AVEC GLOBAL AUSTRALIA AND NEW ZEALAND - PRIVACY POLICY

This Privacy Policy applies to Talent International Holdings Pty Ltd and all references to “Talent International”, “Talent”, “we”, “us”, or “our” in this document are references to Talent International Holdings Pty Ltd, its related subsidiaries (including, without limitation, AVEC Global Pty Ltd, Scale by Avec, RISE by Talent and Solve by Talent) and all digital platforms used by or operated for Talent.

In this Privacy Policy headings are for convenience only and do not affect interpretation. Unless the context requires otherwise, the singular includes the plural and vice versa and a gender includes all genders.

Protecting your privacy is important

Talent International understands that your personal information is important to you and is committed to protecting your privacy. Talent International is guided by the Australian Privacy Principles (APPs) outlined in the Australian Privacy Act 1988 (Cth), the New Zealand Privacy Act 2020 and other applicable laws governing privacy. This Privacy Policy complies with the Australian Privacy Principles and the New Zealand Information Privacy Principles (IPPs).

The APP’s are contained in Schedule 1 of the Privacy Act 1988 (Cth). The APP’s are available from the Office of the Australian Information Commissioner (OAIC) website.

The IPP’s are contained in Part 3 of the Privacy Act 2020. The IPP’s are available from the New Zealand Office of the Privacy Commissioner (OPC) website.

This Privacy Policy sets out the approaches that Talent International adopts and follows when handling personal information that is disclosed, collected or otherwise handled in connection with:

• any Talent website or any other digital platform used by or operated for Talent;
• our prospective and current clients;
• our third party suppliers;
• individuals who apply for a contract or permanent positions with Talent International; and
• individuals who use the services of Talent International (including all beneficiaries of the Talent RISE charity (https://talentrise.org/)).

If you have objections to this Privacy Policy you should not access or use our website and you should not send your resume or any other personal information to Talent International.

Information we collect about you

Talent International generally collects some or all of the following personal information and other information about you when you access any Talent website or any other digital platform used by or operated for Talent, submit a resume for our consideration, when you are in contact with a Talent International representative, or when you use any of our services:

• your name including any use of a pseudonym;
• your personal details (such as age, gender, etc.);
• your address and contact details;
• your employment history;
• information about personality, character, skills, qualifications and experience;
• information about career path and preferences;
• your bank account details and Tax File Number;
• referee opinions;
• interview opinions;
• forms of sensitive information (such as health information, criminal record, racial or ethnic origin, etc.) including as may be required to undertake, or obtained from, medical checks and criminal history checks;
• information required to ascertain your right to work in a particular jurisdiction;
• other information that you have supplied to any Talent website or any other digital platform used by or operated for Talent, any information you have supplied on your resume, any information relevant to proof of identity or other information provided in communications with a Talent International representative; and
• technical information relating to your access of any Talent website or any other digital platform used by or operated for Talent, and which may include the Internet protocol (IP) address used to connect your computer to the Internet, your login information if applicable, browser type and version, browser plug-in types and versions, information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), pages you viewed or pages/services searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs) and methods used to browse away from the page.

You may choose not to provide us with your personal information or act under a pseudonym. However, this will severely restrict our ability to provide you with our services in seeking and being placed into work (or providing you with any of our charitable services through Talent RISE) and Talent may not be able to provide its services to you as a result.

Some personal information that we collect and hold about you may be sensitive information. When used in this Privacy Policy, the term “sensitive information” includes membership of a profession or trade association, health information (including medical check results), whether you have a criminal record (including associated check results), racial or ethnic origin, sexual orientation and the like. We may need to collect, hold, use and disclose sensitive information about you in relation to the specific requirements of your placement with our clients or your direct engagement by us or to provide you with services. We may also collect certain sensitive information from you on an anonymous, de-identified basis in relation to our monitoring of diversity metrics. If we do, we will get your specific consent to the collection, holding, use and disclosure of this information at the time the information is collected.

How we obtain your personal information

We obtain most of your personal information directly from you, for example:

• when you access any Talent website or any other digital platform used by or operated for Talent;
• when you submit your resume to us;
• when you complete one of our registration forms or surveys, or provide any other information in connection with your application; and
• each time you communicate with a Talent International representative (by phone, fax, email or in person).

