Privacy Policy 

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Seenculture Pty Ltd ACN 663 234 348 ("we", "us" or "our") are committed to respecting your privacy. Our Privacy Policy sets out how we collect, use, store, share and disclose your personal information. 

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We operate the platform, ‘SeenCulture’, hosted at https://www.seenculture.com (and associated subdomains, such as platform.seenculture.com, survey.seenculture.com, and app.seenculture.com) SeenCulture is an employment management software platform designed to enhance professional development and personal branding within organisations. Our platform helps employees gain recognition for their achievements and enables leaders to make informed decisions about employee development. We collect and analyse data to identify employee strengths, facilitate skill development, and improve organisational effectiveness. 

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   1. Openness and transparency

 

We are committed to protecting your privacy and respecting and upholding your rights under the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth) (Privacy Act).  We ensure that we will take all necessary and reasonable steps to comply with the APPs and to deal with inquiries or complaints from individuals about compliance with the APPs. 

By accessing and using our website, products and services, you agree to and consent to the collection, use, storage and disclosure of personal information by us as set out in this Privacy Policy.

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   2. Personal information

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Personal information is information or an opinion about an individual whose identity is apparent, or can be reasonably ascertained, from that information or opinion (whether true or not, and whether recorded in a material form or not). 

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The type of personal information we collect, store, handle and/or process from you depends on your relationship with us. 

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• Organisations

  • information you supply to us from your human resource systems in relation to your employees (which may include sensitive information, see section 3); 

  • your skills competency framework by which you assess employee performance; and 

  • your organisation name, and the contact details for your authorised representatives. 

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• Individuals

  • your full name; 

  • your address;  

  • details of your employment (office location, position, level, business unit, tenure, etc.); 

  • email address; and 

  • date of birth. 

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In addition, we may collect the following personal information: 

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• your device ID, device type, geo-location information, computer and connection information, statistics on page views, traffic to and from the sites, ad data, IP address and standard web log information;

• any additional information relating to you that you provide to us directly through our website or app or indirectly through your use of our website or app or online presence or through other websites or accounts from which you permit us to collect information; and 

• any other personal information that may be required in order to facilitate your dealings with us.

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   3. Collection

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We will collect personal information only by lawful and fair means and not in an unreasonably intrusive way. Generally, we will collect personal information directly from you, and only to the extent necessary to provide our products and services requested or ordered by you and to carry out our administrative functions or as required by law. 

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Sensitive information 

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We will also, in limited circumstances, collect, store, handle and/or process sensitive information, including but not limited to: 

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• ethnicity; and 

• performance reviews. 

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We may also collect personal information from you when you fill in an application form, communicate with us, visit our website, provide us with feedback, complete online surveys or participate in competitions. We may collect personal information about you from our business partners or from third parties. 

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If you use a pseudonym when dealing with us or you do not provide identifiable information to us, we may not be able to provide you with any or all of our services as requested. If you wish to remain anonymous when you use our website do not sign into it or provide any information that might identify you. 

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We require individuals to provide accurate, up-to-date and complete personal information at the time it is collected. 

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   4. What do we do with your personal information?

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We use and disclose your personal information for the purposes for which the information is collected, or for a directly related purpose, including (but not limited to):

• providing our website, products and services to you (including surveys, see Section 6);

• administering, protecting, improving or optimising our website, products and services (including performing data analytics, conducting research and for advertising and marketing purposes);

• any other purpose you have consented to; and

• any use which is required or authorised by law.

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   5. Disclosure of personal information

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We may disclose your personal information to:

• third-parties we ordinarily engage from time to time to perform functions on our behalf for the above purposes;

• any person or entity to whom you have consented to us disclosing your personal information to;

• our external business advisors, auditors, lawyers, insurers and financiers; and 

• any person or entity to whom we are required or authorised to disclose your personal information to in accordance with the law.

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   6. Employee surveys

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We provide survey functionality as part the SeenCulture platform, which allows organisations (Survey Creators) to create and administer surveys for their employees (Survey Participants) to participate in. 

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NOTE: Your participation in all surveys is voluntary, and you maintain the right to decline participation at any time.   

How we treat survey data

• as the platform provider, we (SeenCulture) manage and secure all employee survey data and responses, including individual responses. 

• Survey Creators have a right to access employee survey response data at an aggregated level only (except in the case of benchmarking performance within a team, see below). This means that Survey Creators cannot see individualised responses. Surveys also have minimum participation requirements, which means that if not enough employees complete the survey, we (SeenCulture) will not release the results to the Survey Creator. This is to protect Survey Participant privacy. 

• responses are used exclusively to perform our services and generate insights for the Survey Creator; 

• we don't sell or share individual survey responses or aggregated data with third parties; and

• we comply with legal requirements and may be required to release information under limited circumstances. 

