Transparency

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LiveHire Privacy Policy

(version date 6 December 2019)

Welcome to LiveHire! This Privacy Policy and our Terms of Service help guide decisions LiveHire makes every day, so we can help protect and empower the flow of the world’s talent to create a more agile, open and awesome working world. For the purposes of this Privacy Policy, when we say ‘Users‘, ‘you‘ or ‘your‘ we mean any individuals about whom we process Personal Information including anyone creating an account on our Platform, users of our Website, applicants for employment, Clients and anyone else who may provide Personal Information to us. Important information about LiveHire Words like ‘us‘, ‘we‘, ‘our‘, ‘LiveHire‘ or ‘livehire.com‘ refer to LiveHire Ltd of Level 10, 461 Bourke Road, Melbourne, Victoria 3000 (ABN 59 153 266 605) (https://www.livehire.com). LiveHire is a cloud-based human resources productivity platform for sourcing and recruitment that delivers ‘talent on demand’ for small to large enterprises. The Platform enables Clients to leverage their brand, employee networks and digital assets to invite and curate talent into a private ‘Talent Community’. It also allows individuals to sign up to our Platform and to source new employment opportunities with enterprises in our network. Where you provide your Personal Information to LiveHire directly, for example by signing up for an account on our Platform, LiveHire will be responsible for the original collection of your Personal Information and will be your primary Data Controller. Where a Client collects your Personal Information and uses the LiveHire Platform to manage it, the Client will be responsible for the original collection of your Personal Information and will be your primary Data Controller. You can find out more about LiveHire at https://www.livehire.com or by contacting us here. We also provide our services in jurisdictions where country-specific requirements may apply. As you use our Services, we want you to be clear about how we collect and use your information, the ways in which you can protect your information at all times and how we help you in protecting your information. This Privacy Policy explains how we collect, use, share and store your Personal Information in the course of our business activities, including:

Your privacy matters to us, so whether you are new to the Platform or a long-term User, please take the time to get to know our practices and read through this Privacy Policy and if you have any questions please contact us. If you require a copy of this Privacy Policy in a particular form, please let us know and we will provide this to you.


What information we collect and when we collect it

Information gathered during registration When you sign up for our Services, or register to use our Platform as a User, we collect and process certain Personal Information and data about you including:

  • If you are a Member: information relating to your profile, photograph, curriculum vitae or resume (including industry and operations, profession and specialities, work history, achievements, awards, languages, references, availability and job search status, right to work, education and qualifications), contact details (including your full name, address, phone number and email address), profile data (including password, username, log-ins and user preferences), diversity information (including gender and date of birth), work preferences (including salary, contract type, hours and location), technical data (including IP address, browser type, other technology on the device used and usage data (including the frequency and details of your use of our Platform and Website)), each as further detailed in this Privacy Policy. We collect marketing and communications data, including your preferences for receiving marketing and related communications. We also collect the data that our Clients attach to your profile, including their communications with you, details of your job applications, their assessment of you and interview and other notes.
  • If you are a Client: if you are an entity, we will collect data in order to provide our Services to you and your users, including your business or company name, ABN or ACN, contact details (including address, phone number and email address) and payment information. If you are an individual representative of the Client (such as a recruiter, hiring manager, approver or referrer) we will collect your contact details (including your full name, address, phone number and email address), details of your role, communications with Members, marketing and communication preferences. If you carry out any training offered by LiveHire we will also collect details relating to that training (such as whether or not training has been completed). We use this data to notify you of Member messages, job vacancy notifications, marketing emails and training opportunities.
  • If you are a recruitment agency submitting a person for a job vacancy to a Client: if you are an entity, we will collect data in order to provide our Services to you and your users, including your business or company name, ABN or ACN and contact details (including address, phone number and email address). If you are an individual representative of a recruitment agency we will collect your contact details (including your full name, address, phone number and email address).

