Privacy Policy
About this Privacy Policy
This Privacy Policy outlines how PageUp People Limited (ACN 005 630 740) and its related companies (collectively, “PageUp”) manages your personal information. It also describes what personal information is held, for what purposes it is held, and how that information is collected, held, used and disclosed. This policy applies to all your dealings with us, including on our website.
This policy does not apply to the practices and processing of our customers, to companies that we do not own or control, to individuals that we do not employ or manage, to services.
PageUp recognises that your privacy is important to you. We take protecting your personal information seriously.
What personal information do we collect?
General
PageUp may collect personal information for purposes related to the management, operation, promotion and improvement of our business and our products and services, including our talent management software products and services. For people who are interested in PageUp and its products, the information collected may include details such as your name, postal address, email address, telephone number, details of your job title and role and potentially information about your use of our products and services. We may also collect information about your communications, interactions and transactions with us, including contact we have with you via email, telephone or in person.
Potential job candidates
For people who are interested in working at PageUp or who may be potential candidates for employment with PageUp, the information collected may include your name, postal address, email address, telephone number, employment history, visa details and educational qualifications. PageUp may also collect, store or process other personal information about you that you choose to include in your resume or curriculum vitae.
How we collect personal information
We may use your personal information if:
- you have provided your consent to such use; or
- it is necessary for the performance of a contract with you; or
- necessary in connection with a legal or regulatory obligation; or
- we are otherwise required or authorised by law.
General
Where it is reasonable or practicable to do so, we collect your personal information from you. This may happen when you ‘Contact us’ via our website, subscribe to our newsletter or events, enquire about a service or product, apply online for a job at PageUp or when you give us personal information over the telephone or email, at an event or in person. We may also collect personal information from third party sources including your representatives, our related companies, your employer, background checking service providers and other trusted parties with whom we exchange personal information. By accepting this privacy policy, you consent to such third parties providing us with your personal information.
PageUp may also collect contact details and other personal information from data supply companies or professional conference administrators to use for the purpose of marketing PageUp’s products and services (provided that we are authorised to do so by law).
Potential job candidates
For people who are interested in working at PageUp or who may be potential candidates for employment with PageUp, our recruitment team may also collect information about you from publically available sources including social media resources such as LinkedIn Recruiter, Seek and Indeed.
How we hold personal information
PageUp primarily holds data electronically, both at our own premises and with the assistance of our third party service providers. We also hold some hard copy records, including in relation to job candidates. PageUp takes data security seriously. Accordingly, we have put in place various security measures to protect personal information we collect and hold from unauthorised use, modification or disclosure, including as referred to in the Security section below. PageUp also takes steps to ensure that it retains personal information for as long as is necessary to fulfil the purposes described in this policy and deal with disputes unless a longer period is required or authorised by law.
Cookies
Our website uses cookies to administer, analyse and improve the website performance and content. A cookie is a piece of information that an internet website sends to your browser when you access information at that site. If you do not wish to receive cookies, you may be able to change the settings of your browser to refuse all cookies or to notify you each time a cookie is sent to your computer, giving you the choice whether to accept it or not.
Through the use of cookies and other technology, our website may also detect and use your IP address or domain name for internal traffic monitoring and capacity management purposes and to deliver tailored content. PageUp tracks the usage patterns of its website visitors for purposes related to improving our services and website content based on an aggregate or statistical review of website visitor use patterns. This is not, on its own, personal information. However, if you choose to provide us with your personal information by, for example, completing an online form on our website, we may link your browsing activity and your IP address or domain name with your personal information in order to personalise your website experience and to gain an understanding of which PageUp products and services may be of interest to you.
Why we collect personal information
General
We collect personal information for the purposes of delivering services, keeping you updated about PageUp, our products and developments and inviting you to events which may be relevant to you and your business.
Potential job candidates
We collect personal information for the purpose of identifying and qualifying candidates for career opportunities within our organisation.
Use and disclosure of information
General
We use and disclose personal information for the purposes of conducting our business activities, improving and personalising our products and services and customer experience, complying with our legal requirements, protecting our lawful interests, updating our records, training and managing our staff, dealing with enquiries and disputes, verifying your identity and personal information, corresponding with you, keeping you updated about PageUp, our products and developments and inviting you to events which may be relevant to you and your business. We may also collect, hold, use and disclose personal information in relation to:
- acquisitions or potential acquisitions of our business or assets,
- lawful requests from courts, government agencies and lawyers, or
- investigating suspected unlawful activity.
PageUp may also use your information to notify you of important changes to our website or this policy.
As a global business, PageUp does business in a number of countries around the world, including (amongst others) Australia, the United Kingdom, the United States, Singapore, Hong Kong and the Philippines. Depending on the particular circumstances, we may exchange personal information with your and our representatives, regulatory authorities, our related companies and our service providers. Our service providers include those that assist us with archival, auditing, accounting, customer contact, legal, business consulting, banking, payment, mailing, delivery, data processing, data analysis, document management, information broking, research, investigations, insurance, website and technology services.
Some of the third parties mentioned in this policy may be located in Australia, the United Kingdom, Ireland, the United States, Singapore, Hong Kong, Argentina, Poland, the Philippines and in other countries. Where we transfer your personal information outside of your country, we take steps to ensure that your information is treated securely. You agree to us handling your information in the manner set out in this policy and that the obligations imposed by privacy laws in other countries may be less stringent than the requirements established by the privacy laws in your country. Where we transfer your information internationally we will take reasonable steps to ensure that your information is treated securely and the means of transfer provides adequate safeguards.
