Mincka Privacy Policy

This Policy has been published to provide a clear and concise outline of how and when personal information is collected, disclosed, used, stored and otherwise handled by Mincka and any of its subsidiaries and related entities (Mincka, we, our or us. This Policy relates to personal information collected by any means and by any technology, including but not limited to information collected via our website at www.mincka.com.au. Mincka is committed to protecting the privacy of visitors to our website, and the protection of any personal information provided to us. When you visit our website, you do so anonymously unless you voluntarily provide your personal information to us. We may use cookies or other means to collect statistics on visitors to our website (generally including country of location, pages visited etc.) in order to be as user-friendly, informative and personal as possible.

1. Introduction

   1. Our privacy assurance to you

      1. Your privacy has always been important to us. We respect your right to be aware of who has information about you, what they are doing with it and why, and who else they are sharing it with.

      2. Our objective is to handle information responsibly and provide you with some control over the way information about you is handled.

   2. Overview

      This privacy policy explains how we manage personal information. In particular it explains, in relation to that personal information:

      1. the kinds of personal information we collect and hold;

      2. how we collect the personal information;

      3. the purposes for which we collect, hold, use and disclose the personal information;

      4. how we store your personal information;

      5. your rights to deal with the personal information held;

      6. how complaints are dealt with; and

      7. whether we are likely to disclose the personal information to overseas recipients and the countries where those recipients are likely to be located.

2. The kinds of personal information we collect and hold and how it is collected

   We collect a variety of personal information about individuals in a variety of ways. For example, we may obtain the information from the individual or from persons acting on the individual’s behalf. When it is possible and practical, we will collect the information direct from the individual. When it is not practical or reasonable to do so we may collect the information from a third party. We may also collect information based on the individual’s interactions with us.

   The main categories of information we collect is as follows:

   1. Information that is necessary for the provision of our services

      We ask for and collect the following personal information about you to assist us in providing our services, marketing our services and administering our business. This information is necessary for the adequate performance of our services and to allow us to comply with our legal obligations. Without it, we may not be able to provide you with all the requested services.

      1. Personal identification information (name, email address, phone number etc). This will be collected if you submit your details through a website enquiry or register for further information;

      2. Communications with Mincka. When you communicate with Mincka we will collect information about your communication and any information that you choose to provide;

      3. Payment Information. To engage our services we may require you to provide certain financial information (like your bank account or credit card information) in order to facilitate the processing of payments;

   2. Information you choose to provide to Mincka

      You may choose to provide us with additional personal information in order to obtain a better experience when using our services or to apply for a position or engagement with us. This additional information will be processed based on our legitimate interest or when applicable, your consent.

      1. Employment history, academic record, professional memberships and other information. This may be provided through or supporting an employment application or curriculum vitae, employment references or through Mincka’s E-Hire System;

      2. Other Information. You may choose to provide us information when you fill in a form, update or add information to you contact details, respond to surveys, participate in promotions (such as conferences, seminars and surveys), communicate with our employees and contractors, share your experiences with us or use any part of our services;

      3. Payment Information. You may provide us with certain financial information (like your bank account or credit card information) in order to process payments.

   3. Information we collect from third parties

      We may collect information, including personal information, that others provide about you, or obtain information from other sources and combine that with information we collect through the services. We do not control, supervise or respond for how the third parties providing your information process your personal information, and any information request regarding the disclosure of your personal information to us should be directed to such third parties.

      1. Third Party Services. If you link, connect, or login to our website or other online access related to our services with a third party service (e.g. Google, Facebook, LinkedIn), the third party service may send us information such as your registration, friends list, and profile information from that service. This information varies and is controlled by that service or as authorised by you via your privacy settings at that service.

      2. Your References. If someone has provided an employment reference for you this communication will be collected.

      3. Background Information. To the extent permitted by applicable laws and with your consent where required, we may obtain the local version of police, background or registered sex offender checks. We may use your information, including your full name and date of birth, to obtain such reports.

      4. Referrals. If you are referred to our services, the person who invited you may submit personal information about you such as your email address or other contact information.

      5. Other Sources. To the extent permitted by applicable law, we may receive additional information about you, such as demographic data or information to help detect fraud and safety issues, from third party service providers and/or partners, and combine it with information we have about you. For example, we may receive background check results (with your consent where required) or fraud warnings from service providers like identity verification services for our fraud prevention and risk assessment efforts.

   4. Information that we automatically collect

      When you use our services or our website, we automatically collect personal information about the services you use and how you use them. This information is necessary for the adequate performance of the contract between you and us, to enable us to comply with legal obligations and given our legitimate interest in being able to provide and improve the functionalities of our services and website.

      1. Usage Information. We collect information about your interactions with our website such as the pages or content you view, your searches, and other actions on our website.

