Critical Compass — Privacy Policy
1. Who we are
This Privacy Policy explains how GYLD Pty Ltd (ACN: 64 640 644 006) of C/- Saward Dawson, 20 Albert Street, Blackburn, Victoria, 3124, Australia (“GYLD”, “we”, “us”) handles personal information collected through the Critical Compass website at https://criticalcompass.games/ (the “Site”) and in the course of providing our research and decision-support services.
We handle personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles. Where the EU or UK General Data Protection Regulation applies to you, the additional provisions in section 9 apply.
2. What we collect
Information you give us:
- Contact details when you request a sample report, book a meeting, or email us: name, work email, company, role, and anything you include in free-text fields (such as the decision you’re working on).
- Business information provided during engagements. Engagement materials are handled under confidentiality terms in our Terms of Service and Engagement Agreements; this policy covers any personal information within them.
- Event information if you RSVP to a GYLD event (dietary requirements are collected only if you volunteer them and deleted after the event).
Information collected automatically:
- Site usage data via Cloudflare Analytics and Umami: pages visited, referral source, approximate location (country/city level), device and browser type.
- Cookies as described in section 8.
What we do not collect: we do not knowingly collect sensitive information (health, political views, etc.) or information from children — the Site and our services are strictly business-to-business.
3. Why we collect it
We collect and use personal information to: deliver sample reports and respond to enquiries; scope, deliver and administer engagements; send service communications; send marketing communications where you have opted in or would reasonably expect them, always with an unsubscribe option, run and improve the Site; manage events; and meet legal obligations.
4. What we do not do
- We do not sell personal information. Ever.
- We do not use your confidential engagement materials to train our models or to inform any other client’s work.
- We do not use advertising trackers or share visitor data with ad networks.
5. Who we share it with
We share personal information only with: service providers who help us operate (website hosting Cloudflare, Microsoft), email [Microsoft], analytics [Cloudflare], document delivery [Cloudflare, Microsoft and Google] — each bound by contractual confidentiality); professional advisers where necessary; and authorities where required by law. Within GYLD, access is limited to personnel who need it for the purposes above.
6. International transfers
We are based in Australia. Some service providers store data in Australia. Where personal information is transferred overseas, we take reasonable steps to ensure it is handled consistently with the APPs, and for GDPR-covered individuals we rely on the safeguards in section 9.
7. Security and retention
We protect personal information with access controls, encryption in transit, and internal confidentiality obligations. We retain personal information only as long as needed for the purposes above or as required by law: enquiry and sample-request data for 24 months after last contact; engagement records for 3 years to meet legal and accounting obligations.
8. Cookies
The Site uses: essential cookies (required for the Site to function). You can control cookies through your browser settings.
9. If you are in the EU or UK (GDPR)
Where the GDPR applies, GYLD Pty Ltd is the data controller. Our legal bases are: performance of a contract (engagements, sample-report delivery you request), legitimate interests (running and securing the Site, B2B relationship management — balanced against your rights), consent (marketing, where sought), and legal obligation. You have the rights of access, rectification, erasure, restriction, portability, and objection, and the right to withdraw consent at any time. You may complain to your local supervisory authority.
10. Your rights (Australia)
You may request access to or correction of the personal information we hold about you at any time by contacting us (details below). We will respond within a reasonable period. If you believe we have breached the APPs, contact us first; if unresolved, you may complain to the Office of the Australian Information Commissioner (oaic.gov.au).
11. Marketing preferences
Every marketing email we send includes an unsubscribe link. Opting out of marketing does not affect service communications for an active engagement.
12. Changes to this policy
We may update this policy from time to time. The “last updated” date will change, and material changes will be flagged on the Site.
13. Contact
Privacy questions, requests or complaints: contact@gyld.agency — GYLD Pty Ltd, of C/- Saward Dawson, 20 Albert Street, Blackburn, Victoria, 3124, Australia