Humanforce encourages being data privacy aware.

We at Humanforce (Humanforce Holdings Pty Ltd and its affiliates) respect your privacy and are committed to protecting your personal data. We take our obligations regarding the collection and processing of your personal data seriously. This Privacy Notice is intended to inform you about the conditions in which we collect, use, store, share, transmit, transfer, delete or otherwise process (collectively, “Process”) information relating to you (your “Personal Data”). In this Humanforce Privacy Notice we describe the measures we take to ensure the protection of your Personal Data. Importantly, we inform you about your rights and tell you how you can reach us to ask any questions you may have about this Privacy Notice and your Personal Data.

At Humanforce, we are committed to complying with all applicable legislation relating to Personal Data, including the European Union’s General Data Protection Regulation (“GDPR”), the Australian Privacy Act 1988 (Cth), the New Zealand Privacy Act 2020 and any other applicable local law.

In this Privacy Notice, “you” and “your” means any covered individual. “We”, “us”, “our” and “Humanforce” means the global organisation of Humanforce entities.

What this Privacy Notice covers

This Privacy Notice applies to Humanforce across our global organisation and in all geographies where we operate.

This Notice applies to the collection and Processing by Humanforce, as controller of the Personal Data of: our applicants, employees of our customers or prospective customers, employees of our suppliers/vendors, our contractors/subcontractors and visitors to our websites.

This Privacy Notice does not apply when we provide Humanforce services as processor on behalf of our customers. If you wish to obtain information relating to the use by or on behalf of any of our customers, please contact the customer directly.

The Personal Data we collect from you may include:

• your contact information (name, company name, title, phone, email, address),
• your identifiers (username and password),
• your education, professional or employment-related information (CV, background and performance-related information),
• your financial account information (billing name and address, credit card number or bank account information),
• your commercial information, 
• your internet activity information (Internet Protocol (IP) addresses or other identifiers); and
• any information supplied by you during or in connection with your use of the platform.

We collect such information when:

• you request (or express an interest in receiving) information about our services; 
• you use our “Contact Us” or similar features or download certain content on our websites;
• you request customer support;
• you register for an event, webinar or training;
• you attend an event (where we may, with your further consent, scan your attendee badge);
• you visit our websites,
• you communicate with us via phone or email;
• you use our services (in which case we automatically collect information about your device and your usage of our services through log files and other technologies, some of which may qualify as Personal Data – please see the “What device and usage data we process” section, below);
• you visit one of our offices and you are requested to register as a visitor;
• you apply for a job at Humanforce.

We also collect information about you from other sources including our business partners, third parties from whom we purchase Personal Data and from publicly available information.  The Personal Data we collect from these sources includes your business contact information, including mailing addresses, job titles, email addresses, phone numbers, IP addresses, social media profiles, LinkedIn URLs and custom profiles, for purposes of targeted advertising, delivering relevant email content and event promotion.

We only collect or process Your Personal Data where we have a lawful reason to do so, as follows:

• to contact you and communicate with you;
• to provide you with information about our services (based on your consent or our legitimate interest);
• to provision our services, fulfil your orders and manage the billing of our services (based on the performance of a contract with you or our legitimate interest);
• to plan and manage your registration, access and participation to marketing and training events (based on your consent or our legitimate interest);
• to promote and market our services, send you marketing communications in accordance with any applicable legal requirements (based on your consent or our legitimate interest);
• to improve our services and your experience using our services and navigating our websites (based on our legitimate interest);
• to secure our services and websites, including to diagnose website technical problems, to prevent, detect, investigate, mitigate and fix potential security issues and fraudulent or illegal access or activities (based on our legitimate interest);
• to respond to a court or a regulator order or a public authority request and defend our rights in court (based on a legal obligation);
• to review our application and manage our recruitment process (based on our legitimate interest).

When you have given your consent to the processing of your Personal Data, you can withdraw your consent at any time, which will not affect the lawfulness of the processing before your consent was withdrawn. If you would like to withdraw your consent, you can do so by mailing privacy@humanforce.com.

