Engaged Strategy Pty Ltd Privacy Policy Statement

Effective Date – 2nd October, 2008

The original effective date of this privacy statement is October 2nd, 2008. This statement was last revised January 7th, 2022.

Your privacy is important to Engaged Strategy Pty Ltd and its offshore entities. This privacy statement provides information about the personal and organisational information that Engaged Strategy Pty Ltd collects, and the ways in which Engaged Strategy Pty Ltd uses that personal and organisational information. This covers our website www.engagedstrategy.com.au, surveys, workshops, and other business interactions across our business entities in Australia (Engaged Strategy Pty Ltd) and India (Engaged Professional Service Pvt. Ltd.), both entities together hereby referred to as Engaged Strategy.

Engaged Strategy is committed to safeguard personal data and operates its business with high standards of data privacy and security. The following segments provide information about how our business operates and the details of how we collect, safeguard, store and utilise data.

Introducing Engaged Strategy

Engaged Strategy is a boutique consulting firm  that provides to its clients, a third-party customer experience platform that allows them to measure customer experience at multiple touchpoints, recognise strengths and gaps in their business operations, and implement solutions to provide an enhanced customer experience. We also provide expert consultancy services via in-depth insights of survey data and conduct workshops and in-person interactions at various levels of the organisation of the client to help them visualise the impact of their business in the market that they operate in, realise the impact of CX on key business metrics and vice-versa, build on their expertise, plug the gaps, and maintain and grow their business standards.

Information Collection

The information collection process for clients and contacts at Engaged Strategy Pty Ltd includes, but is not exclusive to, the collection of information from forms, face-to-face or online meetings, emails, telephone conversations or by third parties. Engaged Strategy Pty Ltd may collect and use the following kinds of personal and organisational information:

  • Information about your use of this website
  • Information that you provide for the purpose of registering with the website including organisation or personal name, email, position, phone, address, website, etc.
  • Information about transactions carried out over this website, including credit card details
  • Information that you provide for the purpose of subscribing to the website products and services
  • Information that is provided by respondents to surveys
  • Information that is provided by clients to connect with respondents
  • Any other information that you send to Engaged Strategy Pty Ltd

Using Information

Engaged Strategy Pty Ltd may use your personal and organisation information to:

  • Enable your access to and use of the website services
  • Publish information about you on the website with your approval
  • Send you products that you purchase
  • Supply you with services that you purchase
  • Inform contacts and clients of services and information which may be relevant and/or of interest
  • Notify clients or contacts of new services, events and seminars that Engaged Strategy Pty Ltd  is organising or is/will be a part of
  • Send you statements and invoices
  •  Receive payments from you
  • Provide you with recruitment opportunities
  • Send you marketing communications
  • Send you any information that you request
  • Any other purposes which relate to our business

Although users are not required to provide any information in order to use the Engaged Strategy website, Engaged Strategy collects personally identifiable information from users as described in this privacy statement. Engaged Strategy also collects personally identifiable information through ongoing sales and marketing activities. Personally identifiable information consists of information that identifies or is identifiable with a natural person. Engaged Strategy only collects personally identifiable information that is voluntarily provided by users or other individuals. This includes names, e-mail addresses, physical addresses, phone numbers, cookie information as described below, IP addresses, and employment/education information as described below.

Contacts and clients always have the option to opt out of marketing communications such as emails through the unsubscribe option. Alternatively, customers or clients can email enquiry@engagedstrategy.com.au to formalise  not to receive any further marketing information from Engaged Strategy. Where Engaged Strategy discloses your personal information to its agents or sub-contractors, for these purposes, the agent or sub-contractor in question will be obligated to use that personal information in accordance with the terms of this privacy statement.

In addition to the disclosures that are reasonably necessary for the purposes identified elsewhere above, Engaged Strategy Pty Ltd may disclose your personal and organisation information to the extent that it is required to do so by law, in connection with any legal proceedings or prospective legal proceedings, and to establish, exercise or defend its legal rights.

Securing your data

Engaged Strategy Pty Ltd will take reasonable technical and organisational precautions to prevent the loss, misuse and/or alteration of your personal or organisational information.

