Special Group – Privacy Policy
Effective Date: 03 August 2026

This Privacy Policy explains Special Group’s (“Special,” “we,” “us,” or “our”) online and offline data practices, including the kinds of personal data we collect, how we collect and use it, and to whom we disclose it. This Privacy Policy applies to Special’s operations worldwide, including in Sydney, Melbourne, Auckland, Wellington, Los Angeles, New York, and London. 

This Privacy Policy applies to information we collect in the course of providing our services, including information about our enterprise customers and visitors to our informational website https://www.specialgroup.com and any related webpages and websites, including https://au.specialgroup.com, https://nz.specialgroup.com, https://wellington.specialgroup.com, https://us.specialgroup.com, and https://uk.specialgroup.com (the “Sites”). We refer to the Sites and any other online and offline services we offer collectively as the “Services.” This Privacy Policy applies only to our Services and does not apply to third-party websites, products, or services, even if our Services link to them or vice versa. We recommend that you review the privacy practices of those third parties before sharing personal data with them. 

For the purposes of many privacy laws, Special Group is the data controller of information subject to this Privacy Policy. Our contact information is found in Section 12 (“Contact Us”).
Please note that we are providing the following disclosures in this Privacy Policy in the interest of transparency. Such disclosures are not intended to waive any applicable exemptions under state and federal law.

If you are a visually-impaired customer, a customer who has another disability, or a customer who seeks support in another language, you may access this Privacy Policy by emailing us at privacy@specialgroup.com. 

Table of Contents

1. Personal Data
We collect personal data in connection with your use of our Services.

2.  Use of Personal Data
‍We use personal data for different purposes in connection with your use of our Services.

3. Disclosure of Personal Data
‍We may disclose personal data to certain third parties, including our service providers and advertising partners.

4. Cookies and Other Tracking Technologies
‍We collect information about your use of our Services through cookies and other tracking technologies.

5. Legal Bases for Processing 
‍We rely on one or more legal bases to process personal data.

6. Data Security and Retention
‍We use reasonable measures to protect personal data and will retain personal data for as long as necessary to fulfill purposes set out in this Privacy Policy.

7. International Transfers
‍Our Services are operated in, and personal data may be transferred to, the United States. 

8. Children’s Privacy
‍Our Services are not directed to or intended for use by anyone under the age of 18.

9. Privacy Rights and Choices 
‍We explain how you may exercise rights and choices related to personal data. 

10. Supplemental Location-Specific Notices 
We provide additional disclosures and rights to individuals in Australia; New Zealand; the EEA, UK, and Switzerland; and California.

11. Updates to this Privacy Policy
‍Updates to this Privacy Policy become effective on the date they are posted.

12. Contact Us 
You may contact us for comments or questions in various ways. 

1. Personal Data We Collect 
As used in this Privacy Policy, “personal data” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with an identifiable individual. Personal data includes “personal information” and “personally identifiable information” as such terms are defined under applicable privacy laws. 
Personal data does not include publicly available information, which includes information that is made available from federal, state, or local government records; information that we have a reasonable basis to believe is lawfully available to the general public, either through widely distributed media, or by the individual; and information that is made available by a person to whom the individual has disclosed the information if the individual has not restricted the information to a specific audience.
We collect the following personal data: 

A. Personal Data You Provide Us
‍We collect information directly from our enterprise customers in furtherance of offering our Services, including first and last name; phone number; business address and billing address; business email address; billing/payment information; and professional/employment information. We also collect information that enterprise customers and visitors to the Sites choose to provide when they contact us, provide feedback, or otherwise interact with us. Please note that our general practice is not to collect sensitive information (e.g., racial or ethnic origin, religious beliefs or affiliations, political opinions, philosophical beliefs, health or genetic information, sexual orientation, membership of professional or trade associations or unions, or criminal record), unless it is necessary to provide the Services and we obtain your consent. 

B. Personal Data Collected Automatically
‍We use cookies and other tracking technologies such as web beacons, embedded scripts, and tags (collectively, “Cookies”) which collect information from you automatically as you use our Sites, including: 
‍
1. browser and device data, such as IP address, device identifier, device type, operating system and Internet browser type, screen resolution, operating system name and version, device manufacturer and model, language, plug-ins, add-ons, and the language version of the Sites you are visiting; and 
2. usage data, such as geolocation data, browsing history, time spent on the Sites, pages visited, links clicked, language preferences, and patterns of use. 

Please review Section 4 below for more information about our use of these technologies.