How long we store your Personal Data

We only retain your Personal Data for as long as reasonable and necessary for the purposes we collected it or as long as required to satisfy any legal, accounting or reporting requirements. To determine the appropriate retention period for your Personal Data we take into account the amount, nature, and sensitivity of the Personal Data being processed, the potential risk of harm from unauthorised use or disclosure of the Personal Data, whether the purposes of the processing can be achieved in another way and the applicable legal requirements (such as applicable statutes of limitation).

Upon expiry of the applicable retention period, we will securely destroy your Personal Data in accordance with applicable laws and regulations.

How we secure your Personal Data

Your Personal Data is securely stored on Amazon Web Services (AWS) servers in Australia and Dublin, Ireland.  We use appropriate technical and organisational measures to protect your Personal Data against accidental or unlawful alteration or loss and deploy security measures both digitally and physically to deter unauthorised use, disclosure or access.
We work to ensure appropriate and reasonable measures are deployed based on Privacy by Design and Privacy by Default principles, to safeguard and protect the processing of your Personal Data.

How we disclose your Personal Data

We share your Personal Data, in the following circumstances:

• To related Humanforce entities for the purposes described in this Privacy Notice;
• With third parties we have engaged in connection with the purposes described in this Privacy Notice and/or our services;
• With entities as required for the prevention of money laundering fraud and crime. Including financial institutions, tax authorities and regulatory bodies;
• With courts, law enforcement authorities, regulators, government officials or attorneys or other parties where it is reasonably necessary for the establishment, exercise, or defence of a legal or equitable claim, or for the purposes of a confidential alternative dispute resolution process;
• With service providers who we engage, including shared service centres, to process your Personal Data for any of the purposes listed above on our behalf and in accordance with our instructions only;
• In the event of purchase or sale of any company, business or assets, in which case we may disclose your Personal Data to a prospective purchaser, subject to appropriate obligations of confidentiality.

How we transfer your Personal Data internationally

Humanforce operates globally and we may transfer, store or process your Personal Data in a country that is not yours, including countries outside the European Economic Area (“EEA”) or United Kingdom. We have taken appropriate safeguards to ensure your Personal Data and your rights are protected in compliance with applicable data protection laws. In particular, if we transfer your Personal Data from the EEA or the UK to a country not recognized to provide adequate protection, such as the United States or, we enter into EU/UK standard contractual clauses with the data importer or implement any alternative mechanism as approved by the European Commission or other applicable regulator.

For further information, please contact us at privacy@humanforce.com.

Cookies, use and management

We use “cookies” on our website. “Cookies” are portions of text that are placed on your computer’s hard drive when you visit certain websites. We may use cookies to tell us, for example, whether you have visited us before or if you are a new visitor and to help us identify features in which you may have the greatest interest. Cookies may enhance your online experience by saving your preferences while you are visiting a website.
We will let you know when you visit our websites what types of cookies we use and how to disable such cookies. Where required by law, you will have the ability to visit our websites and refuse the use of cookies at any time on your computer. You can accept or manage your preferences as a first action on visiting the website, or via your browser settings, but removal of some cookies may affect the performance of some website features.

What your rights are

Humanforce supports and commits to ensuring the protection of your rights under applicable laws, which may include (depending on the jurisdiction in which you are located):

• Your right to access and correct data.

You can request a copy of the Personal Data we hold about you. You may also request rectification of inaccurate Personal Data, or to have incomplete Personal Data completed.

• Your right to be forgotten.

Your right to be forgotten entitles you to request the erasure of your Personal Data in cases where:
(i) the data is no longer necessary for the purpose for which it was collected;
(ii) you choose to withdraw your consent;
(iii) you object to the processing of your Personal Data;
(iv) your Personal Data has been unlawfully processed;
(v) there is a legal obligation to erase your Personal Data;
(vi) erasure is required to ensure compliance with applicable laws.

