Privacy Policy

We understand that protecting your personal information is important. This Privacy Policy sets out our commitment to protecting the privacy of personal information provided to us, or otherwise collected by us when providing our Services to you. In this Privacy Policy we, us or our means Alooba Pty Ltd ABN 96 631 848 872.

 

 

 This Privacy Policy takes into account the requirements of the Privacy Act 1988 (Cth) and the Australian Privacy Principles. In addition to the Australian laws, individuals located in the European Union (EU) may also have additional rights under the General Data Protection Regulation 2016/679 (GDPR). Personal information under the GDPR is referred to as personal data and is defined as information relating to an identified or identifiable natural person (individual). Throughout this privacy policy, where we use the term ‘personal information' this refers to ‘personal information’ and ‘personal data’, as applicable.

 

 

 Types of information

 

 Personal information or personal data: is information or an opinion, whether true or not and whether recorded in a material form or not, about an individual who is identified or reasonably identifiable.

 

 Sensitive information or special categories of data: is a sub-set of personal information that is given a higher level of protection. It means information relating to your racial or ethnic origin, political opinions, religion, trade union or other professional associations or memberships, philosophical beliefs, sexual orientation or practices, criminal records, health information or biometric information.

 

 The information we collect

 

 Personal information: The types of personal information we may collect about you include:

 

 As an Alooba for Work customer or recruitment services customer:

 

 - your name;

 - your email address;

 - your phone number;

 - the organisation you work for;

 - your job title;

 - your level of data maturity;

 - your role in hiring;

 - your feedback provided to us about your user experience;

 - additional personal information that you provide to us, directly or indirectly, through your use of our Services, associated applications, associated social media platforms and/or accounts from which you permit us to collect information; and

 - any other personal information requested by us and/or provided by you or a third party.

 

 As an Alooba Community user

 

 - your name;

 - your email address;

 - your Google and/or LinkedIn account unique id;

 - the city you live in;

 - the number of years of your analytical work experience;

 - your base salary;

 - the industry you work in;

 - your feedback provided to us about your user experience;

 - additional personal information that you provide to us, directly or indirectly, through your use of our Services, associated applications, associated social media platforms and/or accounts from which you permit us to collect information; and

 - any other personal information requested by us and/or provided by you or a third party.

 

 As an individual invited to use our Services by a customer of ours, we may collect:

 

 - your name;

 - your email address;

 - your CV, which itself may include numerous pieces of information;

 - a self-assessment of your own skills;

 - your identified gender;

 - the country you live in;

 - the number of years of your analytical work experience;

 - the year of your birth;

 - the job description and/or the job ad of the role that you are sitting the test for;

 - your feedback provided to us about your user experience;

 - additional personal information that you provide to us, directly or indirectly, through your use of our Services, associated applications, associated social media platforms and/or accounts from which you permit us to collect information; and

 - any other personal information requested by us and/or provided by you or a third party.

 

 As a candidate for our recruitment services

 

 - your name;

 - your email address;

 - your phone number;

 - your CV, which itself may include numerous pieces of information;

 - the country you live in;

 - the number of years of your analytical work experience;

 - your feedback provided to us about your experience of our Services;

 - additional personal information that you provide to us, directly or indirectly, through your use of our Services, associated applications, associated social media platforms and/or accounts from which you permit us to collect information; and

 - any other personal information requested by us and/or provided by you or a third party.

 

 As a user of our website or platform:

 

 - your browser session and geo-location data, device and network information, statistics on page views and sessions, acquisition sources, search queries and/or browsing behaviour; and

 - information about your access and use of our Services, including through the use of Internet cookies, your communications with our online Services, the type of browser you are using, the type of operating system you are using and the domain name of your Internet service provider.

 

 

 Sensitive information or special categories of data: We do not actively request sensitive information or special categories of data about you. If at any time we need this type of information about you, unless otherwise permitted by law, we will first obtain your consent and we will only use it as required or authorised by law.

 

 

 How we collect personal information

 

 We collect personal information in a variety of ways, including:

 - Directly: We collect personal information which you directly provide to us, including when we onboard you as a customer, when you complete any questionnaires for us before sitting a skills assessment, when you make an account with us, when you fill in any ‘contact us' form on our website or when you request our assistance via email, social media or over the telephone.

 

 - Indirectly: We may collect personal information which you indirectly provide to us while interacting with us, such as when you use our website, in emails, over the telephone and in your online enquiries.