C. Personal Data Collected From Other Sources
‍We also collect information from the following sources:

- Service providers. We may collect personal data via our service providers, including payment processing, hosting, analytics, customer and technical support, and other services.
- Third-party platforms. We may also collect personal data through third-party platforms such as LinkedIn, Meta, and Vimeo, including if you interact with us on those platforms.
- Other third parties. We may collect personal data from business and marketing partners, analytics providers, advertising, and other clients or businesses that provide referrals. 

We may combine the personal data we receive from third parties with personal data we otherwise collect. We may also create aggregated, deidentified, or anonymous information from data by removing certain data components that makes the data identifiable, or through aggregation, obfuscation, or other means. Subject to applicable law, our use and disclosure of such aggregated, deidentified, and anonymized information is not personal data or subject to this Privacy Policy.

2. Use of Personal Data
‍We may use the personal data we collect for the following purposes: 

- To provide, operate, and maintain our Services;
- To improve, personalize, and expand our Services;
- To provide customer service and support;
- To communicate with you in accordance with your preferences to provide you with updates and other information relating to our Services, and for marketing and promotional purposes through email and any other channels you choose to communicate with us;
- To prevent unauthorized, improper, or illegal activities on our Services;
- For systems and data security;
- For internal business purposes;
- To perform internal analytics; 
- To comply with our legal obligations, responding to subpoenas, court orders, or legal process; and to establish or exercise our legal rights or defenses against legal claims;
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal data held by us about our customers is among the assets transferred;
- For purposes disclosed at the time we collect the information, or as otherwise set forth in this Privacy Policy, or for any other legal purpose not inconsistent with this Privacy Policy; and 
- For any other purpose consistent with your consent and expressed preferences.

3. Disclosure of Personal Data
We may disclose personal data to the following categories of third parties:
‍
- Service providers. We disclose personal data to our service providers to provide services on our behalf, such as hosting, customer and technical support, billing, payment processing, order fulfillment, email, analytics, advertising and marketing, and other services. 

- Video hosting platforms. Videos on our Sites are embedded and hosted by the third-party video hosting platform Vimeo. Vimeo may collect and store viewing data, including video titles and descriptions, viewing times and duration, and interaction data. For more information please review Vimeo’s privacy policy at https://vimeo.com/privacy.

- Business transferees. If we or our affiliates are involved in a merger, acquisition, asset sale, or other corporate combination, personal data may be transferred to the acquiring or surviving entity.

- Professional advisors. We may disclose personal data to our professional advisors, including lawyers, auditors, bankers, and insurers, where necessary in the course of the professional services they render to us. 

- Authorities for compliance and harm prevention. Under certain circumstances, we may be required to disclose personal data if required to do so by law or in response to valid requests by public authorities, and/or in response to a threat of harm involving an individual’s health and/or safety.

- Other parties with your consent.
‍We may disclose personal data to other parties with your consent. 

4. Cookies and Other Tracking Technologies 
As mentioned above, we use Cookies to collect and track information, improve and analyze our Sites, and promote content and services that relate to your interests.  Cookies on the Sites generally fall into the following categories:

- Essential Cookies: These Cookies are necessary for the Sites to function and cannot be switched off in our systems. They are usually only set in response to actions made by you, which amount to a request for services, such as setting your privacy preferences, logging in, or filling in forms.
‍
- Functional Cookies: These Cookies enable the Sites to provide enhanced functionality and personalization. They may be set by us or by third-party providers whose services we have added to our pages. If you do not allow these cookies, then some or all of these services may not function properly. 
‍
- Performance/Analytics Cookies: These Cookies track and analyze information about visits to the Sites so we can make improvements, report our performance, and provide more relevant content. These cookies collect information about how visitors use the Sites, which website the visitor came from, the number of each user’s visits, and how long a user stays on the Sites. For example, we use Google Analytics and other service providers for analytics services. These analytics services may use cookies to help us analyze how users use the Sites. Information generated by these services (e.g., your IP address and other usage information) may be transmitted to and stored by Google and other service providers on servers in the U.S. (or elsewhere), and these service providers may use this information for purposes such as evaluating your use of the Sites, compiling statistic reports on the Sites’ activity, and providing other services relating to Sites’ activity and other Internet usage. You may exercise choices regarding the use of cookies from Google Analytics by going to tools.google.com/dlpage/gaoptout or downloading the Google Analytics Opt-out Browser Add-on.

