1. Privacy Policy
1.1 Our commitment to your privacy
Lula Group Pty Ltd (ACN 643 772 025) ("us", "we", or "Lula") is committed to respecting and protecting your privacy. We comply with all privacy laws that apply to our business and seek to adopt the best practices for the management of your personal information.
This Privacy Policy sets out our personal information practices that ensure your privacy, including:
The types of personal information we collect and hold;
The purposes for our collection, and our use and disclosure of personal information;
Your right to access and seek correction of your personal information;
How you may complain about privacy matters to us;
1.2 What personal information do we collect and hold?
We collect and hold personal information from candidates, clients, and referees which is either consented to us receiving or that which is reasonably necessary to fulfill our activities and functions as a business.
We will only collect personal information from you directly unless it is both reasonable and fair to receive this from a secondary source such as LinkedIn.
We collect and hold the following kinds of information, but it is not limited to:
a) For candidates:
Personal details such as your name, postal and/or email addresses, telephone numbers, date of birth and gender
Enquiries such as background checks, your working rights in Australia and other relevant enquiries.
b) For clients and referees:
Contact details such as your business name, job title, addresses and phone numbers.
Records of any interactions, conversations or dealings with you.
c) For clients only:
• Confidential and private opinions and feedback regarding our candidates. d) For referees only:
• Confidential and private opinions about a candidate's suitability. Sensitive Information
From time to time, you may be required to provide us with a document that contains 'sensitive information (for example race, religion, political opinion, memberships or medical information).
This sensitive information will only be used to fulfill our obligations under any privacy rules and no other purpose. Similarly, where personal information provided to us includes a 'government identifier' (such as a license number on a driver's license), we will only use or disclose such identifiers where it is reasonably necessary to verify your identity, or as required or permitted by law.
Where possible, sensitive information will not be collected and will otherwise be deleted where practicable once any obligations under any rules have been fulfilled.
Depending on your role with us, we may collect and hold other information. For example, payment or account information that you may use when paying for our service.
1.3 How do we collect and hold your information?
We collect personal information from:
details you provide to us;
results from any enquiries we make or references we receive;
responses from a job advertisement;
investigations;
communications with us online;
note-taking;
participation in our competitions, promotions, testimonial, surveys or other
offerings;
any way involving a need for personal information to be provided such as if you bring a claim against us.
We may also collect personal information about you by using data from other sources and analysing this data together with information we already hold about you to learn more about your likely preferences and interests. When you visit our websites, social media pages or our other online presence, we may collect information about you using technology, for example, 'cookies'.
Personal information we hold is generally stored in computer systems. These may be operated by us or by our service providers. In all cases, we have rigorous information security requirements aimed at eliminating risks of unauthorised access to, and loss, misuse or wrongful alteration of, personal information.
1.4 Why we collect, use, hold and disclose your personal information
We primary collect, use and hold your personal information to facilitate our business activities in relation to our services, and to improve on the services we offer.
For example:
technical partners (providing us services such as email, web hosting, data storage and backup), email marketing companies and legal or other professional consultants, some of whom may be located outside of Australia.
to assist in investigating your complaints or enquiries.
to report any information to a relevant body when required to do so under a relevant rule.
1.5 Security and destruction of data
We take all reasonable steps to store your personal information securely. Personal information is destroyed securely when no longer required by us.
1.6 Sharing of your personal information overseas
When holding your personal information, we store our data with backup and hosting services located within Australia. In the event the services we use change so that your personal information would no longer be held in Australia we will seek your consent except where the recipient country has equivalent (or greater) privacy laws and protections to that of Australia and that would apply to your personal information.
1.7 Access and correction of your personal information
If you wish to access or have an enquiry about your personal information, or how we handle privacy matters generally, please contact us by email at Jovana@lulagroup.com.au
We may require proof of identity before giving you access to your personal information. We may charge a reasonable fee for giving access to your personal information if your request requires substantial effort on our part.
Should you need to correct any personal information please contact us by email above.
1.8 Complaints
If you wish to complain about the privacy rules that bind us, please contact us in writing using the above details. We may request further details from you so we may adequately understand or address your concerns. We may also discuss your complaint with our staff, our service providers or our professional advisors as appropriate.
We will investigate the matter and attempt to resolve it in a timely way. We will inform you in writing about the outcome of the investigation. If we do not resolve your complaint to your satisfaction and no other complaint resolution procedures are agreed or required by law, we will inform you that your complaint may be referred to the Privacy Commissioner for further investigation and will provide you with the Commissioner’s contact details.
1.9 Updates
This privacy policy is current at the date below. We may change it periodically and provide notice of the changes on our website: www.lulagroup.com.au
1.10 Other privacy terms and limits of this policy
Depending on your dealings with us, there may be additional privacy notices and terms relevant to you. Such additional terms are contained within our various contractual documents, such as our terms of business.
1.11 More information
This Privacy Policy is consistent with the Australian Privacy Principles (APPs) as set out in the
Privacy Act 1988 (Cth).
More information about privacy law and privacy principles is available from the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au.
Last update of this policy: September 2020. 237720395v1_GEM