 

 - From third parties: We collect personal information from third parties, such as where your employer or a business that you have applied for a job with sends you a link to participate in one of our skills assessments or send your contact details to us, where we get your contact details from a publicly available source such as LinkedIn, from your referees where you are applying for a job and where we receive details of your use of our website from our analytics and cookie providers and marketing providers. See the “Cookies” section below for more detail on the use of cookies.

 

 

 Collection and use of personal information

 

 We may collect, hold, use and disclose personal information for the following purposes:

 

 - to enable you to access and use our Services, including to provide you with a login where relevant;

 - to send you (and our customer if relevant) your results after sitting one of our skills assessments;

 - where you are a candidate and have engaged us to provide recruitment services, to assist you to find employment and to verify your work rights status;

 - to contact and communicate with you;

 - to receive your feedback on our Services;

 - for internal recordkeeping, administrative, invoicing and billing purposes;

 - for analytics, market research and business development, including to operate and improve our Services and any associated platforms;

 - to run promotions, competitions or offer additional benefits to you;

 - for advertising and marketing, including sending you promotional information about our products and services and information that we consider may be of interest to you;

 - to comply with our legal obligations and resolve any disputes that we may have;

 - if you have applied for employment with us; to consider your employment application; and

 - if otherwise required by law.

 

 

 Disclosure of personal information to third parties

 

 We may disclose personal information to:

 

 - the business that requested you to take one of our skills assessments;

 - if we are assisting you to find employment, to potential employers and your referees;

 - third party service providers for the purpose of enabling them to provide their services to us, including (without limitation) IT service providers (such as HubSpot), data storage, web-hosting and server providers, debt collectors, maintenance or problem-solving providers, marketing or advertising providers and professional advisors;

 - our employees, contractors and/or related entities;

 - our existing or potential agents or business partners;

 - anyone to whom our business or assets (or any part of them) are, or may (in good faith) be, transferred;

 - credit reporting agencies, courts, tribunals and regulatory authorities, in the event you fail to pay for goods or services we have provided to you;

 - courts, tribunals, regulatory authorities and law enforcement officers, as required by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights;

 - third parties to collect and process data, such as Google Analytics (to find out how Google uses data when you use third-party websites or applications, please see www.google.com/policies/privacy/partners/ or any other URL Google may use from time to time), Facebook Pixel or other relevant analytics businesses; and

 - any other third parties as required or permitted by law, such as where we receive a subpoena.

 

 

 How we process personal information

 

 Where the GDPR applies we must have a legal basis to process your personal information. We will process your personal information in accordance with the following legal bases:

 

 - Legitimate interests: We will process your personal information for our legitimate interests to allow you to access and use our website, to send you marketing content we think may be of interest to you, to contact you if you leave your contact details with us or if you otherwise initiate contact with us, to offer recruitment services to you if your contact details are publicly available such as on LinkedIn, to review and improve our Services and for our internal business purposes.

 

 - Performing a contract: We will rely on performing a contract to process your personal information where we are preparing to enter into a contract with you or we are carrying out our obligations under a contract with you, including where you have entered into a contract with us for Alooba for Work, Alooba Community, to take a skills assessment on our website or to provide recruitment services to you.

 

 - We will rely on a legal obligation to process your personal information where we are subject to a legal obligation, including to respond to any illegal activity and are taxation purposes.

 

 - If we need to rely on consent, we will ask for consent to process any of your personal information for that specific purpose before we process your personal information for that purpose.

 

 Upon written request, we may provide you with a list of the third parties we use to process your personal information.

 

 

 Data transfers

 

 The countries to which we send data for the purposes listed above may not have the same data protection laws as the country in which you initially provided the information. If we transfer your personal information to third parties in other countries: (i) we will perform those transfers in accordance with the requirements of the GDPR and/or Privacy Act (as applicable); and (ii) we will protect the transferred personal information in accordance with this privacy policy.

 

 Our commitment to you

 

 Your personal information will:

 

 - be processed lawfully, fairly and in a transparent manner by us;

 

 - only be collected for the specific purposes we have identified in the ‘collection and use of personal information’ clause above and personal information will not be further processed in a manner that is incompatible with the purposes we have identified;

 

 - be collected in a way that is adequate, relevant and limited to what is necessary in relation to the purpose for which the personal information is processed;

 

 - be kept up to date, where it is possible and within our control to do so (please let us know if you would like us to correct any of your personal information);

 

 - be kept in a form which permits us to identify you, but only for so long as necessary for the purposes for which the personal information was collected; and

 

 - be processed securely and in a way that protects against unauthorised or unlawful processing and against accidental loss, destruction or damage.

