We are committed to being open and transparent about how we manage your personal information. Our Privacy Policy aims to communicate, in the clearest way possible, how we treat your personal information. We encourage you to read this Privacy Policy carefully. It will help you make informed decisions about sharing your personal information with us. At Referable we have a few fundamental principles:

• We will always collect, store, use and disclose personal information in accordance with all applicable privacy laws. However, we have also put in place this Privacy Policy to protect personal information you submit or we collect.
• We will only use your personal information when it is necessary for us to deliver you our services or perform other necessary business functions and activities.
• We will not use or disclose your personal information for purposes unrelated to our business activities and the services we provide, unless we first obtain your consent.

This Privacy Policy outlines how we comply with our privacy obligations under applicable laws.

We are bound by the requirements of those laws, which regulate how we may collect, store, use and disclose your personal information. Those laws also specify other requirements, such as how individuals may access, correct and delete personal information held about them.

In this Privacy Policy when we say personal information we mean identifiable information about you, such as your name, email, address, telephone number and so on. References in this Privacy Policy to we, us, our and Referable collectively refers to Referable Limited and its related companies and affiliates.

Referable provides an online talent sourcing platform that matches prospective employees to their past colleagues to enable recruiters to obtain recommendations and referrals (Service). Our business relies on the collection of personal information that is publicly available, or submitted by you or with your authority, to enable us to provide our Service.

By using our Service or providing your personal information to us, you consent to our collection, storage, use and disclosure of your personal information in accordance with this Privacy Policy.

We may amend the terms of this Privacy Policy from time to time and will notify you of any changes by posting an updated version on our Website. It is your responsibility to check this Privacy Policy periodically for changes.

Your continued access and use of our Website and/or our Service following notification of any changes to this Privacy Policy constitutes acceptance of those changes. If you do not agree with any aspect of the updated Privacy Policy, you must immediately cease all use of our Website and Service.

Information you make public: We may collect or obtain your personal information that you choose to make public, including via online channels such as social media (e.g. LinkedIn, Facebook etc.)

Information you provide to us directly: We may collect personal information directly from you, when you complete any form, including online forms, register to use our Service, or provide any other information in connection with your use of our Service. A few examples include:

• your name, address, email address, telephone number and payment details;
• Demographic information: gender; date of birth; age.
• Contact details: correspondence address; telephone number; email address.

Information we get from third parties: We collect or obtain personal information from authorised third parties (e.g. credit reference agencies, law enforcement agencies). This includes information such as public information, references, or background checks such as credit and criminal record checks.

Information we collect automatically: We may collect personal information about you automatically when you visit our Website or use our Service, like your IP address and device type. Some of this information may be collected using cookies and similar tracking technologies.

Information we create in the performing the Service: We may also create or obtain personal information, such as evaluative records about your interactions with us, and any interactions we have with others on your behalf.

Where we collect personal information, we will only process it:

• where we have legitimate interests to process the personal information and these interests are not overridden by your rights; or
• to perform a contract with you; or
• in accordance with a legal obligation; or
• where we have your consent.

Referable collects your personal information so that we can provide you with the Service and any related services you may request. In doing so, we may use the personal information we have collected from you or collected from a publicly available publication for purposes related to the Service including:

• to process and administer the Service, and to help us develop, improve, manage, administer and facilitate our Service and business operations;
• to fulfil orders placed by you;
• to process your personal information for Referable's internal business purposes;
• to verify your identity and user details; for general internal purposes (such as record keeping, database management, billing);
• to assess your eligibility for an account;
• to assist with the resolution of any issues relating to the Service;
• to comply with all laws and regulations in all applicable jurisdictions; or
• communicate with you.

We may also anonymise data and use it in a manner in which you cannot be identified.

By using the Service, you consent to your personal information being collected, stored, used and disclosed in this way and for any other use you authorise. Referable will only use your personal information for purposes described in this Privacy Policy, or with your consent.

We will only disclose your personal information outside Referable and its related companies if it is necessary and appropriate to facilitate the purpose for which your personal information was collected pursuant to this Privacy Policy, including providing the Service, or a directly related purpose.

We will not otherwise disclose your personal information unless we believe on reasonable grounds that the information is publicly available information, or that you have provided your authorisation for the disclosure. However, you should be aware that we may be required to disclose your personal information without your consent in order to comply with any court orders, subpoenas or other legal process or investigation including by tax authorities, if such disclosure is permitted or required by law. Where possible and appropriate, we will notify you if we are required by law to disclose your personal information.

We will only disclose your personal information outside Referable and its related companies if it is necessary and appropriate to facilitate the purpose for which your personal information was collected pursuant to this Privacy Policy, including providing the Service, or a directly related purpose.

We will not otherwise disclose your personal information unless we believe on reasonable grounds that the information is publicly available information, or that you have provided your authorisation for the disclosure. However, you should be aware that we may be required to disclose your personal information without your consent in order to comply with any court orders, subpoenas or other legal process or investigation including by tax authorities, if such disclosure is permitted or required by law. Where possible and appropriate, we will notify you if we are required by law to disclose your personal information.

