Privacy Policy

1. Introduction

NEOFind.ai ("NEOFind", "we", "us" or "our") is an AI-powered people search and discovery platform that helps organisations discover and engage with job candidates. NEOFind.ai is operated by NEO Global Pty Ltd, an Australian company and part of the NEO Global group.

This Privacy Policy explains how we collect, hold, use and disclose personal information in connection with our websites, applications and services (together, the "Services"), and how you can exercise your privacy rights. It applies to job candidates whose professional information appears in our platform, to visitors to our websites, and to users of our Services.

We handle personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles ("APPs"), and, where applicable, the EU and UK General Data Protection Regulation ("GDPR"), the California Consumer Privacy Act as amended ("CCPA"), and other applicable privacy laws.

2. Personal Information We Collect

2.1 Public information about job candidates

We collect professional information about individuals from publicly available sources, such as public professional profiles, company websites, publications and resumes made available online. This may include:

• first and last name;
• education history;
• professional or employment-related qualifications (such as years of experience, publications, and skills);
• work history and current or former job titles;
• contact information (such as business email address and phone number); and
• general geographic location (such as city, state or country).

We do not intentionally collect sensitive information (such as health information, racial or ethnic origin, religious beliefs, political opinions, sexual orientation, or trade union membership) from public sources, and we do not use such information in our Services.

2.2 Information you provide to us

When you visit our websites, register for an account, or otherwise interact with us, we collect information you provide directly, including business contact details (name, employer, job title, email address, phone number), account credentials, billing and payment information, the contents of your communications with us, marketing preferences, and any other information you choose to provide.

2.3 Information collected automatically

When you use our websites or Services, we and our service providers automatically collect certain information using cookies and similar technologies, including device data (operating system, device manufacturer and model, browser type, IP address, and approximate location derived from IP address) and usage data (pages viewed, time spent on pages, navigation paths, and access times). See Section 7 (Cookies and Tracking) for more information.

2.4 Information from other sources

We may receive information about you from third parties, including our group companies, marketing partners and data providers, for example to keep our records accurate and up to date or to identify prospective customers.

3. How We Use Personal Information

3.1 Job candidate information

We use candidate information to help our customers discover and engage with internal and external job candidates and to analyse attributes of existing personnel or internal talent. Where the GDPR applies, we rely on our legitimate interest in operating and providing our recruitment search platform as the legal basis for this processing.

3.2 Website visitor and customer information

We use the information described in Sections 2.2 to 2.4 to:

• provide the Services and perform our contractual obligations;
• communicate with you about the Services and provide customer support;
• improve, monitor, personalise and protect the Services;
• carry out research and development, including creating de-identified or aggregated data;
• send direct marketing communications, where permitted by law (you can opt out at any time);
• perform analytics and, where permitted, interest-based advertising; and
• comply with our legal obligations and protect our rights and the rights of others.

4. How We Disclose Personal Information

We disclose personal information to:

• Customers. We disclose job candidate information to our customers for talent sourcing and recruitment purposes.
• Group companies. We may share information within the NEO Global group for the purposes described in this policy.
• Service providers. We engage third parties to provide hosting, communications, security, billing, analytics and artificial-intelligence services Anthropic. We do not allow these providers to train their AI models using your personal information, and we require them to delete personal information within 30 days unless a longer period is required by law.
• Professional advisers. Lawyers, auditors, accountants, bankers and insurers, where necessary.
• Government authorities and law enforcement. Where we believe disclosure is required or appropriate under applicable law.
• Business transaction participants. In connection with an actual or proposed merger, acquisition, financing, or sale of all or part of our business.

Some of these recipients may be located overseas. See Section 8 (International Data Transfers).

5. Your Rights and Choices

Subject to applicable law, you may:

• ask us for information about our collection and use of your personal information;
• request access to the personal information we hold about you, including in a portable, machine-readable format;
• request correction of inaccurate or out-of-date personal information;
• request deletion of personal information we no longer need;
• ask us to remove your information from our candidate database and/or opt out of its disclosure ("sale" or "sharing") to customers;
• object to, or ask us to restrict, our use of your personal information; and
• appeal a decision we make about a privacy request.

To exercise any of these rights, contact us at privacy@joinneo.com. We may need to verify your identity before acting on your request. We will respond within the timeframe required by applicable law (and in any event within 30 days where the Privacy Act applies, unless a longer period is permitted). We will not discriminate against you for exercising your rights.

5.1 Marketing communications

You can opt out of marketing emails at any time by using the unsubscribe link in the email or by contacting us at privacy@joinneo.com.

5.2 Online tracking choices

You can manage optional cookies through the cookie preferences link in our website footer, configure your browser to reject cookies, or use an opt-out preference signal such as Global Privacy Control, which we honour where required by law. You can also opt out of certain third-party advertising cookies via the Network Advertising Initiative and Digital Advertising Alliance opt-out pages.