Personal Data

We process personal data from the customers of our clients, client representatives, business representatives, and other users. Personal Data can be actively submitted or automatically collected through your use of our Services or from third-party sources. We may process your personal data, including collection, recording, organization, structuring, analysis, storage, alteration, retrieval, consultation, use, disclosure, dissemination, or erasure. We do not sell your Personal Data.

Personal Data provided by our clients

We process personal data on behalf of our clients. When we establish a client relationship, our software is customized to suit how we will interact with our clients’ customers. We then receive customer contact information, which is personal information, from our client for the purpose of obtaining customer feedback and may include the customers’ names, email addresses, telephone numbers, and relevant business identifiers such as account numbers. Clients provide information of customers to Engaged Strategy directly or by connecting us with their customer resource management or customer email database(s) via email, an app or API.

Personal Data actively submitted to us by customers, clients, survey respondents and website/social media channel visitors

When we reach out directly to you and seek your feedback through a survey or other feedback platform, you actively submit personal data to us. You also actively submit personal data to us when you interact directly with us through our website, social media, completing online forms, make inquiries, among other things. We use the information you provide us to obtain customer sentiment ratings and other customer feedback for our client.  Any data use for Engaged Strategy’s own analysis and research purposes relevant to the Services is only performed on de-identified and aggregate data.

Personal data that we automatically collect through your use of our Services

We receive some personal data automatically when you use our Services. This includes information about the device, browser, and operating system you use when accessing our Services, your IP address, the website that referred you, pages that you request and visit, and the date and time of each request you make.

‍‍Personal data of minors

The Services of Engaged Strategy are not intended for users younger than 16, unless explicitly requested for by certain clients. We do not actively collect or otherwise process Personal Data from users under the age of 16. If we become aware that an individual under the age of 16 has submitted personal data without verifiable parental consent, we will remove his or her information from our files.

How we use your personal data

‍We use your personal data to fulfill our contractual obligations in our service contracts with our clients. We also utilise the data to review and enforce adherence to our Terms of Use, to analyse the use of services in order to understand how we can improve our content and service offerings and products and for administrative and other business purposes.

The personal data that we collect is used to process our business purposes to obtain customer sentiment ratings and other customer feedback for our clients. The legal basis for our processing of your personal data is either the necessity to perform contractual and other obligations, our legitimate business interest as a provider of security services, or regulatory requirements. In addition, our clients may follow up or reply to a customer sentiment rating or other customer feedback that you provide via Engaged Strategy. The client may also wish to publish some or all of the customer feedback that you provide, such as a customer testimonial, but the client will obtain your consent via Engaged Strategy. The legal basis for processing in this context will be your explicit consent.

Sharing of Personal Data

‍We do not sell personal data. We may share your personal data in the following circumstances:

  • Clients: We share information at an aggregate level with our clients with a key focus on providing relevant feedback and recommendations to clients based upon data analysis. We only share identifiable information with our clients after we have your consent. Your contribution in providing feedback and sharing your experiences and sentiments is highly valuable to our clients and plays a vital role in their ability to identify and improve customer interactions and experience and achieve other business performance goals.
  • Third-party Service Providers: We may share information that we collect about you with third-party service providers to perform tasks either on our behalf or on behalf of our clients in supporting the services. The types of service providers, or sub-processors to whom we entrust personal data include: (I) providers of hosting services; (ii) providers of analytic data services; (iii) system support; (iv) other third-party software providers with service contracts limiting personal data processing to specific services.
  • Social Media:We share information with social media platforms when you click on the social media links on our website or interact with us through those channels . We encourage you to read the privacy policies applicable to these other websites and platforms prior to selecting links or providing your data.
  • Regulatory Bodies, Agencies, and Law Enforcement: We may access and disclose your Personal Data to regulatory bodies if we have a good-faith belief that doing so is required under applicable law or regulation. This may include submitting personal data required by tax authorities. We may disclose your personal data in a response to lawful requests by public authorities or law enforcement, including to meet national security or law enforcement requirements. If we are going to release your personal data in this instance, our policy is to provide you with notice unless we are prohibited from doing so by law or court order.
  • Merger, Sale, or Other Asset Transfers: If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, then your personal data may be transferred as part of such a transaction as permitted by law and/or contract. Should such an event occur, Engaged Strategy will endeavor to direct the transferee to use personal data in a manner that is consistent with the Privacy Policy in effect at the time such personal information was collected.
  • Other Disclosures: We may also disclose your personal data to exercise or defend legal rights; to take precautions against liability; to protect the rights, property, or safety of the Services, of any individuals, or of the general public; to maintain and protect the security and integrity of our services or infrastructure; to protect ourselves and our services from fraudulent, abusive, or unlawful uses; or to investigate and defend ourselves against third-party claims or allegations. Disclosures may be made to courts of law, attorneys and law enforcement, or other relevant third parties in order to meet these purposes.

