Privacy Notice 

Introduction
 
This Privacy Notice explains how MyAnova (a trading name of Marbral Advisory Limited) collects and handles your personal information, and applies to all of our Services, which includes this website. Through our product offerings, Customers and their employees have the ability to provide organisational feedback and/or individual feedback within their companies. We value your trust and take our privacy obligations seriously. We have developed this Privacy Notice to provide you with detailed information about how your personal information and data is collected, held, and processed by MyAnova.

This notice (together with our Terms of Business and any other documents it refers to) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. For the purposes of The Data Protection (Jersey) Law 2018, the General Data Protection Regulation (EU) 2016/679 (GDPR) and any subsequent UK data protection legislation, the data processor for data that we collect from you is MyAnova as a trading name of Marbral Advisory Limited, which is a private limited company registered in Jersey, No 54395. The registered office of Marbral Advisory Limited is at Bond Street, St. Helier, Jersey, JE2 3NP.  

By using MyAnova’s services, you acknowledge that you have read and understand this Privacy Notice. 

Contact us:
If you have questions regarding this Privacy Notice, please contact us by email: hello@marbraladvisory.com or in writing to Marbral Advisory Limited, Bond Street, St. Helier, Jersey, JE2 3NP.

What type of information is collected from you and how is this collected?

The information we collect about you will depend on the way that you use our Services, for example, whether you are an Administrator, Dashboard Manager, Survey Respondent or Visitor.  We will only collect personal information which is necessary to deliver our Services and all survey responses are anonymous to your organisation.  

• Customer or Company means, in relation to you, the person or entity that has contracted with MyAnova to allow you to use MyAnova’s Services. The Customer or Company will generally be your employer, or an identified subgroup (i.e., division, department, etc.) within your employer;

• Administrator means any person who has log in credentials to a Customer account to manage that account, create surveys, review and share survey results, or manage the account to enable individual users to provide feedback;

• Dashboard Manager means any person who has log in credentials to view the resulting dashboard information from the surveys issued by Customer

• Survey Respondent means any person who accesses our Services to answer surveys (either wholly or partially) issued by the Customer or Company;

• Visitor means any person who visits our Website(s). 

 
Information we collect includes:

• Contact information: When you provide us with your contact information, whether through use of our Services, creation of an account, a form on our website, or an interaction with our sales or customer support team, we collect your contact information. This information may include, for example, your name and email address.

• Usage information: We collect usage data about you whenever you interact with our Services. This may include which web pages you visit, what you click on, when you performed those actions, and other activities. You can manage your cookie preferences via the cookie preferences manager.

• Device and browser data: We collect data from the device you use to access our Services, such as your IP address, operating system, browser details and time of visit. This information may also tell us your location.

• Cookies and page tags: We use third party tracking services that employ cookies and page tags (also known as web beacons) to collect aggregated and anonymous data about Visitors to our Websites. This data includes usage details and user statistics. You can manage your cookie preferences via the cookie preferences manager.

• Other data you submit: We may collect your personal information or data if you submit it to us in other contexts. For example, by giving us a testimonial, attending an event we host or entering a contest. We may also collect personal information at other points throughout our Services or within our website that states personal information is being collected. If you contact us at hello@myanova.com, or hello@marbraladvisory.com we will also collect any information that you provide to us voluntarily, such as your operating system version, and other requested information in order for us to respond to your request.

• Information collected from your Company:  Your company will provide us with demographic data such as your name, email information, and other information related to your role within the Company, including your manager, direct reports, and your position within the Company’s organisation chart.   

• Information you provide:  When you log in to complete a survey, you may be asked for additional demographic information such as gender, age, location, and the team you work within.  As the survey responses are anonymous, the only information shared with the Dashboard Managers and Administrators is the aggregate survey responses and comments, gender, age, location, and team.  If less than 3 responses are received for a particular demographic, the data will not be displayed to avoid any unintended ability to identify survey respondents. 

We may collect the following information about Administrators:

• Registration details: When you register an account or another Administrator creates an account for you, we collect your name, company name, email address, password, and other information.

• Survey data: When you create and launch surveys using the Services, we will store those survey questions and other information related to those surveys.

• Billing details: If you use a credit card for billing, our credit card processor may collect information such as the cardholder’s name, billing address, email address, credit card number, expiry date and credit card security code.

• Account settings: You may be able to set or update various preferences and personal details on your account settings page or your profile. For example, your name, email address, default language or time zone.

How is your information used?

The personal information collected is used for the purposes of:

• Identity verification: This information is used to confirm your identity when registering for access to our services. The information is matched against our existing records to allow you to login.  

• Survey administration:  As an Administrator, you will register your organisation and the users of your organisation who will have access to the surveys issued.  

• Survey completion:  As a Survey Respondent, your survey responses and comments, along with non-personally identifiable demographics, will be used to present results in the MyAnova Dashboard.  Survey responses are anonymous to your Company.

• Dashboard Review:  The Administrator for your Company will confirm that you are a Dashboard Manager, and this data will be used to allow you to access the MyAnova Dashboard. 

• Communication with MyAnova: If you send us an email, we will use your email address to respond to your query and to keep a record of our correspondence.