Please note that if you are a Member, LiveHire profiles can be created by you directly via the LiveHire home page at www.livehire.com, via a job application with a potential employer (for example on a job board) or by joining a Talent Community powered by LiveHire (such as via the employer’s career page or links in their blogs, social media or email signature). Members can also have profiles created on their behalf by Clients (referred to as ‘Temporary Profiles‘) if, for example, the Member submits their curriculum vitae directly to the Client, provides their business card to the Client, registers for an event held by the Client or if they are headhunted by the Client through sites such as LinkedIn. It is the Client’s responsibility to notify you of this collection of your Personal Information and the Client will be the primary Data Controller in this scenario. LiveHire does not access or use Temporary Profiles for any purpose other than servicing the Client. A Temporary Profile includes a Member’s name, contact details (including email address and phone number), current role, company, location, curriculum vitae (if available) and whether the Member has been assigned to a talent pool or job vacancy. Our Clients may also provide us with a historical database of past applicants, alumni and other contacts to invite to join their Talent Community. Profiles are not created in the Platform and if the invitation to join is not accepted within set time frames the Personal Information is deleted in accordance with LiveHire’s data deletion policy. Job applications may be made to our Clients via an ‘Apply with Seek’ (a service offered by Seek and paid for directly by our Clients which takes job applicants to the Client’s own careers page, powered by LiveHire). In this Privacy Policy these are referred to as ‘Closed Applications‘. Closed Applications do not create a Member profile and LiveHire does not access or use the information in a Closed Application for any purpose other than to service the applicable Client (ie to allow the Client to manage the job application and communicate with the applicant via the LiveHire Platform) and to store the application within the Platform on the Client’s behalf. If the job applicant is a Member with a pre-existing LiveHire profile then the Closed Application will automatically merge with the Member’s existing profile so long as the email addresses are the same. If the job applicant subsequently creates a LiveHire profile with the same email address as used in the Closed Application, the information included in the new profile will override the Closed Application information.

Information gathered other than during registration We may include other optional requests for information from you, to help us update, improve or tailor the Platform for you and/or deliver personalised information to you. You do not have to provide any additional Personal Information and can opt out of any such request for information at any time from us by clicking ‘unsubscribe’ or using any of the opt-out measures included in communications from us or by emailing us at [email protected]. Any information you choose to provide to us will be held and protected by us in accordance with this Privacy Policy. We also collect Personal Information from our Website, social media pages, phone calls with you, forms completed by you and other correspondence with you. In some circumstances, we and our Service Providers collect information about you from publicly accessible sources, such as Facebook, Google, Seek and LinkedIn. For example, we may collect your Personal Information when you:

  • provide information to comply with our AML (anti-money laundering) processes;
  • request information, material or a demonstration from us;
  • enter one of our promotions;
  • subscribe to our mailing list;
  • provide your business card;
  • attend an event that we host, sponsor or are otherwise involved in;
  • provide your Personal Information to companies that we have acquired or partnered with;
  • apply to become a referral partner;
  • have your details submitted by another person as a referral for a job vacancy; and/or
  • join our social media pages.

Information from third parties We may also collect Personal Information about you from third parties who assist us with lead generation or third-party systems with which we integrate on behalf of Clients. For example, a Client may request that we integrate with Fit2Work to undertake policy checks on candidates before offering them a role. We may collect Personal Information about you from our Clients and publicly available sources. We may keep a record of your use of the Platform or Services and any communication between you and us. If at any time you provide the Personal Information of another person to us, then you must ensure that, and we will assume, that person has read, understands and acknowledges this Privacy Policy. We will treat and protect that person’s Personal Information in accordance with this Privacy Policy.

Sensitive Personal Data We may collect sensitive information including Sensitive Personal Data if you choose to disclose this to us. Your provision of Sensitive Personal Data is optional, and we will not collect this data unless you choose to provide it. You do not have to provide this information to receive our Services. If you choose to provide it, Sensitive Personal Data may include information on your gender, nationality and ethnicity, which we may request for the purposes of verifying work permits and visa requirements and to support diversity initiatives in connection with our provision of the Services. If you voluntarily upload Sensitive Personal Data in a curriculum vitae, such as your criminal or medical history, religion or union membership, you are expressly consenting to us using this data for the purposes set ou in this Privacy Policy. We will not use Sensitive Personal Information for any secondary purpose, unless you would reasonably expect the information to be used for the secondary purpose, that secondary purpose is directly related to the primary purpose of collection and you have consented to that further use. We do not currently collect Sensitive Personal Data on EU/UK Individuals. However, if you are a EU/UK Individual before collecting and/or using any Sensitive Personal Data we will establish a lawful exemption which will allow us to use that information. This exemption will typically be:

  • your explicit consent; or
  • the establishment, exercise or defence by us or third parties of legal claims;

Usage Data We may collect information about which Services you use and how you use them and/or the Platform. This usage data and information includes:

  • Device information: We may collect device-specific information (such as your hardware model, operating system version, unique device identifiers, and mobile network information including phone number). We may associate your device identifiers or phone number with your account. We also automatically collect your browser type and browser software version to optimise the presentation of the Platform to your platform and to maintain a record of your activity on the Platform. Please see our Cookie Policy for further information on how we collect and process browser type information and your rights to opt-out.
  • Log information: When you use our Services or view content provided by us (including through our ‘General Search’ function), we may automatically collect and store certain information in our server logs. This may include:
    • details of how you used the Service, such as search queries;
    • telephony log information;
    • Internet Protocol (IP) address. As an automatic process, our webserver records a log file of IP addresses that access the Platform. We also collect IP addresses and other system information for purposes of statistical analysis and to maintain the security of the Platform. We will not use IP addresses or other system information to identify a User unless we determine, in our sole discretion, that it is necessary to improve our Services or to enforce compliance with our policies or agreements with Users to protect our Service, Platform, Clients and others. Notwithstanding this, we gather only that information that is reasonably necessary for us to operate and improve the Platform and otherwise conduct our business. We use commercially reasonable efforts to ensure our collection of information does not interfere with the operation or security of your system;
    • device event information such as crashes, system activity, hardware settings, browser type, browser language, the date and time of your request and referral URL;
    • we use Hotjar to optimise our Services and User experience and to better understand our Users’ needs (including how much time Users spend on particular pages and which links Users click on). This enables us to build, maintain and improve our Services. Hotjar uses cookies and other technologies to collect data on our Users’ behaviour and their devices (in particular, a device’s IP address (captured and stored only in anonymised form), device screen size, device type (unique device identifiers), browser information, geographic location (country only) and preferred language used to display our Website). Hotjar stores this information in a pseudonymised User profile. Neither Hotjar nor we will use this information to identify individual Users or to match it with further data on an individual User. For further details, please see Hotjar’s privacy policy by clicking on this link. You can opt-out of the creation of a User profile, Hotjar’s storing of data about your usage of our Website and Hotjar’s use of tracking cookies on other websites by following this opt-out link.
  • Location information: When you use a location-enabled service or device, we may collect and process information about your location. We may also use various technologies to determine location, such as sensor data from your device and IP addresses. We collect this data in order to pre-fill forms for you, and to allow relevant suggestions of job opportunities.
  • Unique application numbers Certain Services include a unique application number. This number and information about your installation (for example, the operating system type and application version number) may be sent to us when you install or uninstall that Service or when that Service periodically contacts our servers, such as for automatic updates.
  • Local storage: We may collect and store information, including Personal Information, locally on your device using mechanisms such as browser web storage (including HTML 5) and application data caches.
  • Cookies and anonymous identifiers: We use various technologies to collect and store information when you visit our Platform, including cookies. For more information about our use of cookies, please read our Cookie Policy. Third parties (including advertising networks and providers of external services) may also use cookies, over which we have no control. You should review the privacy policies of such third parties to understand how they use and protect your Personal Information. You always have the option of disabling cookies via your browser preferences. If you disable cookies on your browser, please note that some parts of our Platform may not function as effectively or may be slower.

What we use your Personal Information for

We use the Personal Information we collect from you for a range of purposes, including to:

  • enable us to provide, maintain, protect and improve the Services and our products offered to you, to operate our business and develop new services, and to help us protect you and the Platform;
  • offer you specific and relevant information such as search results, IOPS, work opportunities, connection opportunities and education recommendations, in connection with the provision of our Services;
  • assist you in pursuing potential employment opportunities with, or through, our Clients;
  • as required by law and when complying with our legal obligations and assisting governments, law enforcement agencies or regulators;
  • support our internal business purposes (including administration, planning and product development);
  • issue marketing, promotional and fundraising materials to you;
  • contact you to inform you about updates to the Platform and Services and provide information relating to transactions you may conduct on the Platform;
  • create offer documentation;
  • verify the information you have provided (such as through reference checks and evaluating your suitability for employment opportunities);
  • facilitate your set up in third party systems with which we integrate on behalf of Clients (including payroll, superannuation, onboarding, reference and background checks and video interviewing);
  • infer information such as gender for diversity and reporting purposes; and
  • send alerts about potential job opportunities in our Talent Communities or publicly available online.

We may combine Personal Information from our Services with information from our other services provided to you, or information from a Client or Service Provider and/or Other Third Parties, to ensure we can deliver our Services to you (for example, to validate the Personal Information contained in a profile, curriculum vitae and/or any background checks completed by a Service Provider or LiveHire). We will only do so in accordance with this Privacy Policy.