If we transfer Personal Data of individuals located in the European Economic Area (“EEA”) or Switzerland that we have received under the EU-U.S. Privacy Shield Framework or Swiss-U.S. Privacy Shield Framework to a third party, Engaged Strategy remains liable for such Personal Data and the actions of such third party. For more details, please refer to the section on Data Subject Rights.

Retention of Personal Data 

Engaged Strategy retains personal data for a reasonable time period to fulfill the processing purposes mentioned above and to comply with client instructions. Personal data is then archived for time periods required or necessitated by law or legal considerations. When archival is no longer required, personal data is deleted from our records. Please note, where applicable, personal data is also de-identified.

We retain your account information, including personal data in your profile, while our client’s account is active. After termination or deactivation of our client’s account, we delete your account as part of our standard delete function.

Kindly note that we may retain information within our internal systems for backup, archival, audit, or other purposes. We retain personal data that are required to be retained to meet our regulatory obligations, including tax records and transaction history. We regularly review our retention policy to ensure compliance with our obligations under data protection laws and other regulatory requirements. We regularly audit our databases and archived information to ensure that personal data is only stored and archived in alignment with our retention policies.

Protection of Personal Data

Engaged Strategy uses technical and organizational measures to protect the personal data that we store, transmit, or otherwise process, against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access. We regularly consider appropriate new security technology and methods as we maintain and develop our software and systems.

Please be aware that despite our best efforts to ensure the security of your data, we cannot guarantee that your information will be 100% secure. The Engaged Strategy platform is hosted on GoDaddy, which is renowned for its high security.

International Data Transfer

‍If you are a customer of one of our clients, your personal data may be transferred to, and maintained on, computers located outside of your state, province, country, or other governmental jurisdiction, depending upon the contractual agreement entered with our client. If you are a client representative or business representative or other user on our website, we will transfer your personal data to other countries that follow adequate privacy principles and process it there as part of our business operations. Where we transfer your personal data, the privacy laws may not be as protective as those in your jurisdiction; however, we will take all reasonable steps to ensure that your personal data and your privacy rights continue to be protected.

In the case of transfers of data out of Europe, we have committed to comply with the Privacy Shield and implement Standard Contractual Clauses as required. We endeavor to utilize third-party service providers from the United States that have certified with Privacy Shield or alternatively provide adequate protections that are compliant with the EU General Data Protection Regulation (“GDPR”) such as implementing Standard Contractual Clauses or Binding Corporate Rules.

Data Subject Rights

Special categories of information 

We do not actively collect or otherwise process special categories of Personal Data as identified in the EU General Data Protection Regulation (“GDPR”) including data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade-union membership, or genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation. We do not actively collect or otherwise process personal data relating to criminal convictions and offences.

Users or individuals in the European Union may exercise certain rights with regard to the information collected by Engaged Strategy as described in this privacy statement. This includes the rights of users in the European Union to
1. access to their personally identifiable information
2. in certain instances, rectification or erasure of their personally identifiable information, 3. in certain instances, restriction of the ways in which Engaged Strategy is using their personally identifiable information, or object to the ways in which Engaged Strategy is using your personally identifiable information; and,
4. in certain instances, to have Engaged Strategy transfer your personally identifiable information to another entity or organization that you specify.

