Privacy Policy
Purpose and scope
Elula Group Pty Ltd (ACN 618 864 976) and any associated entities (Elula) recognises the importance of your privacy. This Privacy Policy applies to all individuals interacting with Elula excluding clients and employees, and explains how Elula intends to collect, store, use, disclose, protect and otherwise handle your Personal Information having regard to the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth) (Privacy Act).
This Privacy Policy does not constitute a contractual representation, promise, guarantee or warranty by Elula to you as to the manner in which Elula will or may collect, store, use, disclose, protect or otherwise handle your Personal Information.
Some matters are beyond the control of Elula, such as third party malicious or criminal attacks.
What is Personal Information?
Personal Information is information or an opinion about an individual, whether true or not and whether recorded in a material form or not, from which an individual can be reasonably identified.
Some information may not be Personal Information when considered on its own. However, when combined with other information held by (or accessible) to Elula, it may become Personal Information.
Why does Elula collect Personal Information?
Elula collects Personal Information for three main purposes:
a) to review, select, and engage with job applicants and candidates
b) to understand the profile of our website visitors, to provide a better user experience, and to analyse and track data to determine the popularity of certain content
c) conducting and maintaining business relationships with suppliers, service providers, and prospective clients.
For (a), Elula may obtain Personal Information either directly from you as job applicants, or from third parties, for the purpose of job recruitment. If Elula does not collect your Personal Information, it may not be able to review your job application.
For (b), Elula may also collect information based on how you use its website, including through ‘cookies’, web beacons and other similar technologies.
For (c), Elula may collect your personal information if you engage with Elula as a supplier, service provider, prospective client or if you visit the office.
What Personal Information does Elula collect?
During the recruitment process, we will collect information about you – either from you directly or from third parties – which may include the following:
a) contact details;
b) employment history;
c) educational qualifications;
d) citizenship information, such as your visa and right-to-work status;
e) if you interview with us in person, your image may be recorded on CCTV
f) information received from third parties, such as the results of a professional-reference check or background check, and the information we receive from someone who refers you for a position;
g) publicly available information that helps us make a determination about your candidacy, such as information from your LinkedIn or GitHub profiles; and
h) any other information you choose to submit to us as part of your application.
During your visit to Elula’s website, a cookie is stored on your device acting as a memory for a website. This is to make the website function or work more efficiently by recognising users and their activity over time and may include the following information:
a) User demographics – Data about the age, gender, and interests of users, as well as their location and language.
b) Unique visitors – Whether a page view comes from a first-time or returning visitor.
c) Traffic sources – The sources of website traffic, including data about the search engines, websites, and social networks that are referring traffic to the website.
d) Traffic channels – Based on classifying traffic sources into different groups, such as organic search, direct traffic, referral traffic, and paid search.
e) Device and browser information – Type of devices, operating systems, and web browsers to help optimise the user experience for different devices and browsers.
f) User engagement – based on how many pages they view, the time they spend on each page, and the bounce rate.
Elula obtains your Personal Information either directly from you or through the supplier, service provider or referee. This information may include:
a) your personal information such as your contact details, photo or video recording
b) employment history
c) any other information necessary to assess your application.
Sensitive Information
The Personal Information collected by Elula may include sensitive information, which is defined in the Privacy Act as information or an opinion about such things as an individual’s racial or ethnic origin, political opinions, membership of a political association, religious or philosophical beliefs, membership of a trade union or other professional body, criminal record or health information. Elula will only use sensitive information:
a) for the primary purpose for which it was obtained;
b) for a secondary purpose that is directly related to the primary purpose;
c) with your consent; or
d) where required or authorised by law.
How does Elula collect Personal Information?
Elula will collect Personal Information only by lawful and fair means and not in an unreasonably intrusive manner.
Collecting information from you
If it is reasonable and practical to do so, Elula will collect Personal Information directly from you.
Depending on how you choose to interact with Elula, Elula may collect your Personal Information when you contact, or are contacted by, Elula or its service providers by telephone, by email, through Elula’s website, apps, social media and other digital services or when you complete a form or document and provide it to Elula.
When you provide Elula with Personal Information you consent to the use, disclosure and handling of your Personal Information in accordance with this Privacy Policy.
