Protecting your personal
information is important

This Privacy Policy sets out our commitment to protecting your personal data

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 data analytics consultancy services (Services). In this Privacy Policy we, us or our means Talent First AI Pty. Ltd. (trading as Culturate) ABN 97 643 400 131.

Types of information

Personal information: 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: is a sub-set of personal information that is given a higher level of protection. Sensitive information 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:

If you are a contractor (or prospective contractor) working with us to assist us to provide Services (Contractor):

your name;
your business name and entity details (including ABN or ACN);
your contact details, including email address, mailing address, street address and/or telephone number;
your age and/or date of birth (if required by a Client); and
your qualifications;

If you are a business seeking our Services (Client):

your name;
your business name and entity details (including ABN or ACN);
your contact details, including email address, mailing address, street address and/or telephone number;

If you are a Contractor or Client or user of our website:

your preferences and/or opinions;
details of services we have provided to you and/or that you have enquired about, and our response to you;
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;
information about your access and use of our Services, 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;
additional personal information that you provide to us, directly or indirectly, through your use of our Services and/or associated applications 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

Sensitive information: We do not actively request sensitive information about you. If at any time we need to collect sensitive 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.

Client data: In providing our Services to Clients, we may be given access to data that our Clients have collected. If the data contains personal or sensitive information about you, 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 through the 'contact us' form on our website or when you request our assistance via email or over the telephone or when you enter into a contract with us.
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 may collect personal information from third parties, such as from our Clients when they give us data sets so that we can provide them with our Services.

Collection and use of personal information

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

to provide our Services;
to contact and communicate with you about our Services;
for internal record keeping, administrative, invoicing and billing purposes;
for analytics, market research and business development, including to operate and improve our Services;
for advertising and marketing, including to send 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 or contractual work with us; to consider your application; and
if otherwise required or authorised by law.

Disclosure of personal information to third parties

We may disclose personal information to:

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, Jira and Xero, data storage, web-hosting and server providers, debt collectors, couriers, maintenance or problem-solving providers, marketing or advertising providers, professional advisors and payment systems operators;
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;
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 or authorised by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights; and
any other third parties as required or permitted by law, such as where we receive a subpoena.

Overseas disclosure: We store your personal information in Australia. Where we disclose your personal information to third parties listed above, these third parties may store, transfer or access personal information outside of Australia. We will only disclose your personal information overseas in accordance with the Australian Privacy Principles.

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 our ability to provide our Services to you and 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.

Restrict and unsubscribe: To object to processing for direct marketing/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 access to the personal information that we hold about you. An administrative fee may be payable for the provision of such information. Please note, in some situations, we may be legally permitted to withhold access to your personal information.

Correction: 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, out of date, incomplete, irrelevant or misleading. Please note, in some situations, we may be legally permitted to not correct your personal information.

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 privacy authority.

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.

While we are committed to security, 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.

User Generated Content

We may enable you to post reviews, comments, photos and other user-generated content. Any content you choose to submit will be accessible by anyone, including third parties not associated with us. We have no control over how others may use or misuse information you make publicly available. We are not responsible for the privacy, security or accuracy of any user-generated content you choose to post or for the use or misuse of that information by any third parties.

Cookies and Analytics

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. If and when you choose to provide our online Services with personal information, this information may be linked to the data stored in the cookie.

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.

Google Analytics: We may use Google Analytics Advertising Features. We and third-party vendors may use first-party cookies (such as the Google Analytics cookie) or other first-party identifiers, and third-party cookies (such as Google advertising cookies) or other third-party identifiers together. These cookies and identifiers may collect Technical and Usage Data about you.

You can opt-out of Google Analytics Advertising Features including using a Google Analytics Opt-out Browser add-on found here. To opt-out of personalised ad delivery on the Google content network, please visit Google's Ads Preferences Manager here or if you wish to opt-out permanently even when all cookies are deleted from your browser you can install their plugin here. To opt out of interest-based ads on mobile devices, please follow these instructions for your mobile device: On android open the Google Settings app on your device and select "ads" to control the settings. On iOS devices with iOS 6 and above use Apple's advertising identifier. To learn more about limiting ad tracking using this identifier, visit the settings menu on your device.

To find out how Google uses data when you use third party websites or applications, please see here.

Facebook/Meta Analytics: We may use tools provided by Meta, such as the Meta Pixel, advanced matching, and Conversions API. These allow us to measure ad performance and deliver ads that may be relevant to you on Meta platforms based on your activity on our website/app. You can control whether we can join data from third party partners with your Meta account for ads by adjusting your preferences within Meta's settings. You can disconnect this data from your Meta account by changing your settings for Off-Facebook activity. For more information, please see Meta's Privacy Policy here.

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.

Use of Artificial Intelligence

Overview: We may use artificial intelligence and machine learning technologies, including AI Technologies provided by third parties (AI Technologies) in our business operations and the provision of our Services. We will only use AI Technologies when legally permitted and necessary for our business operations.

How we use AI Technologies: We may use AI Technologies for the following purposes:

to conduct analysis and processing;
to generate and modify content and coding;
to improve and optimise our services and operations;
to automate certain processes and communications, such as routine tasks;
to personalise your experience with our services;
for quality assurance purposes; and
to assisting with customer support and queries.

Data Protection and Security: Where we use service providers who provide AI Technologies to us, we will take reasonable steps to ensure that such service providers handle your personal information according to privacy law, including by ensuring that we have contracts in place requiring the service provider to protect personal information.

We will not input your personal information into any platform provided by an AI Technology service provider which then trains its model based on that information.

Your Rights and our Commitments: We will treat information generated or inferred by the AI Technologies about individuals as personal information and you maintain all rights over your personal information as outlined in this privacy policy, regardless of whether AI Technologies are used in processing. When using AI Technologies with your personal information:

Transparency and control: we will inform you when AI Technologies are being used to make decisions that may significantly affect you. We will implement processes to verify the accuracy of AI-generated outputs and we will take reasonable steps to maintain human oversight and review of significant AI-generated decisions. Our staff are trained to understand the limitations of AI systems and verify outputs before they are relied upon; and
Security: we implement appropriate technical and organisational measures to ensure that our use of AI Technologies maintains the security and integrity of your personal information. This includes regular testing and monitoring of AI outputs for accuracy and reliability; and
Risk mitigation: We regularly assess and document the risks associated with our use of AI Technologies in processing personal information and implement appropriate mitigation measures. This includes ongoing monitoring of AI Technologies and regular reviews of their performance and impact.

Amendments

We may, at any time and at our discretion, vary this Privacy Policy by publishing the amended Privacy Policy on our website. We recommend you check our website regularly to ensure you are aware of our current Privacy Policy.

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

Talent First AI Pty. Ltd. ABN 97 643 400 131

Email: hello@culturate.ai

Last update: 05 November 2024

Protecting your personal information is important