      2. Cookies and Similar Technologies. We use cookies and other similar technologies when you use our website, use any mobile app, or engage with our online ads or email communications. We may collect certain information by automated means using technologies such as cookies, web beacons, pixels, browser analysis tools, server logs, and mobile identifiers. In many cases the information we collect using cookies and other tools is only used in a non-identifiable without reference to personal information. For example, we may use information we collect to better understand website traffic patterns and to optimise our website experience. In some cases, we associate the information we collect using cookies and other technology with your personal information. Our business partners may also use these tracking technologies on our website or engage others to track your behaviour on our behalf. You can set your browser not to accept cookies however it is possible that some of our website features may not function as a result.

      3. Pixels and SDKs. Third parties, including Facebook, may use cookies, web beacons, and other storage technologies to collect or receive information from our websites and elsewhere on the internet and use that information to provide measurement services and target ads.

      4. Payment Transaction Information. We collect information related to any payment transactions through our website, including the payment instrument used, date and time, payment amount, payment instrument expiration date and billing postcode, PayPal email address, IBAN information, your address and other related transaction details. This information is necessary for the adequate performance of the services.

3. The purposes for which we collect, hold and use personal information

   We may use, store and process personal information for purposes permitted by law and which are reasonably necessary for our business activities. These include:

   1. To provide, improve and develop our services and business

      We may use the personal information to provide, improve, and develop the services and our business such as to:

      1. enable you to access and use the services and our website;

      2. enable you to communicate with other our staff and service providers where necessary;

      3. operate, protect, improve, and optimise the services and website and experience, such as by performing analytics and conducting research;

      4. provide customer service;

      5. send you service or support messages, updates, security alerts, and account notifications;

      6. if you provide us with your contacts’ information, we may process this

         information:

         1. to facilitate your referral invitations;

         2. send your requests for references;

         3. for fraud detection and prevention; and

         4. for any purpose you authorise at the time of collection;

      7. to operate, protect, improve, and optimise the services and website and experience, and personalise and customize your experience; and

      8. enable your use of our enterprise products.

         We process this personal information for these purposes given our legitimate interest in improving our services, our website and your experience with it, and where it is necessary for the adequate performance of our obligations to you.

   2. To meet staffing and recruitment needs

      We may use the personal information to assist us in meeting staffing and recruitment needs such as to

      1. to consider applications for roles and positions;

      2. to notify you of employment opportunities aligned to your qualifications, skills and experience (as provided to us in an online job application;

      3. for general employment purposes;

   3. To provide, personalise, measure and improve our advertising and marketing

      We may use the personal information to provide, personalise, measure, and improve our advertising and marketing such as to:

      1. send you promotional messages, marketing, advertising, and other information that may be of interest to you based on your preferences (including information about campaigns and services and social media advertising through social media platforms such as Facebook or Google);

      2. personalise, measure, and improve our advertising;

      3. administer referral programs, rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by us or our third party partners;

      4. conduct profiling on your characteristics and preferences (based on the information you provide to us, your interactions with us and information obtained from third parties) to send you promotional messages, marketing, advertising and other information that we think may be of interest to you;

      5. invite you to events and relevant opportunities.

         We will process your personal information for the purposes listed in this section given our legitimate interest in undertaking marketing activities to offer you products or services that may be of your interest.

   4. To operate payment services

      We may use the personal information as part of services to facilitate payments such as to:

      1. enable you to access and use the payment services;

      2. detect and prevent fraud, abuse, security incidents, and other harmful activity;

      3. conduct security investigations and risk assessments;

      4. conduct checks against databases and other information sources;

      5. comply with legal obligations (such as anti-money laundering regulations);

      6. enforce the payment terms and other payment policies;

      7. with your consent, send you promotional messages, marketing, advertising, and other information that may be of interest to you based on your preferences.

         We will process this personal information given our legitimate interest in improving the payment services and its users’ experience with it, and where it is necessary for the adequate performance of the services and to comply with applicable laws.

   5. To create and maintain a trusted and safer environment

      We may use the personal information to create and maintain a trusted and safer environment such as to:

      1. detect and prevent fraud, spam, abuse, security incidents, and other harmful activity;

      2. conduct security investigations and risk assessments;

      3. verify or authenticate information or identifications provided by you (such as to verify your employment history or compare your identification photo to another photo you provide);

      4. conduct checks against databases and other information sources, including background or police checks, to the extent permitted by applicable laws and with your consent where required;

      5. comply with our legal obligations;

      6. resolve any disputes and enforce our agreements with third parties;

      7. enforce our terms of service and other policies; and

         We process this personal information for these purposes given our legitimate interest in protecting our business and the services we provide, to measure the adequate performance of services and the relationship with you, and to comply with applicable laws.