To verify your identity, we may request proof of identification from you including copies of your passport, visa, driver’s license or any other relevant licenses and will only do so for the performance of our activities or functions as a recruitment agency.

We also collect some of your personal information or other information from third parties including:

• reference checks with referees;
• information from former colleagues or candidates or a prospective member of staff that has nominated you as one of their referees;
• publicly available sources including newspapers, journals, directories, the Internet and social media sites;
• results of any competency or background checks including credit and criminal record checks;
• health information, including health information obtained from the results of medical checks and from medical records provided to us by you or by a third party medical practitioner having authority to do so;
• for beneficiaries of the Talent RISE charity, receiving information from other third-party organisations that refer you to the Talent RISE program;
• receiving any complaint or other information from or about you in the workplace;
• receiving any information about any insurance investigation, litigation, registration or professional disciplinary matter, criminal matter, inquest or inquiry in which you were involved;
• receiving any information about a workplace accident in which you are involved; and
• networking with your peers.

This information will be included in our records only to the extent necessary for the performance of our usual activities or functions.

In addition, Talent International may occasionally be required by law to collect, use and disclose your personal information, for example in order to comply with the requirements of government departments for business data.

Purposes of collecting, holding, using and disclosing your personal information

Talent International collects personal information about you to carry out its business functions, provide our services to you and fulfil its obligations to you, including (where applicable) in relation to:

• determining if you are suitable for a position;
• contacting you if a position becomes available that in which you may be interested;
• submitting your details to a client for a potential position;
• notifying clients of your skills and other attributes, and availability for any future positions;
• administration of payments to you, which may include the processing of sensitive information about you (e.g. sick leave);
• carrying out our obligations arising from any contracts we intend to enter into or have entered into between you and us and to provide you with the information, products and services that you request from us or we think will be of interest to you because it is relevant to your career or to your organisation;
• providing you with information about other goods and services we offer that are similar to those that you have already purchased, been provided with or enquired about;
• any additional services which we provide our candidates and clients, including supporting individuals and companies throughout their career, supporting businesses’ resourcing needs and strategies;
• where applicable, providing you with the services of the Talent RISE charity;
• to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical, survey purposes and competitions;
• to improve our site to ensure that content is presented in the most effective manner for you and for your computer;
• to allow you to participate in interactive features of our service, when you choose to do so; and
• as part of our efforts to keep our site safe and secure.

If you have been nominated by a former colleague or candidate or a prospective member of staff as one of their referees, we use your data to contact you for a reference. This is a part of our quality assurance procedure, and so we deem this to be necessary for our legitimate interests as an organisation offering recruitment services and employing people ourselves.

Use and disclosure of your personal information

Your personal information may be disclosed to:

• prospective employers or entities seeking to fulfil contract positions (this may also include your buy rate if Talent International is operating under a preferred supplier agreement);
• prospective candidates for the purpose of arranging interviews and engagements;
• subcontractors required for us to provide the services to you, including technology partners, email specialists, event organisers, payment and other financial service institutions;
• staff of the departments responsible for administering the processes described above;
• related bodies corporate and third parties for the administration and provision of selected benefits and services (eg: background checking/screening, software solutions providers, training and superannuation); and
• providers of web analytics services, search engine, marketing automation platforms and social media services to assist us in the improvement and optimisation of Talent websites and any other digital platforms used by or operated for Talent.

Your personal information may be transferred overseas, for the purposes and processes described above (for example, submitting your resume for an international position).

The list of countries where your personal information may be sent to & stored can be found here.

We may also disclose certain de-identified information about you to clients and potential clients for the purpose of promoting and advertising the diversity of our candidates. Such information only disclosed on an anonymised, aggregated and secure basis. The kinds of anonymised diversity metrics which may be included in such disclosures include racial or ethnic origin, gender identity, sexual orientation and disability. We will only collect, use and disclose such information with your prior written consent.

Direct marketing

We may provide you with electronic marketing messages from time to time. You may opt out of receiving electronic messages from us at any time by contacting the Privacy Inquiry Service as set out below opt out mechanism included in our electronic marketing messages.