 

Survey responses 

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Survey responses may include:

• professional achievements and recognition;

• skill assessments and competencies;

• feedback on workplace contributions;

• development opportunities and career aspirations; and 

• peer and manager recognition data.

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How survey data will be used 

 

Survey data may be used to:

• identify employee strengths and development areas;

• inform leadership decisions about employee development;

• benchmark employees; 

• support professional growth opportunities; 

• enhance personal branding within the organisation; and 

• track and recognise employee achievements.

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NOTE: this may involve benchmarking you as an employee against your peers within your organisation (e.g. who is the strongest or weakest salesperson).    

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Survey data access controls 

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We employ a hierarchical access system that restricts survey data to authorised personnel of Survey Creators. Only designated individuals with appropriate permissions can view aggregated survey results.

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   7. Access and management

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Subject to some exceptions provided by law, you may request access to your personal information in our customer account database, or seek correction of it, by contacting us.  See section 11: Contact information. Should we decline you access to your personal information, we will provide a written explanation setting out our reasons for doing so. 

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We may charge a reasonable fee that is not excessive to cover the charges of retrieving your personal information from our customer account database.  We will not charge you for making the request.

If you believe that we hold personal information about you that is not accurate, complete or up-to-date then you may request that your personal information be amended.  We will respond to your request to correct your personal information within a reasonable timeframe and you will not be charged a fee for correcting your personal information.  

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If we no longer need your personal information for any of the purposes set out in this Privacy Policy, or as otherwise required by law, we will take such steps as are reasonable in the circumstances to destroy your personal information or to de-identify it.

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   8. Cross-border disclosure

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We may disclose your personal information to third party recipients located in or outside of Australia in order to provide our website, products and services to you (Recipients). As at the date of this Privacy Policy, we process all information we receive in data centres located in Australia. 

When entering into a transaction with us you consent to your personal information being disclosed or transferred to such Recipients and you acknowledge and agree that we have no obligation to take such steps as are reasonable in the circumstances to ensure that the information that is transferred or disclosed to the Recipients will be treated in a manner that is consistent with the APPs. You also agree that insofar as the law allows, we have no liability to you or anyone else for any breach by the Recipient of the APPs.

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   9. SeenCulture website

When transmitting personal information from your computer to the SeenCulture website, you must keep in mind that the transmission of information over the Internet is not always completely secure or error-free. Other than liability that cannot lawfully be excluded, we will not be liable in any way in relation to any breach of security or any unintended loss or disclosure of that information.

 

The SeenCulture website may use 'cookies' or other similar tracking technologies on our website that help us track your website usage and remember your preferences. Cookies are small files that store information on your computer, TV, mobile phone or other device. They enable the entity that put the cookie on your device to recognise you across different websites, services, devices and/or browsing sessions. You can disable cookies through your internet browser but if you do so, you may not be able to fully experience the interactive features of the SeenCulture website.

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   10. Security

 

We may hold your personal information in either electronic or hard copy. We take reasonable steps to protect your personal information from misuse, interference and loss, as well as unauthorised access, modification or disclosure and we use a number of physical, administrative, personnel and technical measures to protect your personal information. For example, we: 

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• ensure there are suitable password protection measures and access privileges in place to monitor and control access to our IT systems;

• impose restrictions on physical access to paper files;

• require any third parties engaged by us to provide appropriate assurances to handle your personal information in a manner consistent with Australian law; 

• take reasonable steps to destroy or de-identify personal information after we no longer need it for our business or to comply with the law; 

• maintain a disaster recovery plan which provides for the restoration of our website within 24 hours of a failure (Disaster Recovery Plan). We test the Disaster Recovery Plan annually;

• maintain and host our website only in data centres that are compliant with a recognised information security standard; and 

• implement the principle of least privilege access for our employees, ensuring that staff members have access only to the information and systems necessary for their specific roles and responsibilities;

• employ strict access controls and regularly review and update access permissions to restrict access to only necessary systems and data;

• use encryption for data in transit and at rest;

• maintain up-to-date security software, including firewalls, anti-virus, and intrusion detection systems;

• implement multi-factor authentication for our staff when accessing critical systems (however, Survey Creators do not currently require multi-factor authentication to access aggregated employee survey data – we are working on implementing this); and

• regularly backup data and test the restoration process to ensure data recoverability in case of any incidents.

 

However, we cannot guarantee the security of any personal information transmitted over the internet and therefore you disclose information to us at your own risk. We will not be liable for any unauthorised access, modification or disclosure, or misuse of your personal information. 

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   11. Contact information

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If you require further information regarding our Privacy Policy or wish to make a privacy complaint, please email us at [support@seenculture.com]

 

   12. Miscellaneous

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We reserve the right to modify this Privacy Policy in whole or in part from time to time without notice and amendments will be effective immediately upon posting of the amended Privacy Policy on the SeenCulture website.

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Date: 6 November 2024