         You have choices on the promotional messages that you choose to receive and can limit the information that you provide to us. Participation in promotions and marketing programs is voluntary and you can limit the communications that we send to you. Please note however that even if you elect not to receive marketing communications, we may still need to contact you with important transaction information or alerts.

4. How we might share or disclose your personal information

   1. Advertising and Social Media; Sharing with Your Consent

      1. Where you have provided consent, we share your information, including personal information, as described at the time of consent, such as when you authorise a third party application or website to access your information or when you participate in promotional activities conducted by us, our partners or third parties.

      2. Where permissible according to applicable law we may use certain limited personal information about you, such as your email address, to share it with social media platforms, such as Facebook or Google, to generate leads, drive traffic to our websites or otherwise promote our products and services. These processing activities are based on our legitimate interest in undertaking marketing activities to offer you products or services that may be if your interest.

      3. The social media platforms with which we may share your personal information are not controlled or supervised by us. Therefore, any questions regarding how your social media platform service provider processes your personal information should be directed to such provider.

      4. Please note that you may, at any time ask us to cease processing your data for these direct marketing purposes by opting out directly though the original source of communication e.g Mailchimp or sending an e-mail

         to info@mincka.com

   2. Compliance with Law, Responding to Legal Requests, Preventing Harm and Protection of our Rights

      1. We may disclose your information, including personal information, to courts, law enforcement, governmental authorities, tax authorities, or authorised third parties, if and to the extent we are required or permitted to do so by law or if such disclosure is reasonably necessary:

         1. to comply with our legal obligations;

         2. to comply with a valid legal request or to respond to claims asserted against us;

         3. to respond to a valid legal request relating to a criminal investigation or alleged or suspected illegal activity or any other activity that may expose us, you, or any other of our users to legal liability;

         4. to enforce and administer our terms of service or other agreements;

         5. to protect our rights, property or personal safety, or that of our employees, or members of the public.

      2. These disclosures may be necessary to comply with our legal obligations, for the protection of your or another person’s vital interests or for the purposes of our or a third party’s legitimate interest in keeping our services and business secure, preventing harm or crime, enforcing or defending legal rights, facilitating the collection of taxes and prevention of tax fraud or preventing damage.

      3. Where appropriate, we may notify you about legal requests unless:

         1. providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law;

         2. we believe that providing notice would be futile, ineffective, create a risk of injury or bodily harm to an individual or group, or create or increase a risk of fraud upon our property.

            In instances where we comply with legal requests without notice for these reasons, we may attempt to notify you about the request after the fact where appropriate and where we determine in good faith that we are no longer prevented from doing so.

   3. Service Providers

      1. We use a variety of third-party service providers to help us provide services related to our services and business. Service providers may be located inside or outside of Australia.

      2. For example, service providers may help us:

         1. verify your identity or authenticate your identification documents;

         2. check information against public databases;

         3. conduct background or police checks, fraud prevention, and risk assessment;

         4. perform product development, maintenance and debugging;

         5. allow the provision of the services through third party platforms and software tools (e.g. through the integration with our APIs);

         6. provide customer service, advertising, or payments services; or process, handle or assess insurance claims or other similar claims. These providers have limited access to your personal information to perform these tasks on our behalf and are contractually bound to protect the personal information and only use the personal information in accordance with our instructions.

      3. We will need to share your information, including personal information, in order to ensure the adequate performance of our contract with you.

   4. Corporate Affiliates

      1. To enable or support us in providing the services and operating our business, we may share your information, including personal information, within our corporate family of companies (both financial and non-financial entities) that are related by common ownership or control.

      2. Additionally, we share your information, including personal information, with our corporate affiliates in order to support and integrate, promote, and to improve our services and those of our affiliates.

      3. Mincka is an international company. We may disclose your personal information to personnel within Mincka in the countries in which Mincka operates. When you (or your authorised recruitment agency representative) volunteer personal information on our website, you consent to us sharing your personal information within Mincka for the purpose which it was disclosed to us, or for a related purpose which would be reasonably expected without your permission.

   5. Business Transfers.

      If we undertake or are involved in any merger, acquisition, reorganisation, sale of assets, bankruptcy, or insolvency event, then we may sell, transfer or share some or all of our assets, including your information in connection with such transaction or in contemplation of such transaction (e.g., due diligence). In this event, we will notify you before your personal information is transferred and becomes subject to a different privacy policy.

   6. Aggregated Data.

      We may also share aggregated information (information about our users that we combine together so that it no longer identifies or references an individual user) and other anonymized information for regulatory compliance, industry and market analysis, research, demographic profiling, marketing and advertising, and other business purposes.

   7. Cross-border disclosure

      1. Generally, we do not disclose personal information to overseas recipients other than our corporate affiliates. However, we may do so. For example, if the debtor is located overseas, we may need to send the client’s personal information overseas so that we can collect the debt. We may use service

         providers located overseas. In each case personal information is provided to an overseas recipient when this is permitted by law.