How to access, correct or update your personal information

Talent International relies on the accuracy of the personal information you provide to us.

To the extent authorised by privacy legislation and other applicable laws, you can access and amend your personal information held by Talent International.

If you wish to request access to, find out more about or seek amendment of your personal information held by Talent International, you should contact the Privacy Inquiry Service (contact details below).

Security of your personal information

We generally hold personal information in electronic format, which we store either within our own internal systems and applications or using third party data processors and data storage providers.

We may otherwise hold your personal information in hard copy form which is stored in our offices.

Talent International will take reasonable steps to ensure that we hold your personal information in a secure environment accessed only by authorised persons for approved business purposes.

However, no data transmission across the internet can be guaranteed to be 100% secure. While we strive to protect your personal information from misuse, loss and unauthorised access, we cannot guarantee the security of any information you transmit to us or receive from us across the internet. These activities are conducted at your own risk. Once we receive your transmission, we make our best effort to ensure its security.

Retention of your personal information

We may be subject to legal and regulatory requirements in relation to the retention of information collected under this Privacy Policy. Subject to these requirements, we will only retain your personal information for such a period as reasonably necessary or as otherwise permitted by applicable law.

Privacy Inquiry Service

Please contact the Privacy Inquiry Service (privacyinquiryservice@talentinternational.com) if you wish to:

• obtain a copy of this Privacy Policy;
• request access to, find out more about or seek amendment of your personal information held by Talent International;
• inquire generally about your privacy rights and obligations;
• opting-out of receiving any direct marketing from us;
• provide suggestions or feedback in respect Talent International’s handling of personal information; or
• make a complaint in relation to Talent International’s handling of your personal information.

Alternatively, you may contact Talent International’s APAC Head Office at +61 2 9223 9855 for further information.

Complaints

We take your privacy concerns seriously. If you have a complaint regarding our handling of your personal information or concerning our privacy practices, you may file a complaint with our Privacy Inquiry Service as set out above. We will confirm receipt of your complaint and, if necessary, will open an investigation into your complaint. We may need to contact you to request further details of your complaint. If an investigation has been opened following a complaint made by you, we will contact you with the result of that complaint as soon as possible.

In the unlikely circumstances we are unable to resolve your complaint to your satisfaction, you may refer your complaint to the relevant authority in your jurisdiction.

If you are located in Australia

Office of the Australian Information Commissioner) at the contact details below:

• Address: GPO Box 5288, Sydney NSW 2001
• Phone: 1300 363 992
• Website: oaic.gov.au

If you are located in New Zealand

Office of the New Zealand Privacy Commissioner at the contact details below:

• Address: PO Box 10 094, Wellington 6143.
• Phone: 0800 803 909 (Monday to Friday, 10:00 am to 3:00 pm)
• Website: https://www.privacy.org.nz/

Cookies

A cookie is a small string of information that the website you visit transfers to your computer for identification purposes. Cookies can be used to follow your activity on the website and that information helps us to understand your preferences and improve your website experience. Cookies are also used for such activities as remembering your user name and password, if you use such a feature on this site.

You can turn off all cookies, in case you prefer not to receive them. You can also have your computer warn you whenever cookies are being used. For both options you have to adjust your browser settings (such as Chrome, Safari, Firefox, Internet Explorer, or other browser). There are also software products available that can manage cookies for you. Please be aware, however, that when you choose to reject cookies, this choice may limit the functionality of the website you visit, and you may lose access to some of its features.

Consent

By providing us with personal information, you consent to the collection, use and disclosure of your personal information as contemplated by this Privacy Policy.

Changes to this Privacy Policy

Talent International may vary this Privacy Policy from time to time. The most current version of this Privacy Policy will be published at www.talentinternational.com. We encourage you to check these documents regularly. We will not separately notify you of changes to them.

TALENT INTERNATIONAL USA - PRIVACY POLICY

Talent International CA, Inc. (referred to herein as “Talent”, “Company,” “us,” or “we”) is an affiliate of Talent International Holdings Pty. Ltd. and member of the Talent group of companies. Talent respects the privacy rights of its customers, contractors and visitors to its website (“website” or “site”). Talent has therefore established this privacy policy (“Privacy Policy”) with the intent to comply with all applicable laws and regulations that address privacy rights in the places where Talent operates its business.