Direct marketing

We may use your Personal Information to send you direct marketing communications about the Services or our related services. This may be in the form of email, post, SMS, telephone or targeted online advertisements This may also include email communications, including information that we think may be of interest to you, and information on upcoming changes or improvements. In most cases our processing of your Personal Information for marketing purposes is based on our legitimate interests, although in some cases (such as where required by applicable laws or where we use or process any of your Sensitive Personal information or Sensitive Data) it may be based on your explicit consent. You can find out more on how we process your Sensitive Personal Data and Sensitive Information above. You have a right to prevent direct marketing of any form at any time – this can be exercised by following the opt-out links in electronic communications, or contact us. When you receive any permitted electronic marketing communications from us, you may opt out of receiving further marketing communications by following the opt-out instructions provided in the communication. Please specify whether you would like us to stop all forms of marketing or just a particular type (e.g. email). You can also change the way your browser manages cookies, which may be used to deliver online advertising, by following the settings on your browser. See further our Cookies section above and our Cookies Policy. For EU/UK individuals: When and how we carry out profiling and automated decision making We do not conduct any automated decision-making on your Personal Information information. We may use limited profiling or other forms of automated processing for:

  • security purposes only to assess if your account may be fraudulent, a spam account or suspect in any way;
  • the purposes of marketing, and where this is completed we undertake to do this to pursue our legitimate interests of ensuring our marketing communications are relevant to you, its audience and persons to whom it is targeted.

As profiling uses automated processing, it is sometimes connected with automated decision making. Not all profiling results in automated decision making, but it can do. Please note, you have certain rights (including a right to object) in respect of automated decision making, where that decision has significant effects on you, including where it produces a legal effect on you. See below for more information about your rights.


Accessing, correcting and updating your Personal Information

To request access to Personal Information we hold about you, please contact us. If that information is incorrect, out of date or incomplete, we strive to give you ways to update it quickly or to delete it – unless we have to keep that information for legitimate business or legal purposes. When requesting access or changes to your Personal Information, we may ask you to verify your identity before we act on your request. There are some circumstances in which we are not required to give you access to your Personal Information. We may reject requests that are unlawful, frivolous, vexatious, unreasonably repetitive, require disproportionate technical effort (for example, developing a new system or fundamentally changing existing practices), that we believe risk the privacy, health or safety of others, or would be otherwise be extremely impractical (for example requests concerning information on our backup systems or unique ID data on Users). Where we provide information access and correction, we will do so for free, except where in our opinion it would require a disproportionate effort or cost for us to do so. We may require you to meet our reasonable costs in providing you with access including for photocopying and postage. Where you correct, update or otherwise provide personal information, you represent to us that the information you provide to us is, having regard to the circumstances, accurate, up to date and complete, having regard to the purposes of the disclosure, and not misleading or deceptive. We will respond to any requests to change your personal information within a reasonable timeframe and will take all reasonable steps to ensure that the personal information we hold about you remains accurate, up-to-date and complete. For EU/UK individuals If you are an individual based in or a resident of the European Union or the United Kingdom, there are additional rights to your personal data available to you. Please see below your detailed rights including rights of access, erasure, rectification and portability of your personal data.

Right What this means
Access You can ask us to:

  • confirm whether we are processing your Personal Information;
  • give you a copy of that data;
  • provide you with other information about your Personal Information such as what data we have, what we use it for, who we disclose it to, whether we transfer it abroad and how we protect it, how long we keep it for, what rights you have, how you can make a complaint, where we got your data from, to the extent that information has not already been provided to you in this Privacy Policy.
Rectification You can ask us to rectify inaccurate Personal Information. We may seek to verify the accuracy of the data before rectifying it.
Erasure You can ask us to erase your Personal Information, but only where:

  • it is no longer needed for the purposes for which it was collected; or
  • you have withdrawn your consent (where the data processing was based on consent); or
  • following a successful right to object (see ‘Objection’ below); or
  • it has been processed unlawfully; or
  • to comply with a legal obligation to which LiveHire is subject.

We are not required to comply with your request to erase your Personal Information if the processing of your Personal Information is necessary:

  • for compliance with a legal obligation; or
  • for the establishment, exercise or defence of legal claims.
Restriction You can ask us to restrict (i.e. keep but not use) your Personal Information, but only where:

  • its accuracy is contested (see Rectification), to allow us to verify its accuracy; or
  • the processing is unlawful, but you do not want it erased; or
  • it is no longer needed for the purposes for which it was collected, but we still need it to establish, exercise or defend legal claims; or
  • you have exercised the right to object, and verification of overriding grounds is pending.