5. Legal Bases for Processing 
‍We rely on one or more legal bases to process personal data under applicable law. We may process personal data (i) as necessary to perform our contractual obligations to you; (ii) as necessary to pursue our legitimate business interests as further detailed below; (iii) as necessary for our compliance with our legal obligations such as a request or order from courts, law enforcement or other government authorities; and/or (iv) with your consent. 
We may collect, process, and maintain personal data to pursue the legitimate business interests outlined below. To determine these legitimate interests, we balance our legitimate interests against the legitimate interests and rights of you and others and only process personal data in accordance with those interests where they are not overridden by your data-protection interests or fundamental rights and freedoms. Our legitimate interests generally include:

- Providing, improving, and developing our services, including to deliver your requested services, send you messages and provide user support, customize the Sites to better fit your needs as a user, develop new products and services, and perform internal analytics and research and development. This also includes sharing personal data with our trusted service providers that provide services on our behalf.
‍
- Protecting you and others and to create and maintain a trusted environment, such as to comply with our legal obligations, to ensure compliance our agreements with you and other third parties, to ensure safe, secure, and reliable services, and to detect and prevent wrongdoing and crime, assure compliance with our policies, and protect and defend our rights, interests, and property. In connection with the activities above, we may conduct internal research and profiling based on your interactions on various services, content you submit to us, and information obtained from third parties. 
‍
- Providing, personalizing, measuring, and improving our marketing, including sending you promotional messages and other information that may be of interest to you with your consent. We may also use personal data to understand our user base and the effectiveness of our marketing.
This processing is done pursuant to our legitimate interest in undertaking marketing activities to offer products or services that may be of interest to you.

6. Data Security and Retention
The security of your personal data is important to us but remember that no method of transmission over the Internet, or method of electronic storage, is 100% secure. We maintain appropriate technical, administrative, and physical safeguards to help protect the security of your personal data against unauthorized access, destruction, loss, alteration, disclosure or misuse, but we cannot guarantee its absolute security. 

We retain personal data for as long as necessary to provide our Services, to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies. We also retain certain personal data for internal analysis purposes. This personal data is generally retained for a shorter period, except when it is used to strengthen the security or to improve the functionality of our Services, or we are legally obligated to retain this data for longer time periods. Our determination of precise retention periods will be based on: (i) the length of time we have an ongoing relationship with you; (ii) whether there is a legal obligation to which we are subject; and (iii) whether retention is advisable given our legal position, including regard to applicable statutes of limitations, litigation, or regulatory investigations.

7. International Transfers 
We may transfer, store, and use information we collect and maintain about you, including personal data outside of your state, province, country, or other governmental jurisdiction. For such transfers, we take the necessary measures to ensure that your personal data receives an adequate level of protection, consistent with applicable law in which Special maintains their offices or employ staff or contractors and this Privacy Policy. Please note that the data protection laws in the jurisdiction in which we process personal data may differ from those of your jurisdiction, and in certain circumstances, your personal data may be subject to access requests from governments, courts, law enforcement agencies or regulatory agencies in those other jurisdictions. Where such consent is required under applicable laws, you consent to the transfer of your personal data to the U.S. or to any other country (i.e., you acknowledge and agree that where necessary and in accordance with applicable law, Special may transfer your personal data overseas including Australia, New Zealand, United States or United Kingdom).

8. Children’s Privacy
Our Services are not intended for children, and we do not knowingly collect any personal data from children under the age of 18. If you are a parent or guardian and you are aware that a child has provided us with personal data, please contact us, and we will take steps to remove that information from our servers.

9. Privacy Rights and Choices

A. Privacy Rights 
Based on your location or place of residency, you may have certain rights regarding your personal data. Please review Section 10 (“Supplemental Location-Specific Notices”) for more information.

You can exercise the rights described in this Privacy Policy by emailing us at privacy@specialgroup.com. All requests are subject to certain exceptions under applicable law. Consistent with applicable law, you may designate an authorized agent to submit a request on your behalf, and if so, we may require proof of your authorization of the agent and/or verification of the agent’s own identity. Please note that any request submitted to us is subject to an identification and residency verification process, to the extent permitted under applicable law. We will only use personal data provided in a request to verify your (or your authorized agent’s as applicable) identity or authority to make the request. 
We will respond and process requests consistent with applicable law. We do not charge a fee to process or respond to a request unless it is excessive, repetitive, or manifestly unfounded. If we determine that a request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request. You may be limited in how many requests you make within a twelve (12) month period.  
If you are a visually impaired customer, a customer who has another disability, or a customer who seeks support in other language, you may access your privacy rights by emailing us at privacy@specialgroup.com.