This Privacy Policy is an agreement between us and you, as our customer, contractor or other user of the website (“you”).

This Privacy Policy tells you what information we collect from you, how we use it, how you can review or change the personal information you provided to us, how we may change this Privacy Policy, and the steps we take to ensure that your personal information is protected.

AGREEMENT TO TERMS OF PRIVACY POLICY AND TERMS OF USE.

All activities in which you may engage on the website are voluntary. You are not required to provide any personal information to us unless you choose to access features on this site which require the information. If you do not agree with the terms of this policy or other terms of use on this website, then you should immediately exit this website and discontinue using the site. If you do not agree with the terms of our Privacy Policy and any terms of use posted on the website, please do not use the website and do not provide us with personal information. Any posted terms of use of this website are expressly incorporated herein by reference and made a part of this policy. By using the Talent website, you signify that you agree to the terms of this Privacy Policy as well as to our terms of use.

UPDATES AND CHANGES TO THE POLICY.

This Privacy Policy will remain in effect except with respect to any of its provisions that are changed in the future, in which case the changes will become effective on the date they are posted on the website or we otherwise notify you of the changes. We reserve the right to change this Privacy Policy at any time. Changes, modifications, additions, or deletions will be effective immediately on their posting to this site. You should check this Privacy Policy periodically as its terms may change from time to time. Your continued use of the site after we post any such modifications will constitute your acknowledgment of the modified policy and your agreement to abide and be bound by the modified policy. We will also revise the “last updated” date found at the beginning of this Privacy Policy when we post changes to it.

WHAT WE ARE NOT RESPONSIBLE FOR.

This Privacy Policy does not extend to anything that is inherent in the operation of the Internet, and therefore beyond Talent’s control. This Privacy Policy is always subject to applicable law or governmental regulations. This Privacy Policy applies to information collected through this site and does not apply to any information we may collect from you in any place other than this website unless expressly provided.

TYPES OF INFORMATION WE MAY COLLECT.

Personal Information. We are a recruitment agency and recruitment business. We also provide the following other services, outsourcing and consultancy. In order to provide these services to you and to our customers, we may ask you for certain information referred to on this site as “personal information,” which includes information that pertains to your identity. Such information may include, but is not limited to, items such as:

your name, address, date of birth, age, gender, e-mail address, telephone number, social security number, credit card or debit card number. private and corporate e-mail address and phone number, financial information, compliance documentation and references verifying your qualifications and experience and your right to work, curriculum vitae, and government identification information.

You may be required to provide personal information to access or use certain parts of our website or features of the site. If you do not provide the requested personal information, you may not be able to access or use the features of the site where such information is requested.

There may be other instances in which we collect information from you that is more general in nature (“general information”). Such information may include your Internet Protocol (IP) address, which enables us to identify your computer or device on a Transmission Control Protocol/Internet Protocol (TCP/IP) network, which includes the World Wide Web. Your computer has an IP address, which is required in order for you to communicate with others via the Internet. Such general information, including the click stream data and cookies, as mentioned below, may be collected from you whenever you access the site, whether or not you provide us with any other personal information.

A set of website features may be accessible from web-enabled mobile devices. The intent is to provide screens that are optimized for the size of the screen and operating systems. On some devices, functionality may be limited. If you access this website through a mobile device, then we may collect information about your mobile device whether or not you provide us with any other personal information.

Please note that Talent does not sell your personal information. All information that you provide to us is used solely for the purpose of providing our services to our customers and to contractors.

How do we collect personal information?

Information you give to us.

This is information about you that you give us by filling in forms on the website or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register to use our site, to enter our database, subscribe to our services, attend our events, participate in discussion boards or other social media functions on our site, enter a competition, promotion or survey, networking events or referrals and when you report a problem with our site.

The information you give us or we collect about you may include your name, address, private and corporate e-mail address and phone number, or financial information, compliance documentation and references verifying your qualifications and experience and your right to work, curriculum vitae and ID, links to your professional profiles available in the public domain e.g. LinkedIn, Twitter, Facebook or links to your professional profiles on the public domain.