• Right to restriction of processing.

You may request that processing of your Personal Data be restricted in the cases where:
(i) you contest the accuracy of your Personal Data;
(ii) Humanforce no longer needs your Personal Data for the purposes of the processing;
(iii) you have objected to processing for legitimate reasons.

• Right to data portability.

You can request, where applicable, the portability of your Personal Data that you have provided to Humanforce. We will do this in a commonly used, and machine-readable format. You have the right to transmit this data to an alternative Controller where:
(i) the processing of your Personal Data is based on consent or on a contract; and
(ii) the processing is carried out by automated means.
You can also request that your Personal Data be transmitted to a third party of your choice (where technically feasible).

• Right to object to processing.

You may object (i.e. exercise your right to “opt-out”) to the processing of your Personal Data, particularly in relation to profiling.

• Right not to be subject to automated decisions.

You have the right not to be subject to a decision based solely on automated processing, including profiling, which has a legal impact for you or significantly affects you. We do not implement automated decision-making methods.

• Right to withdraw your consent at any time.

When the processing of your Personal Data is based on consent, you can withdraw it. This does not affect the lawfulness of the processing based on such consent before consent is withdrawn.

In the event you wish to exercise any of the rights listed above, please:

1. Send an email request to privacy@humanforce.com;
2. Contact our DPO at the address below; or
3. Send an email request to our EU Representative via humanforce@datarep.com.

We will aim to respond to your request within the time limits imposed by applicable law. We typically do not charge a fee for you to access your Personal Data but may charge a reasonable fee for providing such access if your request is clearly unfounded, repetitive or excessive for us to respond to. We may also need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to a person who has no right to receive it.

Data collection and privacy of minors

We do not collect and process Personal Data of any child without the consent of the guardian where required. In particular, we do not promote or market our services to children. If you believe that we have mistakenly collected a child’s Personal Data, please notify us using the contact details provided below.

If you are a California Resident

We do not sell Personal Data. We may share the following categories of Personal Data with third party business partners and service providers with whom we have entered into contracts:

• Contact information;
• Commercial information;
• Internet activity information;
• Financial information;
• Education, professional and employment-related information.

For information on how to exercise your rights under the California Consumer Privacy Act, including the right to access specific types of Personal Data, to learn how we process Personal Data, to request deletion of your Personal Data and not to be denied goods or services for exercising these rights, please refer to the above “What Your Rights Are” Section.

Keeping this Privacy Notice up to date

We may update this Privacy Notice as required over time to reflect business changes or changing legal requirements by publishing a new version on our website. If we make any significant changes to this Privacy Notice, we will make reference to the change on our website stating when any changes are made. You are invited to check this page occasionally to ensure you are happy with any updates to it.

Privacy notices of other websites 

Our website may contain links to, or may interface with, other websites. Our Privacy Notice applies only to our website. If you click a link to another website, you should refer to the third-party website’s privacy notice or policy.

How to contact us or the appropriate authority

To exercise your rights as described above or if you have any questions regarding this Privacy Notice or our privacy practices, please contact us via any of the following methods:

Humanforce

Email: privacy@humanforce.com

By mail to our Australian address:
Level 14, 90 Arthur Street
North Sydney, NSW, 2060
Australia
Attn: Privacy Officer

By mail to our UK address:
Union House
182-194 Union Street
London SE1 0LH
United Kingdom
Attn: Privacy Officer

Our EU Data Protection Representative

Humanforce has appointed DataRep as its Data Protection Representative in the European Union for the purposes of the GDPR. You may contact DataRep either by sending an email to humanforce@datarep.com or by posting your query to DataRep at their address in your country, as listed here.

Our Data Protection Officer

HewardMills Ltd
77 Farringdon Road
London
EC1M 3JU
United Kingdom

Email: dpo@hewardmills.com

Under data protection laws you may lodge a complaint with a data protection supervisory authority in the country of your residence, your place of work or the place of the alleged infringement.

Last update: 20 September 2023.