B. Opting Out of Promotional Communications 
We may send you email updates regarding our Services, other announcements, and inquiries. If you no longer wish to receive promotional email communications from us, you may opt out via the unsubscribe link included in such emails or by emailing us at privacy@specialgroup.com. Please note that if you opt out of receiving promotional emails from us, we may still send you important administrative messages that are required to provide you with the Services or for other reasons disclosed in this Policy. 

10. Supplemental Location-Specific Notices 

Certain jurisdictions provide individuals rights with respect to their personal data. Note that we are providing the following disclosures and rights regarding personal data in the interest of transparency and our commitment to privacy; such disclosures and rights are not intended to waive any exemptions under applicable laws. 

A. Supplemental Notice to Individuals in Australia 
This notice applies to any individuals located within Australia about whom we may have collected personal data. We provide this notice in addition to the disclosures throughout the rest of this Privacy Policy to comply with applicable laws and Australian Privacy Principles, including but not limited to the Australian Privacy Act 1988 (Cth) and the Spam Act 2003 (Cth). 
‍
i. Personal Data Collected From Job Applications
‍
We collect personal data about and from individuals who apply for employment with us or our related companies. The information we collect may include the applicants:
a) 0personal contact details (including phone, email and home address) and gender;
b) educational and employment history, relevant qualifications and experience including information which you provide regarding clients with whom you’ve worked in the past;
c) eligibility to work in the location; and
d) referees’ contact details.

In the case of prospective employees, the primary purpose the information is collected is to assess the individual's suitability for employment. We may collect this information directly from the job applicant or indirectly from a third party, including from a recruitment agency.

If you do not provide us with the information we request, we may not be able to process or assess your job application. We may share personal data provided by job applicants or suppliers with our related companies where we reasonably believe there may be a suitable opportunity for you to work with one of our related businesses.

ii. Retention of Personal Data 

‍In the event we retain personal data, it will only be for as long as reasonably necessary for the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law. When personal data is no longer required, we will take reasonable steps to destroy or deidentify it.
As a general guide, we retain:

- website enquiry and contact information for as long as needed to respond to the enquiry and manage our relationship;
‍
- client and supplier records for the duration of the relevant relationship and for any additional period required for legal,
accounting, audit, tax, contract, dispute-resolution, or record-keeping purposes;
‍
- recruitment information for the recruitment process and, where appropriate, for future opportunities or talent-pool management, unless you ask us not to retain it;

- marketing preferences and unsubscribe records for as long as needed to respect your communication choices;

- website analytics, cookie and device data for the period needed for analytics, reporting, security, troubleshooting and site improvement, subject to our cookie settings and applicable law.

Actual retention periods may vary depending on the nature of the information, the purpose for which it was collected, applicable legal obligations, operational requirements, and whether retention is necessary to establish, exercise or defend legal rights.

Sensitive Information

Sensitive information is a special subset of personal information such as information or opinion about an individual:
- racial or ethnic origin, 
- political opinions, 
- membership of a political association, 
- religious beliefs or affiliations, 
- philosophical beliefs, 
- membership of a professional or trade association, 
- membership of a trade union,
- sexual orientation or practices, 
- criminal record,
- health information about an individual,
- genetic information about an individual that is not otherwise health information,
- biometric information that is to be used for the purpose of automated biometric verification or biometric identification, or
- biometric templates.

We generally do not collect or retain sensitive information unless we obtain your consent and if it is reasonably necessary for our services or activities. In the event we inadvertently retain or store your sensitive information, it will be destroyed or stored (as applicable) in accordance with the Australian Privacy Act 1988 (Cth) and the Australian Privacy Principles.

iii. Your Privacy Rights
‍
In certain circumstances, individuals located in Australia have the following privacy rights, subject to certain exceptions:

- Right to access.
You have the right to request confirmation of whether we process personal data relating to you, and if so, to request a copy of that personal data.

- Right to correct.
You have the right to request to have your personal data corrected or updated if that information is inaccurate, outdated, or incomplete.

- Right to lodge complaint.
You have the right to complain to a data protection authority about our collection and use of your personal data. 

iv. How to exercise your rights
‍
Access & Correct: To exercise the privacy rights described above, please email us at privacy@specialgroup.com. Any request you submit to us is subject to an identification and residency verification process as permitted under applicable law.  