We can continue to use your Personal Information following a request for restriction, where:

  • we have your consent;
  • to establish, exercise or defend legal claims; or
  • to protect the rights of another natural or legal person.
Portability You can ask us to provide your Personal Information to you in a structured, commonly used, machine-readable format but case only where:

  • the processing is based on your consent or on the performance of a contract with you; and
  • the processing is carried out by automated means.
Objection You can object to any processing of your Personal Information which has our ‘legitimate interests’ as its legal basis, if you believe your fundamental rights and freedoms outweigh our legitimate interests. Once you have objected, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.
International transfers You can ask to obtain a copy of, or reference to, the safeguards under which your Personal Information is transferred outside of the European Economic Area. We may redact data transfer agreements or related documents (i.e. obscure certain information contained within these documents) for reasons of commercial sensitivity.
Supervisory Authority You have a right to lodge a complaint with your local supervisory authority about our processing of your Personal Information. For example, in the UK, the supervisory authority for data protection is the ICO. We ask that you please attempt to resolve any issues with us first, although you have a right to contact your supervisory authority at any time.

If you wish to access any of the above mentioned rights, we may ask you for additional information to confirm your identity and for security purposes, in particular before disclosing Personal Information to you. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive. We may not always be able to fully address your request, for example if it would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way.


Personal Information we share / disclose to other parties

We do not share your Personal Information with any other Person unless one of the following circumstances applies: Client: we share Personal Information with our Client, including user profile details such as your full CV, verification details, LinkedIn or Facebook data, and other personal data you have provided when you apply to connect to or accept an invitation to connect from a Client or join a LiveHire talent community (a ‘Connection’). We ensure the protection of your Personal Information at all times and we have agreements in place with all our Client to maintain your rights on privacy in a similar way to the protections afforded under this Privacy Policy. You are in full control of the privacy settings on your account on the LiveHire Platform. This gives you full control of your Personal Information, including to update your information, and if desired, discontinue sharing that information with specific Client by deactivating the Connection If you are a UK/EU individual based in or resident in the EU/UK, when a Client contacts you or requests additional information from you for its own purposes (for example for the purposes of inviting you for interview for a role), the information you provide directly to Client pursuant to such request will be held and processed by that Client in accordance with their own privacy policy and terms. You should therefore request a copy of and familiarise yourself with the terms and privacy policy of any Client with whom you wish to engage further.

Third Party Service Providers

We provide your information to Third Party Service Providers to help manage our business and deliver services which broadly include:

  • IT service providers who help manage our IT and back office systems including the hosting and storage of personal data (Amazon Web Services  and Microsoft Azure servers in Australia);
  • Messaging service providers (Mailchimp in the United States for Member emails, Salesforce Australia for Client emails, Burst SMS in Australia for SMS)
  • Email validation (DataValidation Europe)
  • CV parsing technology provider who accesses and processes your information and uses parsing technology for the purposes of analysing and producing a structured profile for you (Daxtra servers in Australia)
  • Security and performance service providers (CloudFlare and Sumologic in the United States and Hotjar in Malta)
  • Client relationship management (Salesforce in Australia), support requests (Zendesk in Europe, Asia Pacific and the United States) and invoicing (Netsuite, United States)
  • Internal communication systems (Atlassian, Asana, Trello and Slack in the United States)
  • other third parties that our clients request us to integrate with (for example for the purposes of the employer verifying profile information and conducting video interviews and conferences).

Some of these providers use ‘cloud based’ IT applications or systems, which means that your personal data will be hosted on their servers, but under our control and direction.

We request all our third party service providers to respect the confidentiality, privacy and security of personal data and our contracts with them include obligations for them to comply with applicable privacy laws and to use any Personal Information we share with them solely for the purpose of providing services to us.

For legal reasons: we may share or limit access to your Personal Information if we have a good-faith belief that access, use, preservation or disclosure of, or restriction therefrom, the information is reasonably necessary to comply with any applicable legal, regulatory or other administrative or governmental process, enquiry or action, enforce our Agreement with you or investigate any potential breach, detect, prevent, or otherwise address any potential fraud, security or technical issues, or protect against potential harm to the rights, property or safety of our Users, us or the public. We may also disclose Personal Information where we are required to do so by applicable laws. Restructure of our Business – If we are involved in or contemplate a merger, acquisition, asset sale, corporate restructure or other similar transaction, we may disclose certain information regarding the Platform and the Services, which may include Personal Information, to potential purchasers or investors for our legitimate business purposes. We will do so subject to acceptable confidentiality obligations being granted to us. Anonymised/ Aggregated Information: We may use and disclose to any person any de-identified information (not personally identifiable on its own or in combination with any other information held by us) we obtain from Users’ use of the Platform, including statistical information of your use of our Services which is in aggregated and anonymised form. LiveHire will only use and disclose fully anonymised and de-identified statistical data information which is not Personal Information for the purposes of and in accordance with all applicable privacy laws.