• Creating aggregated de-identified data: We may create aggregated de-identified data for any purpose derived from data we hold about you. For example, we may create aggregated de-identified data to share with customers, prospects, partners for business or research purposes, or for provision of our Services such as our survey benchmarks.

• Preventing harm: We may disclose your personal information to your Company or relevant authorities if your use of our Services indicates an imminent risk of harm to you or to others around you.

We will not sell or rent your information to third parties. 

We will not share your information with third parties for marketing purposes.

Who has access to your information?

Your information will be accessible to MyAnova administrators and by your Company’s Administrator.  Your survey responses and comments will be anonymised to your Company’s Administrator.

In addition, we may pass your information to our third-party service providers, subcontractors, and associated organisations for the purposes of completing tasks and providing services to you on our behalf (for example to process payment transactions). However, when we use third party service providers, we disclose only the personal information that is necessary to deliver the service and we have a contract in place that requires them to keep your information secure and not to use it for their own direct marketing purposes. Please be reassured that we will not release your information to third parties for them to use for their own direct marketing purposes, unless you have requested us to do so, or we are required to do so by law, for example, by a court order or for the purposes of prevention of fraud or other crime.

We may disclose your information if we are under a duty to disclose or share your personal data to comply with any legal obligation, or to enforce or apply our Terms of Business and other agreements; or to protect the rights, property, or safety of MyAnova Limited, our users, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction. 

Your choices

You can change your marketing preferences at any time by unsubscribing from emails, choosing the unsubscribe option on our website or by emailing us at hello@myanova.com.

You can delete your account and associated profile in the MyAnova platform through your Company Administrator, or by emailing us at hello@myanova.com. 

How you can access and update your information

You can update your details by logging into the MyAnova platform and viewing your profile, then writing to your Company Administrator to update. 

Alternatively, if you wish to change your details or any of the other information, we hold is inaccurate or out of date, please email us at: hello@myanova.com.

Security precautions in place to protect the loss, misuse, or alteration of your information

When you give us personal information via our website, we take steps to ensure that it is treated securely. Our website is encrypted and authenticated using QUIC, x25519, and AES-128_GCM on SSL. When you are on a secure page, a lock icon will appear on the bottom of web browsers such as Google Chrome.

Non-sensitive personal data (e.g., your email address) is transmitted normally over the Internet, and this can never be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, we cannot guarantee the security of any information you transmit to us, and you do so at your own risk. Once we receive your information, we make our best effort to ensure its security on our systems. Where we have given (or where you have chosen) a password which enables you to access certain parts of our sites or applications, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Your rights

You are responsible for ensuring that the information you provide to us is accurate, complete, and up to date. You can review your information by logging into MyAnova and visiting your profile page. To request a change to your information you can do so by writing to your Company Administrator, or by emailing hello@myanova.com. 

You have a number of rights in relation to your personal data, these include the right to:

• find out how we process your data;

• request that your personal data is corrected if you believe it is incorrect or inaccurate 

• request that your data is deleted (within 30 days);

• obtain restriction on, or object to, processing of your personal data;

• if we are relying on consent, you can withdraw your consent to our processing of your personal data (including any direct marketing);

• if we are relying on legitimate interests for direct marketing, you can object to receiving such direct marketing;

• obtain a copy of the personal data we process concerning you. You can download this information from the site.

• lodge a complaint with the Jersey Office of the Information Commissioner (the JOIC) here https://jerseyoic.org/. If you have a concern or complaint about the way we handle your data, we ask that you contact us in the first instance to allow us to investigate and resolve the matter.

If you would like to exercise any of your rights or find out more, please contact us at hello@myanova.com. 

Legal basis for processing your data

We may process your data because:

• We are legally obliged to confirm your identity.

• We have your consent to register for the Services; or

• The processing is necessary for the performance of the contract with you or your employer to provide our services; or

• It is in our legitimate business interests to do so.

In some instances, we will rely on your consent to process personal data and where we do this, you will be made aware.

How long do we keep your personal information?

Your personally identifiable data (email address, date of birth) will be erased if your account is deactivated by your employer, or if your employer terminates their contract with Anova. 

IP addresses

We may collect information regarding your device (computer, mobile device or tablet), including where available your IP address, operating system type, and browser, for system administration. 

This is statistical data about our users' browsing actions and patterns and does not identify any individual.

Use of 'cookies'

Our site makes use of cookies to distinguish you from other users of our website. This helps us to provide you with a positive experience when you browse our website and allows us to improve our site. For a more detailed information on the cookies we use and the purposes for which we use them, see our Cookies Policy.

'Cookies' are small pieces of information sent by an organisation to your computer and stored on your hard drive to allow that website to recognise you when you visit. They collect statistical data about your browsing actions and patterns and do not identify you as an individual. As an example, we make use cookies to store your country preference. This assists us to improve our website and deliver a better more personalised service.

It is possible to turnoff cookies by setting your browser preferences. Turning cookies of may result in reduced functionality when using our website.

Changes to our privacy notice

Any changes we make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail.

Review of this notice

We keep this notice under regular review. This Privacy Notice was last updated in October 2022. 

Contact

Questions, comments, and requests regarding this Privacy Notice are welcomed and can be submitted to hello@marbraladvisory.com or in writing to Marbral Advisory Limited, Bond Street, St. Helier, Jersey, JE2 3NP.