in the California Privacy Law, as a California resident, you have the right to request: (i) the right to know/access the categories of CA Personal Information that we collect about you, including the specific pieces of CA Personal Information; (ii) the categories of CA Personal Information disclosed for a business purpose; (iii) information about the categories of CA Personal Information about you that we have shared (as such term is defined under California Privacy Law) and the categories of third parties to whom we disclose CA Personal Information was shared; (iv) deletion of your CA Personal Information; and (v) correction of inaccurate CA Personal Information.
- Exercising Your Rights. If you are a California resident and wish to request the exercise of these rights as detailed above or have questions regarding the CA Personal Information collected or shared with third parties, please see the “Contact Us” section below, email us at [email protected] or call us toll free at +1 (866) 996-6336.
- You may be asked to provide additional proof of identification so that we can verify your identity and validate the request.
- We may decline to honour your request if we cannot verify your identity, confirm that the CA Personal Information that we maintain relates to you, or where an exception under California Privacy Law applies, such as where the disclosure of CA Personal Information would adversely affect the rights and freedoms of another consumer.
- In any case, we will not discriminate against you by offering you different pricing or products, or by providing you with a different level or quality of products, based solely upon this request.
- Authorized Agents. To the extent that you elect to designate an authorized agent to make a request on your behalf, they must provide appropriate documentation including written signed permission from you, proof of your identity, and verification of their identity; or a valid, designated power of attorney as defined under the California Probate Code.
- Do Not Sell or Share My Information: In addition to the above, California residents have the right to opt-out of the selling or sharing of their CA Personal Information, as such terms are defined under California Privacy Law.[This includes the right to opt-out of analytical/performance, functional, and targeting cookies.. In addition, we have configured our cookie management tool to honour opt-out preference signals sent by Global Privacy Control (“GPC”) within the browser or device communicating the signals, or with respect to you specifically if you have signed onto your UBT account while communicating Global Privacy opt-out preference signals. To use Global Privacy Control opt-out preference signals, please follow the instructions here: https://globalprivacycontrol.org/. Beyond GPC, your browser or extension may allow you to automatically transmit “do not track” signals. Except as required by law, we do not currently respond to web browser “do not track” signals or other mechanisms that indicate your preference for not having information collected over time and across different Web sites or digital apps following your visit to one of our sites. We will not discriminate against you by offering you different pricing or products, or by providing you with a different level or quality of products, based solely upon this request.]
- Financial Incentive. We do not engage in financial incentive programs.
12.2.2 Other US States
- If you are a resident of a US state that has applicable privacy laws, including but not limited to, Colorado, Delaware, Oregon or Virginia, you may have the right to obtain confirmation that we maintain certain Personal Information relating to you, to verify its content, origin, and accuracy, as well as the right to access your Personal Information, request updates or corrections to your Personal Information, request deletion or portability of your Personal Information. You may also have the right to obtain the identities of the third parties to whom we disclose your Personal Information. You may also request restriction of the processing, including for targeted advertising. Additionally, in certain states you may have the right to opt-out of the “sale” of your Personal Information, as the term is defined under applicable law.
- In some states, you can designate an authorized agent to make a request on your behalf. Please note that we may need to retain certain information for recordkeeping purposes, to complete any transactions that you began prior to your request, or for other purposes as required or permitted by applicable law. In any event, should you choose to exercise any of your rights as detailed above, we will not discriminate against you by offering you different pricing or products, or by providing you with a different level or quality of products, based solely upon this request.
- You can exercise your rights for any of the jurisdictions listed above by contacting us as detailed under the “Contact Us” heading above.
Global Cookie Policy
Our global website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive. The cookies that apply across our website are outlined in the table below.
Persistent cookies are cookies saved on your computer and that are not deleted automatically when you quit your browser, unlike a session cookie, which is deleted when you quit your browser.
We use the following cookies:
Strictly necessary cookies. These are cookies that are required for the operation of our website. These essential cookies are always enabled because our website won’t work properly without them. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services. You can switch off these cookies in your browser settings but you may then not be able to access all or parts of our website.
Analytical or performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
Functionality/preference cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
Targeting/marketing/tracking cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose so that they can serve you with relevant advertising on their websites.
You can find more information about the individual cookies we use and the purposes for which we use them in the table below:
| Provider / service | Associated cookies | Purpose | Duration |
|---|---|---|---|
| Google Analytics 4 | _ga | Distinguishes visitors to help measure website usage. | Default: 2 years, subject to browser limits and configuration. |
| Google Analytics 4 | _ga_GBNJ9WDSD5 | Maintains session information to help measure visits and activity on the website. | Default: 2 years, subject to browser limits and configuration. |
| LinkedIn Insight Tag | May include bcookie, lidc, li_gc, AnalyticsSyncHistory, li_sugr and UserMatchHistory. | Supports advertising measurement, conversion tracking, audience insights and retargeting, alongside functions such as remembering consent and identifying browsers. Cookies used depend on consent, browser settings and LinkedIn status. | Varies by cookie. Provider-listed durations range from 24 hours to 1 year for the cookies named here. |
Third Party Cookies
Some of our pages display content from external providers. Please note that the following external third parties may also use cookies, over which we have no control. These named third parties may include, for example, advertising networks and providers of external services like web traffic analysis services. These third party cookies are likely to be analytical cookies or performance cookies or targeting cookies:
- Adobe
- Hotjar
- Chatwoot
- Contentsquare
- Marketo
To deactivate the use of third-party advertising cookies, you may visit the relevant consumer page to manage the use of these types of cookies.
Choices about cookies
You can choose which analytical, functionality and targeting cookies we can set by clicking on the button(s):
- Essential cookies: ALWAYS ACTIVE
- Marketing cookies: OFF
- Google Analytics cookies: OFF
You can find these options in “cookie settings” under the “Information” section on our main website. For each option you can click on “specifications” to see all the individual cookies used.
If you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website.
If you have any questions or concerns about our use of cookies, please send us an email at [email protected]