NextPlay Search Privacy Policy

This Privacy Policy applies to all personal information collected by NextPlay Ventures Pty Ltd (ABN 70 674 228 712) ("we", "us" or "our") via the website located at www.nextplay.ai ("Website") and the NextPlay Hiring Portal ("Portal"), collectively referred to as the "Platform".

1. What information do we collect?

The kind of Personal Information that we collect from you will depend on how you use the Platform. The Personal Information which we collect and hold about you may include:

Website visitors:

• Your full name
• Email address

Portal users (clients):

• Your email address (required for account creation and authentication)
• Your full name (optional, if provided)
• Your profile photo (optional, if uploaded)
• Feedback, comments and assessments you provide on candidates through the Portal
• Usage data, including pages viewed, features accessed and time spent on the Portal
• Authentication logs, including magic link requests and session activity
• Device and browser information collected automatically when you access the Portal

Candidates:

• Professional and biographical information relevant to recruitment engagements, which may include name, contact details, employment history, education, skills, qualifications and other information provided by or about candidates in the course of a recruitment engagement
• Information sourced from publicly available sources in connection with recruitment services

2. What is Personal Information?

This policy concerns Personal Information as defined in the Privacy Act 1988 (Cth) ("Privacy Act").

Personal Information means information or an opinion about an identified individual or an individual who is reasonably identifiable:

(a) whether the information or opinion is true or not; and

(b) whether the information or opinion is recorded in a material form or not.

If the information does not disclose your identity or enable your identity to be ascertained, it will in most cases not be classified as "Personal Information" and will not be subject to this privacy policy.

3. How we collect your Personal Information

(a) We may collect Personal Information from you whenever you input such information into the Platform or provide it to us in any other way, including when you:

(i) visit the Website and submit a contact or enquiry form;

(ii) are invited to and create an account on the Portal;

(iii) provide your name or upload a profile photo to the Portal;

(iv) submit feedback, comments or assessments on candidates through the Portal; or

(v) communicate with us by email, telephone or other means.

(b) We collect Personal Information about candidates from a variety of sources, including directly from candidates, from publicly available sources, and from our clients in the course of recruitment engagements.

(c) We may also collect cookies and similar tracking technologies from your device which enable us to understand how you use the Platform and to help customise your experience. As a general rule, however, it is not possible to identify you personally from our use of cookies alone.

(d) We collect authentication data automatically when you request a magic link to access the Portal. This includes your email address, the time of the request and session information. No passwords are collected or stored.

(e) We do not generally collect sensitive information (as defined in the Privacy Act). Where we hold it, we handle it in accordance with the Privacy Act.

(f) Where reasonable and practicable we collect your Personal Information from you only. However, sometimes we may be given information from a third party. In cases like this we will take steps to make you aware of the information that was provided by a third party.

4. Purpose of collection

(a) We collect and use Personal Information for the following purposes:

(i) to provide you with access to and use of the Platform, including the Portal;

(ii) to facilitate recruitment engagements, including presenting candidate information to clients through the Portal and collecting client feedback on candidates;

(iii) to authenticate your identity and manage your Portal account;

(iv) to communicate with you about our Services, including recruitment updates, engagement progress and Platform notifications;

(v) to improve and develop the Platform and our Services, including through analysis of usage data and feedback;

(vi) to comply with our legal obligations; and

(vii) to keep in touch with you about developments in our business.

(b) We may share your Personal Information with third-party service providers who assist us in operating the Platform, delivering our Services and conducting our business. This may include providers of hosting and cloud infrastructure, email delivery, analytics, customer support and other operational services. These providers are only permitted to use your Personal Information for the purposes of providing their services to us and are required to handle your information in accordance with applicable privacy laws.

(c) Your Personal Information may also be exposed from time to time to maintenance and support personnel acting in the normal course of their duties.

(d) Disclosure of candidate information to clients: In the course of recruitment engagements, we disclose candidate Personal Information to clients through the Portal for the purpose of evaluating candidates for relevant roles. Clients access this information subject to the Terms and Conditions governing use of the Portal, which include confidentiality obligations.

(e) NextPlay Intelligence: We also operate NextPlay Intelligence, a separate research platform. The information in that platform is collected from publicly available sources. Information provided to us in the course of recruitment engagements, such as resumes, interview discussions and client briefs, is not added to that platform. An individual may appear in that platform only where their professional information is publicly available.

(f) By using our Platform, you consent to the receipt of direct marketing material. We will only use your Personal Information for this purpose if we have collected such information direct from you, and if it is material of a type which you would reasonably expect to receive from us. Our direct marketing material will include a simple means by which you can request not to receive further communications of this nature, such as an unsubscribe link.

5. Automated processing

We use technology, including artificial intelligence, to assist in organising and summarising candidate information and preparing assessments in the course of recruitment engagements. These outputs assist our team and our clients: they are reviewed and acted on by people, and do not by themselves determine any outcome for an individual.

6. Security, access and correction

(a) We store your Personal Information in a manner that reasonably protects it from unauthorised access, misuse, modification or disclosure. Security measures include:

(i) passwordless authentication via magic links, which expire after a limited period and are valid for single use only;

(ii) access controls that restrict Portal access to authorised users within a client organisation;

(iii) encryption of data in transit; and

(iv) regular review of our data handling and security practices.

(b) When we no longer require your Personal Information for the purpose for which we obtained it, we will take reasonable steps to destroy, anonymise or de-identify it. Most of the Personal Information that is stored in our records will be kept for a maximum of 5 years to fulfil our record keeping obligations, unless a longer retention period is required by law or a continuing business purpose.

(c) The Australian Privacy Principles:

(i) permit you to obtain access to the Personal Information we hold about you in certain circumstances (Australian Privacy Principle 12); and

(ii) allow you to correct inaccurate Personal Information subject to certain exceptions (Australian Privacy Principle 13).

(d) Where you would like to obtain such access or request correction, please contact us in writing using the contact details set out at the bottom of this privacy policy.

(e) If you are a Portal user, you may update your name and profile photo directly within the Portal at any time. To request deletion of your Portal account and associated data, please contact us using the details below.

7. Candidate rights

(a) If you are a candidate whose Personal Information we hold, you have the right to:

(i) request access to the Personal Information we hold about you;

(ii) request correction of any inaccurate or out-of-date information; and

(iii) exercise any other right in relation to your Personal Information that you have under applicable privacy laws.

(b) To exercise any of these rights, please contact us using the details set out at the bottom of this privacy policy.

8. Complaint procedure

If you have a complaint concerning the manner in which we maintain the privacy of your Personal Information, please contact us using the contact details set out at the bottom of this policy. All complaints will be considered by NextPlay Ventures Pty Ltd and we may seek further information from you to clarify your concerns. If we agree that your complaint is well founded, we will, in consultation with you, take appropriate steps to rectify the problem. If you remain dissatisfied with the outcome, you may refer the matter to the Office of the Australian Information Commissioner.

9. Overseas transfer

Some of our service providers, including our hosting and technology providers, store or process information in countries outside Australia, principally the United States. Where we disclose Personal Information to overseas providers, we take reasonable steps, including contractual requirements, to ensure that it is handled consistently with the Australian Privacy Principles.

10. Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes to our practices, technology or legal requirements. We will use reasonable endeavours to notify you of material changes, including by posting a notice on the Platform. Your continued use of the Platform following the posting of changes constitutes your acceptance of those changes.

11. How to contact us about privacy

If you have any queries, if you seek access to your Personal Information, or if you have a complaint about our privacy practices, you can contact us through: support@nextplay.ai.