If you are a customer or potential customer of PageUp, your personal information may be used to deliver services as well as to inform you on an ongoing basis of additional products and services or special promotions that may be of interest to you, unless you opt out or we are subject to legal restrictions. You can choose not to receive such information when you are registering for a product or service on the PageUp website. PageUp’s electronic marketing communications will provide you with a simple means to opt out of receiving similar communications in the future.
Potential job candidates
We use and disclose personal information for the purpose of identifying and qualifying candidates for current and future career opportunities within our organisation. This may include assessing your job application and work history, conducting security and criminal checks, exchanging information with your listed referees, previous employers and academic institutions, and conducting aptitude and psychometric testing and reference checks. As part of the recruitment process, we may need to disclose your personal information to third party service providers who assist us to carry out testing and other checks.
Some of the third parties may be located in Australia, the United Kingdom, the United States, Singapore, Hong Kong, Argentina, Poland, the Philippines and in other countries. Where we transfer your personal information outside of your country, we take steps to ensure that your information is treated securely. You agree to us handling your information in the manner set out in this policy and that the obligations imposed by privacy laws in other countries may be less stringent than the requirements established by the privacy laws in your country. Where we transfer your information internationally we will take reasonable steps to ensure that your information is treated securely and the means of transfer provides adequate safeguards.
We may also use and disclose personal information for the purpose of communicating to our talent pool candidates to share relevant company information and insights, share new opportunities and remind them to keep their details up to date so we can better assess their suitability to future roles.
Your sensitive information
PageUp will not, without your consent or as otherwise authorised by law, collect information about you that reveals your racial or ethnic origin, political opinions, religious or philosophical beliefs or affiliations, membership of a professional or trade association, membership of a trade union, details of health, disability, sexual orientation, or criminal record.
Potential job candidates
As part of our recruitment process for roles at PageUp, we may collect information from you about your membership of a professional association (eg Institute of Chartered Accountants), in relation to any medical condition that you feel would impact your ability to perform the role, and in relation to your criminal record (for the purpose of conducting criminal and security checks). We will only collect such information with your consent or where such collection is otherwise authorised by law.
Access to personal information held
General
We will, at your request, provide you with access to any personal information which we hold about you, subject to some exceptions allowed by any applicable law.
If you wish to access personal information which we hold about you, please contact us using the ‘Contacting us – Privacy’ details below. If you believe any information is inaccurate, incomplete or out of date, please contact us.
If we refuse to grant you access to the personal information that is the subject of your request, we will give you a written notice setting out various matters including the reason for the refusal.
Potential job candidates
If you are registered on our Careers page, we provide you with the means to ensure that your profile is correct and current. You may review and update this information at any time through the Careers page on our website.
If you wish to access personal information, but cannot access that information at our website, please contact us using the ‘Contacting us – Privacy’ details below.
If we refuse to grant you access to the personal information that is the subject of your request, we will give you a written notice setting out various matters including the reason for the refusal.
Correction of personal information held
The privacy laws of some jurisdictions give individuals the right to access, amend or delete their personal information or, in some circumstances, to restrict or object to the processing of their personal information. You can request that we correct personal information we hold about you and we will consider, respond and action such requests in accordance with applicable law. If you would like to request a copy of your data, or would like to take steps to exercise your rights please contact us as set out below. We may refuse to provide access and may charge a fee for access if the relevant legislation allows us to do so, in which case we will provide reasons for our decision as required by law.
If you are registered on our Careers page, we provide you with the means to ensure that your profile is correct and current. You may review and update this information at any time through the Careers page on our website.
If we refuse to correct the personal information that is the subject of your request, we will give you a written notice setting out various matters including the reason for the refusal.
Dealing with us anonymously
You can deal with us anonymously where it is lawful and practicable to do so. However, if you choose not to provide your personal information to us, we may not be in a position to do the things described in this policy. For example, we may not be able to provide a particular product or service, process your job application or correspond with you.
Concerns
If you are concerned about how we have handled your personal information, you should provide us with details in writing using the ‘Contacting us – Privacy’ details below.
We will then respond to the complaint in writing within a reasonable time (usually 30 days or as otherwise required by relevant applicable laws).
For information about privacy generally, or if your concerns are not resolved to your satisfaction, you may contact the government agency or judicial body in your country that administers the applicable privacy law. In Australia, you may contact Office of the Australian Information Commissioner at www.oaic.gov.au and on 1300 363 992. In the UK, you may contact the Information Commissioner’s Office at www.ico.org.uk and on 0303 123 1113. You may also have the right to submit a complaint to the relevant supervisory authority in your jurisdiction.
Security of information
We use a variety of physical and electronic security measures, including restricting physical access to our offices, network firewalls, secure databases to keep personal information secure from misuse, interference and loss, and unauthorised access, modification or disclosure.
PageUp also monitors developments in security and encryption technologies.
Contacting us – Privacy
If you would like to contact us about privacy, please contact:
Privacy Contact/Data Protection Officer
PageUp People Limited
c/o Ashurst Australia,
Level 16,
80 Collins Street, South Tower
Melbourne, VIC, 3000, Australia
February 2019