To exercise any of these rights, please contact enquiry@engagedstrategy.com.au

If you are a resident of California, you have the right, subject to certain exceptions defined in the California Consumer Privacy Act (“CCPA”) and other applicable laws and regulations, to request Engaged Strategy to disclose certain information to you about our collection and use of your personal information over the past twelve months. If you would like to exercise your rights to make an information access request or a deletion request, please contact us at enquiry@engagedstrategy.com.au. In order to verify your request, you will need to provide your legal first and last name, email address you use to correspond with Engaged Strategy, your relationship to Engaged Strategy, and the state you currently reside in.

If you authorize an agent to make a request on your behalf, they may reach Engaged Strategy according to the “Contact” section below. Please be advised that the authorized agent will need to submit documentation evidencing your authorization of this agent to make the request, as well as verify your and their identities with Engaged Strategy.

Privacy Rights

‍Under certain data protection laws and Engaged Strategy’s compliance commitments, individuals may have the right to access personal data and to correct, amend, restrict, or delete that information where it is inaccurate, or has been processed in violation of applicable law or compliance requirements, except where the burden or expense of providing access is disproportionate to the risks to the individual’s privacy in the case in question, or where the rights of persons other than the individual will be violated.

Engaged Strategy has certain features to enable individuals to exercise rights directly. For example, if you are a customer of one of our clients and receive an email survey or SMS text survey, you may opt-out at any time by selecting the “Unsubscribe” link at the end of the email or text communication. Similarly, if you are a client representative or business representative that receive marketing communication, we provide you the ability to unsubscribe directly from the email or text message.

Please note- where we rely upon your explicit consent to process your Personal Data (including as a legal basis for processing under the GDPR), you may withdraw your consent at any time. Please note the withdrawal of your consent does not affect the lawfulness of processing based on consent before withdrawal.

Client representatives that are account holders in our platform have access to update profile information through their account settings, including to correct, amend, restrict, or delete certain data fields with personal data. Our clients are the data controllers and determine how we process the Personal Data of customers, including whether Personal Data processed on the AskNicely platform is retained within a geographical region.

Individuals in the EEA, UK, and Switzerland have certain rights that may be subject to limitations and/or restrictions. These rights include the right to: (i) request access to and rectification or erasure of their personal data; (ii) obtain restriction of processing or to object to processing of their personal data; and (iii) ask for a copy of their personal data to be provided to them, or a third party, in a digital format.

If you wish to exercise one of the above-mentioned rights, please send us your request to the contact details set out below. Individuals also have the right to lodge a complaint about the processing of their Personal Data with their local data protection authority.

We respect the privacy of all individuals and invite you to submit your requests irrespective of where you reside. Our contact details are provided below.


Engaged Strategy collects certain information through the use of cookies. A cookie is a piece of data that identifies you as a unique user. The user’s browser will generally add information to this file regarding the user’s activity on a given website. Engaged Strategy can then access this information to enhance the user’s experience on Engaged Strategy’s website. We may use cookies to store visitors’ preferences and record session information, such as items that consumers add to their shopping cart.

Engaged Strategy collects information related to user sessions/engagement and interactions with the website through Google Analytics and Facebook Pixel, third-party applications. This information is used to enhance the operation of the Engaged Strategy website and improve user experience and not for any other purpose.

Ad Servers

We do not partner with or have special relationships with any ad server companies.

Other websites

This website contains links to other websites. Engaged Strategy Pty Ltd is not responsible for the privacy policies or practices of any third party.

Contact Engaged Strategy Pty Ltd

If you have any questions about this privacy policy or Engaged Strategy Pty Ltd treatment of your personal and organisation information, please contact us:

Your Consent and Changes to the Privacy Policy

By using our website, you consent to the collection and use of your information as we have outlined in this policy.

From time to time, we may use customer information for new, unanticipated uses not previously disclosed in our privacy notice. If our information practices change at some time in the future, we will post the policy changes to our website. If you are concerned about how your information is used, you should check our website periodically.

Upon request, we provide site visitors with access to contact information (e.g., name, address, phone number) that we maintain about them. Consumers can access this information by calling us at the above telephone number. Upon request, we offer visitors the ability to have inaccuracies corrected in contact information.

With respect to security: We have appropriate security measures in place in our physical facilities to protect against the loss, misuse and/or alteration of information that we have collected from you at our site.

If you feel that this site is not following its stated information policy, you may contact us at the above address or phone number.