International transfers

Your personal information may be disclosed, transferred to or processed outside of your country of residence including to Australia, New Zealand, the United States, Europe and Asia Pacific. Your personal information is principally maintained within data centres and servers located in Australia. When you connect with Clients for employment opportunities, the information shared with those Clients may be processed in the countries in which they operate which may be outside of Australia. We take measures (including contractual commitments from LiveHire) to ensure that any disclosure of your personal information outside of Australia is completed in compliance with Australian Privacy laws. For EU/UK Individuals: If you are an individual based in or a resident of the European Union or the United Kingdom, your data may be processed outside of the European Union in countries, including in Australia, New Zealand, the United States, Europe and Asia Pacific that are subject to different standards of data protection. We will take appropriate steps ensure that transfers of personal information are in accordance with applicable law and carefully managed to protect your privacy rights and interests and transfers are limited to countries which are recognised as providing an adequate level of legal protection or where we can be satisfied that alternative arrangements are in place to protect your privacy rights. To this end: although LiveHire is not currently part of a group of companies, we will ensure that in the event that LiveHire becomes part of a group of companies at any time, any transfers of your personal information between members of this group of companies will be covered by an agreement (an intra group agreement) which contractually obliges each member to ensure that personal information it receives is adequate and consistent level of protection wherever it is transferred within the group of companies; where we transfer your personal information outside any future group of companies or to third parties who help provide our Services, we obtain contractual commitments from them to protect your personal information. Some of these assurances are well recognized certification schemes like the EU / US ‘Privacy Shield’ for the protection of personal information transferred from within the EU to the United States and /or the use of EU approached Standard Contractual Clauses (‘EU Model Clauses’) for controller to controller and /or controller to processor transfers from the EU /UK to jurisdictions, such as Australia and/or New Zealand, the United States and countries in the Asia-Pacific region who do not have an adequacy finding from the EU Commission ; and/or where we receive requests for information from law enforcement or regulators, we carefully validate these requests before any personal information are disclosed. You have a right to contact us for more information about the safeguards we have put in place (including a copy of relevant contractual commitments) to ensure the adequate protection of your personal information when this is transferred as mentioned above.


Application

Our Privacy Policy applies to all of the Services provided by us. Links to other sites Our Privacy Policy does not apply to services offered by other companies or individuals who are not LiveHire, including products or sites that may be displayed to you in search results, sites that may include our Services, or other sites linked to or from our Services. Our Privacy Policy does not cover the information practices of other companies and organisations who use our services, and who may use cookies, pixel tags and other technologies to serve and offer advertisements and information. Please see the associated privacy policies of such other third party websites or links for information on how these third parties process your personal information. Many of our Services also let you share information with others. Remember that when you share information publicly – like on Facebook, Linked-in or any blog – it may be indexable by search engines, such as Google. We are not responsible for the privacy practices or the content of any other websites to which the Platform links or which link to the Platform. By clicking on a link, logo or other item, please note that you may no longer be on the Platform. To check what Internet location you are on, always note the URL at the top and/or bottom of your browser. We encourage you to read the posted privacy statement of any website whenever interacting with it.


How long do we keep your Personal Information?

We will retain your personal information for as long as is reasonably necessary for the purposes for which we collect this information. In some limited circumstances we may retain your personal information for longer periods of time, for instance where we are required to do so in accordance with legal, regulatory, tax or accounting requirements. In specific circumstances we may also retain your personal information for longer periods of time so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your personal information or dealings. We aim to maintain our Services in a manner that protects information from accidental or malicious destruction. At the request of any Client or Member, all data belonging to the requesting party can be removed from the system. For EU / UK individuals: To determine the appropriate retention periods, we consider the amount, nature and sensitivity of the personal data potential risk of harm from unauthorised use or disclosures the purposes for which we process your personal information and whether we can achieve those purposes through other means and the applicable legal requirements. In some circumstances we may store your personal information for longer periods of time than others, for instance where we are required to do so in accordance with legal, regulatory, tax, accounting requirements. This may be for a seven (7) year period unless the applicable law prescribes otherwise. If you would like more information on how we retain your data, please contact us.