      2. The countries where the overseas recipients of personal information may be located in New Zealand, United States, Canada, United Kingdom, Austria, Belgium, Finland, France, Germany, China (including Hong Kong), Ireland, Italy, Japan, Luxembourg, Malta, the Netherlands, Portugal, Singapore, South Africa, Spain and Switzerland.

5. How we store your personal information

   1. We generally retain your personal information for as long as is necessary for the performance of our services and to comply with our legal obligations.

   2. We take all reasonable steps to keep the personal information we hold secure and prevent unauthorised access or disclosure. These steps include physical security and restrictions on access to electronic records. Our employees are prohibited from using or disclosing personal information for purposes unrelated to the purpose for which it was collected.

   3. We restrict access to personal information collected on our website to only those employees who need access to that information in order to perform and discharge their duties. We may share personal information with third parties. The type of third parties that we may disclose personal information to include service providers who assist us in providing and maintaining our website and who provide recruitment services to us.

6. How can you deal with your personal information?

   1. Access

      1. You may access personal information about you which we hold by contacting our privacy contact officer (Privacy Officer) as follows:

         Phone	+61 3 9653 9647
         E-mail:	info@mincka.com
         Mail:	Level 27, 101 Collins St, Melbourne VIC 3000

      2. e Privacy Officer, we will need to verify

         the individual’s identity before giving access.

      3. We will usually provide the requested personal information within 30 days of receiving the request. There is no charge to make a request, but we may levy an administration fee for providing access. If there is a reason why we do not make the requested personal information available, we will provide our reason in writing.

   2. Rectification, Erasure, Restricting Processing and Transferring data

      1. In certain circumstance and some jurisdictions, you have the right to ask us to:

         1. correct in accurate or incomplete personal information;

         2. erase your personal information;

         3. restrict the processing of your personal information;

         4. transfer the personal information that we have collected to another organisation or directly to you;

      2. To make these requests, please contact our Privacy Officer in writing through the details listed above.

      3. In certain situations, we may decide not to agree to a request to correct personal information. These may include where:

         1. access would create a serious threat to safety;

         2. providing access will have an unreasonable impact upon the privacy of other individuals;

         3. denying access is required or authorised by law;

         4. the request is frivolous or vexatious;

         5. legal proceedings are underway or otherwise anticipated;

         6. negotiations may be prejudiced by such access; or

         7. access would reveal a commercially sensitive decision making process.

      4. We will tell you in writing why we have not agreed to the correction request in these circumstances.

      5. Please note that if you request erasure of your personal information, we may retain some of your personal information as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety or to comply with our legal obligations. Because we maintain our records to protect from accidental or malicious loss and destruction, residual copies of your personal information may not be removed from out backup systems for a limited period of time.

   3. Objecting to Processing

      1. In certain circumstances, you may have the right to object to our processing of your personal information.

      2. To make this request, please contact our Privacy Officer in writing through the details listed above.

7. How you can make a complaint relating to privacy

   1. If you believe that your privacy has been infringed, you are entitled to complain. All complaints should initially be in writing and directed to the Privacy Officer through the details provided above.

   2. We will respond to your complaint as soon as possible, within 14 working days, to let you know who is responsible for managing your query.

   3. We will try to resolve the complaint within 30 working days. When this is not possible, we will contact you to provide an estimate of how long it will take to handle the complaint.

   4. While we aim to resolve your complaints at your first point of contact if you are not satisfied with the decision you may make a complaint to the Information Commission appropriate for your jurisdiction.

   5. In Australia, complaints may be made to the Office of the Australian Information

      Commissioner (the “OAIC”). The contact details for the OAIC are:

      Telephone:	1300 363 992
      Website:	www.oaic.gov.au
      Mail:	The Office of the Australian Information Commissioner GPO Box 2999 CANBERRA ACT 2601

   6. In New Zealand, complaints may be made to the Office of the Privacy Commissioner

      (the “OPC”). The contact details for the OPC are:

      Telephone:	0800 803 909
      Website:	www.privacy.org.nz
      Mail:	The Office of the Privacy Commissioner PO Box 10 094 WELLINGTON 6143

8. Acceptance and changes to Mincka’s Privacy Policy

   1. You acknowledge and accept that your use of the our website and services indicates your acceptance of this Privacy Policy.

   2. This is the current Privacy Policy. It replaces any other Privacy Policy published on our website or otherwise provided to date.

   3. We may, at any time, make amendments to the Privacy Policy by publishing the new Privacy Policy on our website. You accept that by doing this, we have provided you with sufficient notice of the amendments. It is your responsibility to check the Privacy Policy each time you visit our website.