Information we collect about you when you visit our website.

With regard to each of your visits to our site we will automatically collect the following information:

Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information if applicable, browser type and version, browser plug-in types and versions, information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs) and methods used to browse away from the page.

Information we obtain from other sources.

This is information we obtain about you from other sources such as LinkedIn, corporate websites, job board, websites, online CV libraries, your business card, personal recommendations, network events, candidate interviews and legitimate conversations.

Click Stream Data

When you visit our website, we may also collect “click stream data” (server address, domain name). This information can be combined with information you have provided to us by registering, for example, which will enable us to analyze and better customize your visits. We may use click stream data for traffic analysis or e-commerce analysis of our website, to determine which features of our site are most or least effective or useful to you.

Cookies

We may also use cookies to gather information about your visits to our website and enhance your experience. More information on how we use cookies is available in Section 11.

From whom do we collect personal information?

We collect the personal information of the following types of people to allow us to undertake our business:

• Prospective and placed candidates for permanent, interim, temporary, contract, fixed term roles;
• Prospective, established and current client contacts;
• Suppliers that support our services;
• Consultants, Employees, temporary workers.

How We Respond to “Do Not Track” Disclosures

We are strongly committed to not sharing personal information with third parties. Under this Privacy Policy, we may share your information only under particular situations, as described in this Privacy Policy. Because we protect all users in this manner, we do not change our behavior in response to a web browser’s “do not track” signal.

Use of Social Media Tools

If this website allows you to use your social media accounts to pre-populate certain fields and you choose to use this feature, you are allowing us to access your personal information. We encourage you to review this Privacy Policy and any terms and conditions for the social media platform you select.

GENERAL INFORMATION ABOUT YOU

We will primarily use the personal information you provide and any general information we receive from you to provide products and services to you. We may also send you communications and marketing materials as follows:

A. To send you information or materials via e-mail about products, offers, and news we think might interest you. This information may relate to products, offers, and news of Talent or its licensees or selected commercial partners. If you no longer wish to receive any e-mails from us, or if you want to modify your personal data or want your personal data to be deleted from our database, see Section 12.

B. To analyze visits to the website and learn about the interests of our visitors in aggregate and also on a personal level to better understand your interests and needs, so we can improve our products and services and deliver to you the type of content, features, and promotions that you are most interested in.

PROTECTION OF YOUR PERSONAL INFORMATION AND GENERAL INFORMATION

Security Measures

In order to protect both the personal information and the general information that we receive from you through our website, we have implemented industry standard security measures.

Risk of Interception.

Please be aware that whenever you give out personal information online there is a risk that third parties may intercept and use that information. While Talent strives to protect your personal information and privacy, we cannot guarantee the security of any information you disclose online. By using this site, you expressly acknowledge and agree that we do not guarantee the security of any data provided to or received by us through this site and that any personal information, general information, or other data or information received from you through the site is provided to us at your own risk, which you expressly assume.

Release of Information.

Talent will release personal or general information without your consent for security purposes, when required by law, or to prevent imminent harm to any person or entity. We will disclose personal or general information upon receipt of a court order or subpoena, or to cooperate with a law enforcement investigation, which may include responding to requests and court orders from jurisdictions outside the United States. We fully cooperate with law enforcement agencies in identifying those who use our services for illegal activities. We reserve the right to report to law enforcement agencies any activities that we in good faith believe to be unlawful, as determined in our sole discretion. Release of your personal data for security purposes, as described in this agreement to any person or entity under any circumstances shall be based on a determination made solely by us, exercising our own discretion, permission for which is expressly granted by you to us in accordance with this Privacy Policy.

NO USE OF THIS SITE BY PERSONS UNDER 18 PERMITTED

Registration Declined

Talent intends only persons who are 18 years or older to use this website. Personal registration information submitted by a person under the age of 18 will not be accepted. Any general information provided by a person under the age of 18 and gathered (for example, through the use of cookies) during his or her visit may be used as indicated in this Privacy Policy (see Section 6). Talent is committed to protecting the privacy of children and has no intention of collecting personal data from children under the age of 18. We encourage parents and guardians of children under 18 to regularly check and monitor their children’s use of e-mail and other activities online.