Security

We recognise our responsibility to protect the personal information that you entrust to us. We take security very seriously and work together with you, developers and external security experts to design security into our products from the ground up (including through implementing privacy by design and security by design measures). We store most information about you in computer systems and databases operated by either us or our external cloud Service Providers. Some information about you may be recorded in paper files that we store securely. Our information storage is on secure computers in locked information centres and data is encrypted, wherever possible. However, as the transmission of information across the internet is not completely secure we cannot guarantee the security of your information transmitted to our website and issues can arise. We will also take reasonable steps to destroy or de-identify personal information once we no longer require it for the purposes for which it was collected or for any secondary purpose permitted under the Australian Privacy laws and/or other applicable data privacy laws. We recommend that you create a secure password, do not disclose your password and account details to anyone, and that you change your password each month. As the security of information depends in part on the security of the computer or device you use to communicate with us and the security you use to protect your user IDs and passwords, we encourage you to please take appropriate measures to protect this information. Our Platform is operated using security measures, including SSL (Secure Sockets Layer) encryption, to protect your personal data. SSL is an industry standard encryption protocol, and this ensure that the information is reasonably protected against unauthorised interception. We also implement and maintain processes and security measures to protect personal information which we hold from misuse, interference or loss, and from unauthorised access, modification or disclosure. These processes and measures may include: requiring all employees to comply with internal information security policies and keep information secure; requiring all employees to complete training about information security; and monitoring and regularly reviewing our practices against our own policies and against industry best practice


Enforcement and complaints

We regularly review our compliance with this Privacy Policy as well as under applicable privacy laws. If you have a complaint regarding this policy or any breach of applicable privacy laws, please contact us immediately to register your complaint and let us know what we can do to resolve it. If we do receive your formal written complaint, we will contact respond to your complaint within a reasonable time and do everything reasonably practicable to resolve the complaint with you. We hope it won’t ever come to this, but if you’ve already contacted us and feel that your complaint cannot be resolved between us, you can contact the relevant local data protection supervisory authority (i.e. your place of habitual residence, place or work or place of alleged infringement). In Australia, this is the Office of the Australian Information Commissioner (OAIC). We will work with the appropriate regulatory and supervisory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of personal information that we cannot resolve with you directly. Please note, you may choose to contact us in relation to a particular matter on an anonymous basis or using a pseudonym and, unless it is impracticable for us to do so or we will not be able to respond reasonably to your complaint, we will attempt to resolve your enquiry on such basis.


Changes

We may review or update our Privacy Policy from time to time. Revised versions will be available on the Website and will apply to your use of the Website, the Platform and the Services from the date of publication. Please regularly check these pages for the latest version of this notice. Any changes will take effect as soon as we publish the new Privacy Policy but there we have already collected information about you, we may take additional steps to inform you of any material changes to our Privacy Policy, including by posting on the Website, through pop-up notices or via email. These policies are published by and remain the property of LiveHire Ltd (ABN 59 153 266 605).


Contact us

If you’ve got any questions or issues with your information, please contact us at: LiveHire Ltd Level 10/461 Bourke Street Melbourne, VIC 3000 Email: [email protected]


Appendix 1 – Categories of Personal information

Information type Details of information that we typically capture
Individuals
Contact Details Name, address, telephone number, email address
Employment Information Resume, employment intentions, Nationality/Right to work
Personal Information Gender, date of birth, profile photo
Marketing Name, email address, interests/marketing list assignments, record of permissions or marketing objections, website data (including online account details, IP address and browser generated information)
Clients
Contact Details Business or company name, name, work address, work email, work telephone numbers, job title, profile photo
Marketing Name, email address, interests/marketing list assignments, record of permissions or marketing objections, website data (including online account details, IP address and browser generated information)