 

 

 Data retention

 

 We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

 

 To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information, whether we can achieve those purposes through other means and the applicable legal requirements.

 

 In some circumstances you can ask us to delete your data: see ‘erasure’ below for further information.

 

 In some circumstances, we may anonymise your personal information (so that it can no longer be associated with you) for analytics, research or statistical purposes in which case we may use this anonymised information indefinitely without further notice to you.

 

 Your rights and controlling your personal information

 

 Your choice: Please read this privacy policy carefully. If you provide personal information to us, you understand we will collect, hold, use and disclose your personal information in accordance with this privacy policy. You do not have to provide personal information to us, however, if you do not, it may affect your use of our Services.

 

 Information from third parties: If we receive personal information about you from a third party, we will protect it as set out in this privacy policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have such person’s consent to provide the personal information to us.

 

 Anonymity: Where practicable we will give you the option of not identifying yourself or using a pseudonym in your dealings with us.

 Unsubscribe: To unsubscribe from our email database or opt-out of communications (including marketing communications), please contact us using the details below or opt-out using the opt-out facilities provided in the communication.

 

 Access: You may request details of the personal information that we hold about you. Where legally permitted, an administrative fee may be payable for the provision of access to such information.

 

 Correction/Rectification: If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the details below. We will take reasonable steps to promptly correct any information found to be inaccurate, incomplete, misleading or out of date.

 

 Complaints: If you wish to make a complaint, please contact us using the details below and provide us with full details of the complaint. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take in response to your complaint. You also have the right to contact the relevant authority in the country in which you are based.

 

 Extra rights for EU individuals

 

 Objecting to processing: You have the right to object to the processing of your personal information that is based on our legitimate interests or public interest. If this is done, we must provide compelling legitimate grounds for the processing which overrides your interests, rights and freedoms, in order to proceed with the processing of your personal information.

 

 Restricting processing: You have the right to request that we restrict the processing of your personal information if (i) you are concerned about the accuracy of your personal information; (ii) you believe your personal information has been unlawfully processed; (iii) you need us to maintain the personal information solely for the purpose of a legal claim; or (iv) we are in the process of considering your objection in relation to processing on the basis of legitimate interests.

 

 Data portability: You may have the right to request that we transfer the personal information we hold about you to a third party.

 

 Erasure: You may have the right to request that we erase the personal information we hold about you.

 

 

 Storage and security

 

 We are committed to ensuring that the personal information we collect is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures, to safeguard and secure personal information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.

 We cannot guarantee the security of any information that is transmitted to or by us over the Internet. The transmission and exchange of information is carried out at your own risk.

 

 

 Cookies and web beacons

 

 We may use cookies on our online Services from time to time. Cookies are text files placed in your computer's browser to store your preferences. Cookies, by themselves, do not tell us your email address or other personally identifiable information.

 You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our online Services.

 We may use web beacons on our online Services from time to time. Web beacons (also known as Clear GIFs) are small pieces of code placed on a web page to monitor the visitor’s behaviour and collect data about the visitor’s viewing of a web page. For example, web beacons can be used to count the users who visit a web page or to deliver a cookie to the browser of a visitor viewing that page.

 We may use Google Analytics to collect and process data. To find out how Google uses data when you use third-party websites or applications, please see www.google.com/policies/privacy/partners/ or any other URL Google may use from time to time.

 

 

 Links to other websites

 

 Our Services may contain links to other websites. We do not have any control over those websites and we are not responsible for the protection and privacy of any personal information which you provide whilst visiting those websites. Those websites are not governed by this privacy policy.

 

 Amendments

 

 We may, at any time and at our discretion, vary this privacy policy. We will notify you if we amend this privacy policy, by contacting you through the contact details you have provided to us. Any amended privacy policy is effective once we notify you of the change.

 

 For any questions or notices, please contact our Privacy Officer at:

 

 Alooba Pty Ltd ABN 96 631 848 872

 

 Email: admin@alooba.com

 

 

 Last Update: 2021-07-29