Collecting information from third parties
For Elula to provide its services to third parties, it collects certain information, which may include Personal Information. In the case of job applicants, Elula may engage a recruitment consultant that may provide Elula with your Personal Information.
Collecting information from visits to Elula’s website
Elula may also collect information based on how you use its website, including through cookies web beacons and other similar technologies.
You can remove or reject cookies by adjusting the settings on your web browser. Please note that some parts of Elula’s website may not function fully for users who disable cookies.
Unsolicited information
If Elula receives Personal Information that it has not requested and determines that the Personal Information received is not reasonably necessary to provide its services, Elula will take all lawful and reasonable steps (if any) to de-identify or destroy that Personal Information.
How does Elula hold Personal Information?
The security of Personal Information is important to Elula. Accordingly, Elula takes reasonable steps to protect Personal Information from misuse, loss, unauthorised access, modification or disclosure, whether the information is stored in physical or electronic form. These steps include the implementation of the following safeguards:
a) conducting regular checks to detect any breaches of this Privacy Policy and other policies, including Elula’s internal Information Security Policy, Encryption Policy, Confidentiality Policy, and Social Media Policy; and
b) maintaining data security by protecting the Confidentiality, Integrity and Availability of Personal Information by following the controls outlined in the Information Security Policy and Encryption Policy.
Elula uses a third party storage provider to store and secure Personal Information.
Elula will take reasonable steps to permanently delete, destroy, or de-identify your Personal Information if it is no longer needed for the purpose for which the information was used or disclosed.
How does Elula use Personal Information?
Elula may hold, use or disclose Personal Information so that it can identify and communicate with job applicants, prospective clients and other individuals who provide their Personal Information to Elula.
Elula may also hold, use or disclose Personal Information to:
a) consider any concern or complaint raised against Elula or to manage any legal action between a complainant and Elula;
b) prevent or investigate any actual or suspected fraud, unlawful activity or misconduct;
c) provide its products and services to its clients; or
d) comply with any relevant laws, regulations, codes of practice and court orders.
How is Personal Information disclosed to others?
Elula does not sell, licence, or trade Personal Information to, or with third parties.
Elula may disclose Personal Information to third parties in limited circumstances, to its third party service providers (such as data storage providers), and as required by law.
Third Party Links
Elula’s website may contain certain links to other websites. Elula does not share your Personal Information with those websites and it is not responsible for the privacy practices applying in respect of those websites.
Cross-border disclosure
Elula may disclose Personal Information to overseas third parties in limited circumstances, such as for background screening of applicants, and visa checks.
Change of control
If Elula sells, assigns, or otherwise transfers part or the whole of its business, the Personal Information which was collected by Elula, may be among the items transferred or sold to the extent that it is relevant to Elula’s business, and you consent to such disclosure or transfer.
How you may access or correct your Personal Information
You may contact Elula to request access to the Personal Information it holds about you at any time. You may also ask Elula to correct information about you that you may believe is inaccurate, incomplete, out of date, irrelevant or misleading.
Please contact Elula using the contact details set out below. Elula will need to verify your identity before giving you access to, or correcting, your Personal Information. Elula will respond to the request within a reasonable period after the request is made. There is no charge to make a request, however, Elula may charge a reasonable fee to cover the administrative costs of retrieving your Personal Information.
In certain circumstances, Elula may refuse, or be unable, to correct or provide you with access to your Personal Information. In such a case, Elula will provide a written response outlining its reasons.
How you may complain if you have concerns about how Elula has managed your Personal Information
If you have a complaint related to how Elula has managed your Personal Information, please contact Elula using the contact details set out below. Elula may ask you to place your concerns in writing so that its compliance staff can fully understand and investigate your complaint.
Elula will provide you with an estimated response timeframe in relation to your complaint. In any event, Elula will endeavour to respond to your complaint within 30 days.
If your complaint remains unresolved, you may contact the Office of the Australian Information Commissioner at www.oaic.gov.au to have your complaint heard and determined.
How to contact Elula
If you have any questions about this Privacy Policy or Elula’s management of your Personal Information, please contact Elula:
Attention: Chief Executive Officer, Elula Group Pty Ltd
Email: [email protected]
Mail: Level 4/364 Kent Street, Sydney NSW 2000