Appendix 2 – Legal Basis for Processing

Activity Type of information collected The basis on which we use the information Who we may disclose the information to
Individuals
Set up a record on our systems
  • Contact Details
  • Employment Information
  • Personal Information
  • Legitimate interests
  • Performance of Contract with you
  • Third Party Service Providers and Other Third Parties
  • Clients
Provide assistance and support
  • Contact Details
  • Legitimate interests
  • Performance of Contract with you
  • Third Party Service Providers and Other Third Parties
  • Clients
Marketing
  • Contact Details
  • Marketing
  • Consent
  • Legitimate interests
  • Third Party Service Providers and Other Third Parties
  • Clients
Comply with legal and regulatory obligations
  • Contact Details
  • Legal obligation
  • Regulators
  • Law enforcement bodies
  • Courts
Diversity initiatives
  • Nationality
  • Gender
  • Consent
  • Legitimate Interests
  • Third Party Service Providers and Other Third Parties
  • Clients
Clients
Manage relationships
  • Contact Details
  • Legitimate interests
  • Third Party Service Providers and Other Third Parties
  • Clients
Administer contracts
  • Contact Details
  • Performance of a contract
Marketing
  • Contact Details
  • Marketing
  • Consent
  • Legitimate interests
  • Third Party Service Providers and Other Third Parties
  • Clients
Applicable to all
Transfer books of business
  • All (where relevant to the book)
  • Legitimate interests
  • Legal obligation
  • Courts
  • Purchaser
  • Professional advisers
Sale or reorganisation of LiveHire
  • All
  • Legitimate interests
  • Legal obligation
  • Courts
  • Purchaser
  • Professional advisors

Definitions

Account means your profile and account that is held on the Platform. Connection (also Talent Community Connection) means an agreement between a Member and a Client to be connected for potential employment opportunities and related communication. It can arise in several ways, for example through a Member choosing to join a Client’s Talent Community, applying for a job, or accepting a contact request or invitation sent from a Client. Data Controller means a natural or legal person (such as a company) which determines the means and purposes of processing of personal information. LiveHire will be your Data Controller as it determines how it will collect personal information from you, the scope of data which will be collected, and the purposes for which it will be used. Clients means LiveHire’s clients and other organisations who use our Services and/or Platform. Other Third Parties means those categories of third parties in the above section ‘Information we share / disclose t other parties’. Person means any individual, company, partnership, joint venture or other legal entity or entities. Personal Data means any information (including Personal Information) capable of identifying a natural person, directly or indirectly, in particular by reference to an identification number or to one or more factors specific to their, his or her physical, physiological, mental, economic, cultural or social identity. Data is considered personal when it enables anyone to link information to a specific person, even if the person or entity holding that data cannot make that link. Personal Information has the meaning given to it in the Australian Privacy Act 1988 (Cth) as amended. Platform means the Website and all associated software, apps, files, emails, SMS, pictures, data, hardware, technology, business systems and processes and other resources. Processing means any operation or set of operations that is performed upon Personal Data, whether or not by automatic means, including, but not limited to collection, recording, organisation, storage, access, adaptation, alteration, retrieval, consultation, use, disclosure, dissemination, making available, alignment, combination, blocking, deleting, erasure, or destruction. Services means any products, goods or services that we or any Client or Third Party Service Provider may provide to or for you, whether or not via the Platform. Sensitive Information has the meaning given to it in the Australian Privacy Act 1988 (Cth), as amended. Sensitive Personal Data means any personal information relating to your health, criminal convictions, sex life, sexual orientation, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership. If you are an EU/UK individual Sensitive Personal Data will also include genetic and biometric data if collected for the purposes of uniquely identifying you. Service Providers include a range of third parties to whom we outsource certain functions of our business for our back-office, IT and professional support services (e.g. partners, service providers, contractors and agents such as IT and web support contractors, cloud service providers, finance agencies), and includes Third Party Service Providers. Some of these providers use ‘cloud based’ IT applications or systems, which means that your personal information will be hosted on their servers, but under our control and direction. We require all our service providers to respect the confidentiality and security of personal information. Third Party Service Providers mean our licensors, contractors, partners, suppliers and distributors, and their respective directors, and employees, including marketing partners and analysis auditors. User means a Person whose name is specified during an online registration process to create an Account on the Platform in the name of that Person, whether that Person then uses the Platform as a Client, Member, or on some other basis. Verification means the validation of any part of the personal information contained in a Member’s profile, CV and/or any background checks, completed by a Third Party Service Provider or LiveHire. Website means the website(s) located at www.livehire.com, www.livehire.com.au and/or www.FIFObids.com.au, our Blog and all other related domains and subdomains. Member means a User who registers with the Platform as a “Member” and uses the Platform and/or the Services primarily to search for, contact or otherwise engage with Client or other Users for its own purposes. A Member may include an individual user who is assigned an account on our Platform by their administrator, such as a Client. If you are such an individual, different or additional terms may apply and your administrator may be able to access or disable your account.