Notice Concerning Children

PLEASE NOTE: We are a general audience site, and do not direct any of our content specifically at children under 13 years of age. We understand and are committed to respecting the sensitive nature of children’s privacy online. If we learn or have reason to suspect that a site user is under age 13, we will promptly delete any personal information in that user’s account.

WHO MAY ACCESS YOUR INFORMATION.

Talent employees and third-party service partners:

Other than Talent employees from the companies belonging to the Talent group for the purposes set out above, and except as described in this Privacy Policy, we do not sell, trade, or otherwise transfer your personal information or general information to third parties without informing you in advance. We provide some of our services through contractual arrangements with affiliates, services providers, partners and other third parties (collectively, “service partners”). Our service partners may use your personal information to operate our sites and to deliver their services. For example, your data may be transferred to website hosting partners and other parties who assist us in designing and operating the website, executing services, or helping us analyze collected data. These parties will only use your data for the purpose of carrying out the work as agreed with us and will be required to keep the information confidential. We will encourage our service partners to adopt and post privacy policies. However, the use of your personal information by our service partners is governed by the privacy policies of those service partners and is not subject to our control.

We will share your personal information with:

(1) Any member of the Talent group including members outside of the United States.

Categories of Data Shared or Disclosed with Third Parties:

We are working closely with third parties including companies within our Group, business partners, sub-contractors in technical, professional, payment and other services, advertising networks, analytics providers, search information providers, credit reference agencies, professional advisors and our CRM partner, Bullhorn. We may receive information about you from them for the purposes of our recruitment services and ancillary support services, AVEC, Talent Unleashed and Talent Rise:

• Clients for the purpose of introducing candidates to them;
• Candidates for the purpose of arranging interviews and engagements;
• Clients, business partners, suppliers, sub-contractors and related business units of Talent Group, for the performance and compliance obligations of any contract we enter into with them or you;
• Subcontractors including email marketing specialists, event organizers, payment and other financial service providers;
• Advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We do not disclose information about identifiable individuals to our advertisers, but we will provide them with aggregate information about our users. We may also use such aggregate information to help advertisers reach the kind of audience they want to target. We may make use of the personal data we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience;
• Analytics and search engine providers that assist us in the improvement and optimization of our site; and
• Credit reference agencies, our insurance broker, compliance partners and other sub- contractors for the purpose of assessing your suitability for a role where this is a condition of us entering into a contract with you.

Links to Third Parties

For your convenience and to improve usage of the website we may insert links to third parties on this site. This Privacy Policy does not apply to such third-party websites. These links take you outside our service and off Talent’s site and are beyond our control. This includes links from partners that may use Talent’s logos as part of a co-branding agreement. The sites those links can take you to have their own separate Privacy Policy and although we seek to protect the integrity of our site, Talent is not liable for the content and activities of those sites. Your visits and access to such websites is at your own risk. Please note that those other sites may send their own cookies to users, collect data, or solicit personal information.

AUTOMATIC COLLECTION

COOKIES. A cookie is a small string of information that the website you visit transfers to your computer for identification purposes. Cookies can be used to follow your activity on the website and that information helps us to understand your preferences and improve your website experience. Cookies are also used for such activities as remembering your user name and password, if you use such a feature on this site. You can turn off all cookies, in case you prefer not to receive them. You can also have your computer warn you whenever cookies are being used. For both options you have to adjust your browser settings (such as Chrome, Safari, Firefox, Internet Explorer, or other browser). There are also software products available that can manage cookies for you. Please be aware, however, that when you choose to reject cookies, this choice may limit the functionality of the website you visit, and you may lose access to some of its features.

DELETING OR MODIFYING PERSONAL INFORMATION

CHANGING YOUR INFORMATION. You may cancel your registration at any time, and you may opt out of receiving any e-mails from Talent. We encourage you promptly to update your contact and personal information when it changes.

QUESTIONS OR COMMENTS

CONTACT INFORMATION (Talent USA). If you have any questions or comments relating to our website or the Privacy Policy, send an email to privacyinquiryservice@talentinternational.com.