Complaints: If you have a concern or complaint about how we have handled your personal data, you may contact us at privacy@specialgroup.com. Please include your name, contact details, a description of your concern, and any relevant correspondence or supporting information. We aim to acknowledge receipt of your complaint within a reasonable period and investigate and respond to your complaint as soon as practicable. We may contact you to request further information. Alternatively, you may contact the Office of the Australian Information Commissioner at oaic.gov.au.

v. Spam Act
‍
We will take reasonable endeavors to ensure that any electronic communications, including emails and text messages, adhere to the requirements under the Spam Act 2003 (Cth) including obtaining necessary consents and providing clear opt-out mechanisms. 

vi. Automated Decision Making
‍
We use standard business, productivity, email, collaboration, security and compliance systems to support the operation of our business. These systems may include automated functionality, (e.g., organising information, generating alerts or reports, supporting workflows, maintaining records, monitoring security controls, or assisting with compliance activities. For the avoidance of doubt, these systems support business administration, communication, security, compliance and record-keeping, and do not make or do a thing that is substantially and directly related to making a decision in relation to individuals. In the event that an automated decision-making system is used to make or do a thing that is substantially and directly related to making a decision to the individuals, an appropriate level of human intervention or oversight will be applied to review and determine the outcome. 
‍
As of the Effective Date, we do not use personal information in the operation of the computer program to make a decision or do the thing that is substantially and directly related to making a decision that would have a legal or similarly significant effect on an individual (i.e., recruitment, employment, or access to Services).

B. Supplemental Notice to Individuals in New Zealand
This notice applies to any individuals located within New Zealand about whom we may have collected personal data. We provide this notice in addition to the disclosures throughout the rest of this Privacy Policy to comply with applicable laws, including the New Zealand Privacy Act 2020. 

In certain circumstances, individuals located in New Zealand have the following privacy rights, subject to certain exceptions:

- Right to access. You have the right to request confirmation of whether we process personal data relating to you, and if so, to request a copy of that personal data.
- Right to correct. You have the right to request to have your personal data corrected or updated if that information is inaccurate, outdated, or incomplete.
- Right to lodge complaint. You have the right to complain to a data protection authority about our collection and use of your personal data. The relevant NZ authority is the Office of the Privacy Commissioner.

To exercise the privacy rights described above, please email us at privacy@specialgroup.com. Any request you submit to us is subject to an identification and residency verification process as permitted under applicable law. 

C. Supplemental Notice to Individuals in the EEA, UK, and Switzerland
This notice applies to any individuals located within the European Economic Area (“EEA”), the United Kingdom (“UK”), and Switzerland about whom we may have collected personal data from any source, including through your use of our Services. We provide this notice in addition to the disclosures throughout the rest of this Privacy Policy to comply with the General Data Protection Regulation (“GDPR”), the UK GDPR, Switzerland’s Federal Act on Data Protection, and related laws, regulations, and guidance from the European Union and/or its member states.  

In certain circumstances, individuals located within the EEA, UK, and Switzerland have following privacy rights, subject to certain exceptions:

- Right to access. You have the right to request confirmation of whether we process personal data relating to you, and if so, to request a copy of that personal data.
- Right to erasure. You have the right to request that we erase your personal data in certain circumstances provided by law.
- Right to rectification. You have the right to request to have your personal data corrected or updated if that information is inaccurate, outdated, or incomplete.
- Right to object. You have the right to object to our processing of your personal data.
- Right to restrict. You have the right to request that we restrict the processing of your personal data. 
- Right to data portability. You have the right to request that we provide you with a copy of your personal data in a structured, machine-readable, and commonly used format.
- Right to withdraw consent. You have the right to withdraw your consent at any time where we rely on your consent to process your personal data. 
- Right to lodge complaint. You have the right to complain to a data protection authority about our collection and use of your personal data. For more information, please contact your local data protection authority.
- A list of EU supervisory authorities is available here.
- The relevant UK supervisory authority is the UK Information Commissioner’s Officer.
- The relevant Swiss supervisory authority is the Federal Data Protection and Information Commissioner.

To exercise the privacy rights described above, please email us at privacy@specialgroup.com. Any request you submit to us is subject to an identification and residency verification process as permitted under applicable law. 

D. Supplemental Notice to California Residents
This notice applies to any individuals residing in California about whom we may have collected personal data from any source, including through your use of our Services. We provide this notice in addition to the disclosures throughout the rest of this Privacy Policy to comply with the California Consumer Privacy Act of 2018 (“CCPA”). 
‍
i. Personal data collection and use 
In the last 12 months (from the date listed at the top of this Privacy Policy), we have collected the following categories of personal data for the following purposes to the third parties (excluding service providers and affiliates) listed in the chart below.