In connection with providing the Service, you accept that your personal information may be collected or held in New Zealand and be disclosed to recipients in, or transferred to, or processed in, countries other than New Zealand. We may provide your personal information to third parties in countries other than New Zealand if we have reasonable grounds to believe either that the recipient is required to protect your personal information in a way that, overall, provides comparable safeguards to those required by New Zealand’s privacy laws.

However, there may be differences between New Zealand's privacy laws and those of the overseas locations in which we may store and process your personal information. If we cannot ensure that recipients in those locations are required to protect your personal information using comparable safeguards to those under New Zealand’s privacy laws then we will only provide your personal information to recipients in those locations if you authorise us to do so.

For further information, please contact us using the details set out in the contact section below.

We are committed to protecting the security of your personal information and we take all reasonable precautions to protect it from unauthorised access, modification or disclosure. However, due to the inherent open nature of the Internet, we cannot guarantee that communications between you and us or the information stored on our Website is absolutely secure.

Referable implements and maintains organisational and technical security measures that are designed to provide reasonable protection against the loss, interference or misuse of your personal information and to prevent unauthorised access, modification or disclosure of that information.

Cookies are bits of text that are placed on your computer’s hard drive or Internet-connected device when you visit certain websites. Cookie technology holds information a site may need to personalise a visitor’s experience. Cookies may also be used for security purposes and to gather Website statistical data, such as which pages are visited, what is downloaded, and the paths taken by visitors to our Website as they move from page to page.

You may control or refuse the use of cookies in this way by selecting the appropriate settings on your browser. However, by not accepting or deleting the use of cookies, it may affect how our Website operates and you may not be able to access all or parts of our Website.

We may also use third-party web analytics services on this Site, such as Google Analytics, which uses technologies such as cookies to help analyse how users use our Website. The information generated by the cookie about your use of this Website will be transmitted and stored by Google. Google will use this information to monitor your use of this Website, compiling reports on Website activity for Website operators and providing other services related to Website activity and internet usage. Google may transfer this information to third parties where required by law, or where such third parties process information on Google’s behalf.

Our Website may contain links to other websites that are not under our control. These websites may use cookies. It is the responsibility of those third parties to collect appropriate consents from you in order to permit their own cookies (to the extent this is required by law) and to inform you about the cookies they use. You should check the privacy policy on all third-party websites to ensure you are comfortable with third party cookies.

We have no responsibility for linked websites and provide them solely for your information and convenience. We specifically disclaim responsibility for their content, privacy practices and terms of use, and we make no endorsements, representations or warranties about their accuracy, content or thoroughness. Your disclosure of personal information to third party websites is at your own risk.

We are committed to full compliance with the Unsolicited Electronic Messages Act 2007.

By subscribing to emails and/or text communications, or otherwise providing your email address and/or mobile number, you consent to receiving emails and/or texts (as the case may be) which promote and market our products and services, or the products and services of others, from time to time.

You can unsubscribe from our email and/or text communications at any time by clicking the unsubscribe link in any promotional or marketing email or text received or by emailing privacy@referable.ai.

Once you have unsubscribed from the email or text communications, you will be removed from the corresponding marketing list as soon as is reasonably practicable.

It is your responsibility to ensure that the personal information you provide to us is accurate, complete and up-to-date.

You may request access to the personal information we hold about you, request that we update or correct any personal information we hold about you, ask us to restrict or cease processing your personal information or even delete your personal information, by setting out your request in writing and sending it to us at privacy@referable.ai.

We will review your request as soon as reasonably practicable to comply with our legal obligations. If we are unable to give you access to the information you have requested, we will give you reasons for this decision when we respond to your request.

The length of time we keep your personal information depends on what it is and whether we have an ongoing business need to retain it (for example, to provide you with a service you've requested or to comply with applicable legal requirements such as money laundering and financial reporting legislation).

We'll retain your personal information for as long as we have a relationship with you and for a period of time afterwards where we have an ongoing business need to retain it, in accordance with our internal retention policies and practices. Following that period, we'll make sure it's deleted or anonymised. Otherwise, as a general rule, we only keep your personal information for as long as we require it for the purposes of providing you with our Service.

We take your concerns seriously. If you have any concerns about privacy or the use or collection of your personal information by Referable, please contact our Privacy Officer at [privacy@referable.ai] and include the words 'ATT: THE PRIVACY OFFICER'.

We will respond as quickly as possible (and no later than 20 working days) and handle all complaints in a way that is fair and consistent. However, if you remain dissatisfied, you can make a formal complaint with Office of the Privacy Commissioner if you are in New Zealand (visit https://www.privacy.org.nz/ or call 0800 803 909 for further information), or the relevant data protection agency in the relevant Location.

This Privacy Policy was last updated on November 30, 2023