6. Data Retention

We retain personal information only for as long as necessary to fulfil the purposes for which it was collected and processed, in accordance with our retention policies and applicable laws, or until you ask us to delete it or withdraw your consent (where applicable). In determining retention periods, we consider the amount, nature and sensitivity of the information, the potential risk of harm from unauthorised use or disclosure, the purposes for which we use the information and whether those purposes can be achieved by other means, and applicable legal and regulatory requirements. When personal information is no longer required, we take reasonable steps to destroy or de-identify it in accordance with APP 11.2.

7. Cookies and Tracking

We use cookies and similar technologies to operate our websites, remember your preferences, analyse usage (including via Google Analytics) and, where permitted, deliver interest-based advertising. Where required by applicable law, we rely on your consent for non-essential cookies; otherwise we rely on our legitimate business interests. Detailed information is set out in our Cookie Policy at https://neofind.au/cookie-policy

8. International Data Transfers

We are based in Australia and use service providers located in Australia, the United States and other jurisdictions, so your personal information may be transferred to, stored in and processed in countries other than your own.

Where we disclose personal information overseas, we take reasonable steps as required by APP 8 to ensure the recipient handles it consistently with the APPs. For transfers of personal information originating in the EEA, the United Kingdom or Switzerland, we rely on an adequacy decision of the EU Commission or UK government or on appropriate contractual protections, such as the EU Standard Contractual Clauses and the UK Addendum or International Data Transfer Agreement.

9. Additional Information for Australia

We handle personal information in accordance with the Privacy Act 1988 (Cth) and the APPs. You may complain about our handling of your personal information by contacting us at privacy@joinneo.com; we will investigate and respond within a reasonable period. If you are not satisfied with our response, you may complain to the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au.

If a data breach occurs that is likely to result in serious harm to individuals, we will notify affected individuals and the OAIC in accordance with the Notifiable Data Breaches scheme.

10. Additional Information for the EEA, UK and Switzerland

If you are located in the European Economic Area, the United Kingdom or Switzerland, NEO Global Pty Ltd is the controller of your personal information. Our legal bases for processing are: performance of a contract (where we provide the Services to you); our legitimate interests (including operating and providing our recruitment search platform, securing and improving the Services, and marketing to business contacts); your consent (where required, for example for non-essential cookies); and compliance with legal obligations.

In addition to the rights in Section 5, you have the right to withdraw consent at any time (without affecting prior processing) and the right to lodge a complaint with your local data protection authority.

Where we receive information from Google APIs, our use and transfer of that information will adhere to the Google API Services User Data Policy, including the Limited Use requirements. We do not use Google Workspace API data to develop, improve or train generalised AI and/or machine-learning models.

11. Additional Information for California Residents

This section applies to residents of California and supplements the rest of this Privacy Policy. In the preceding 12 months we have collected the following categories of personal information as described in Section 2: identifiers (such as name, email address and IP address); professional or employment-related information; commercial information (such as billing records); internet or other electronic network activity information; and geolocation data (approximate location derived from IP address). We collect this information from the sources, and use and disclose it for the purposes, described in Sections 2 to 4.

Our disclosure of candidate information to customers may constitute a "sale" or "sharing" under the CCPA. You may opt out by contacting privacy@joinneo.com or via the "Do Not Sell or Share My Personal Information" link in our website footer. We do not knowingly sell or share the personal information of consumers under 16 years of age.

California residents have the rights to know, access, correct, delete, and port their personal information, to opt out of sale/sharing, to limit the use of sensitive personal information, and not to be discriminated against for exercising these rights. You may exercise these rights as described in Section 5, including through an authorised agent.

12. Children's Privacy

Our Services are not intended for use by anyone under 16 years of age, and we do not target our Services at, or knowingly collect personal information from, individuals under 16. If we learn that we have collected personal information from an individual under 16, we will take reasonable measures to promptly delete it.

13. Security

We employ technical, organisational and physical safeguards designed to protect the personal information we collect, appropriate to its nature and sensitivity. However, no security measures are failsafe, and we cannot guarantee the absolute security of your personal information.

14. Third-Party Sites and Services

Our websites and Services may contain links to third-party sites and services. This Privacy Policy does not apply to those third parties, and we are not responsible for their privacy practices. We encourage you to review their privacy policies.

15. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. If we make material changes, we will notify you via our website and, where required by law, by email, before the changes take effect. The "Last updated" date at the top of this policy indicates when it was most recently revised.

16. Contact Us

If you have questions, requests or complaints about this Privacy Policy or our handling of personal information, contact us at:

NEO Global Pty Ltd (operator of NEOFind.ai)

39 Martin Pl, Sydney, NSW 2000, Australia

Australia

Email: privacy@joinneo.com

For appeals of decisions relating to privacy rights requests, please use the subject line "Appeal of Decision Related to Privacy Rights Request".