PulsePoint Privacy Policy

Last updated: 22 December 2025

Version: 2.0

1. About this Policy

PulsePoint Au Pty Ltd (ACN 692 761 345) (“PulsePoint”, “we”, “us”, or “our”) is committed to protecting the privacy of your personal information. We are bound by the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles (APPs).

This Policy explains how we collect, hold, use, and disclose your personal information. By using our website or services, you consent to the data practices described in this Policy.

2. The Information We Collect

We collect different types of information depending on your relationship with us (e.g., as a Client or a Candidate/Employee).

2.1 Clients and Business Partners

  • Identity Data: Name, job title, and role.

  • Contact Data: Email address, telephone numbers, and business address.

  • Business Data: Company details, operational requirements, and information necessary to scope your offshore staffing needs.

  • Financial Data: Billing address, bank account details, and payment history.

2.2 Candidates and Offshore Staff

  • Identity Data: Name, date of birth, and government ID numbers (where required for background checks).

  • Employment Data: Résumés/CVs, employment history, education, qualifications, references, and skills assessment results.

  • Sensitive Information: In limited circumstances, and only with your consent, we may collect sensitive information such as health information, criminal record checks, or membership of professional associations, where relevant to the role.

2.3 Website Users

  • Technical Data: IP address, browser type, device information, and operating system.

  • Usage Data: Information about how you use our website, pages visited, and time spent.

3. How We Collect Information

We collect personal information through:

  • Direct Interaction: When you enquire about our services, sign a Client Services Agreement, submit a job application, or correspond with us via email or phone.

  • Automated Technologies: As you interact with our website, we may automatically collect Technical Data (via cookies and analytics tools).

  • Third Parties: We may receive information from:

    • Recruitment platforms (e.g., LinkedIn, JobStreet).

    • Referees or background check providers (with your consent).

    • Publicly available sources (e.g., company websites).

4. Purpose of Collection (Why we need your data)

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

  • Service Delivery: To provide managed outsourcing services, including sourcing, vetting, and managing offshore talent for Clients.

  • Employment Management: To facilitate the employment, onboarding, and payroll of offshore staff via our Philippine subsidiary.

  • Communication: To send you service updates, invoices, and support responses.

  • Compliance: To comply with legal obligations in Australia and the Philippines (e.g., tax reporting, labor laws).

  • Improvement: To analyse website usage and improve our service offerings.

5. Disclosure of Personal Information

We may disclose your personal information to:

  • Related Bodies Corporate: Specifically, our wholly-owned subsidiary in the Philippines for the purpose of operational management and staff employment.

  • Service Providers: Third-party vendors who assist with our business operations, including:

    • Cloud storage and CRM providers (e.g., HubSpot, Google Workspace).

    • Accounting and invoicing software (e.g., Xero).

    • Background check and testing agencies.

  • Professional Advisers: Lawyers, accountants, and auditors.

  • Regulatory Authorities: If required by law (e.g., the ATO, ASIC, or Philippine government agencies).

6. Cross-Border Disclosure (Sending data overseas)

Important: As an outsourcing business, cross-border data transfer is essential to our operations.

By providing your personal information to us, you acknowledge and consent that we may disclose your information to our subsidiary and staff located in the Philippines.

We take reasonable steps to ensure that our overseas recipients handle your personal information in accordance with the APPs and maintain data security standards consistent with Australian law. This includes contractual obligations and strict internal data access policies.

7. Security and Data Retention

We implement appropriate technical and organisational measures to protect your personal information from misuse, interference, loss, unauthorised access, modification, or disclosure.

  • Storage: Data is stored in secure, encrypted cloud-based systems.

  • Access: Access is restricted to authorised personnel on a "need-to-know" basis.

  • Retention: We retain your data only for as long as necessary to fulfil the purposes for which it was collected, or to comply with legal/reporting requirements. When no longer needed, data is securely destroyed or anonymised.

8. Your Rights (Access and Correction)

You have the right to request access to the personal information we hold about you and to ask for corrections if it is inaccurate, incomplete, or out of date.

  • To make a request, please contact us using the details in Section 10.

  • We may require you to verify your identity before processing your request.

  • In some cases, we may refuse access where permitted by law (e.g., if it would breach the privacy of others).

9. Complaints

If you believe we have breached the Australian Privacy Principles, please contact us in writing. We take privacy complaints seriously and will respond within a reasonable timeframe (usually 30 days).

If you are not satisfied with our response, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC):

  • Website: www.oaic.gov.au

  • Phone: 1300 363 992

10. Contact Us

If you have any questions about this Privacy Policy, please contact our Privacy Officer:

PulsePoint Au Pty Ltd

Email: go@pulsepoint.com.au

Postal Address: PO Box 511, Lidcombe NSW 1825.