We are committed to respecting your privacy and complying with our privacy obligations in accordance with all applicable data protection laws, including the Australian Privacy Principles contained in Schedule 1 to the Privacy Act 1988 (Cth) (the “Privacy Act“) . We also comply with the EU General Data Protection Regulation (“GDPR”) in relation to all personal data that we process (“GDPR Data“).

This Privacy Policy sets out our policy on the collection, use and disclosure of personal data of users of our recruitment tools (collectively, our “Cloud Services“) in accordance with our statutory obligations under the Privacy Act . It also describes:

• The period for which we store personal data;
• Your rights to access and rectify or to request erasure of personal data;
• Your right to withdraw consent to the processing of personal data;
• The right to lodge a complaint with the Office of the Australian Information Commissioner (or in the case of the GDPR, the relevant supervisory authority);
• Why we collect and process personal data, the categories of personal data that we process, and who we disclose it to;
• The types of automated decision making tools that we use;
• Details of the security measures that we take to help protect your personal data;
• Other information about how we collect, use, disclose and process personal data.

  This Privacy Policy sets out our policy on the collection, use and disclosure of personal data of users of our recruitment tools (collectively, our “Cloud Services“) in accordance with our statutory obligations under the Privacy Act . It also describes:

  • The period for which we store personal data;
  • Your rights to access and rectify or to request erasure of personal data;
  • Your right to withdraw consent to the processing of personal data;
  • The right to lodge a complaint with the Office of the Australian Information Commissioner (or in the case of the GDPR, the relevant supervisory authority);
  • Why we collect and process personal data, the categories of personal data that we process, and who we disclose it to;
  • The types of automated decision making tools that we use;
  • Details of the security measures that we take to help protect your personal data;
  • Other information about how we collect, use, disclose and process personal data.

In this Privacy Policy, “personal data”  has the meaning given in the GDPR.

The Privacy Act defines “personal information” as 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.

Note: Section 187LA of the Telecommunications (Interception and Access) Act 1979 extends the meaning of personal information to cover information kept under Part 5‑1A of that Act.

Article 4(1) of the GDPR defines “personal data” as any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Our policy is to minimise the amount of personal data we collect. Accordingly, we only collect personal data that is adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.

We collect personal data that you give us, whether by online, email, telephone, in person, via application forms or otherwise. We may also obtain personal data directly from third parties such as our resellers, related companies, installers, sales agents and any of their representatives.  In addition, we may obtain personal data from public sources, where available including social media. However, if it is reasonable and practicable to do so, we will collect personal data about an individual only from that individual.

We will only collect personal data for specified, explicit and legitimate purposes and we will not further process personal data that we collect in a manner that is incompatible with those purposes. If you enter and/or upload into the Cloud Services and/or otherwise provide us with personal data about any person other than you, please notify us so that we can ensure that the data subjects are provided with the information required by Australian Privacy Principle 5 and Article 14 of the GDPR.

We will not collect personal information (other than sensitive information) unless the information is reasonably necessary for one or more of our entity’s functions or activities and we will not collect sensitive information unless you consent to the collection and the sensitive information is reasonably necessary for one or more of our functions or activities, or we collect it pursuant to subclause 3.4 of the Australian Privacy Principles. Please notify us if you are not of old enough or not otherwise able to provide us with consent, and if so do not provide us with any consent for the purposes of applicable privacy law.

We will not process any any data that is personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation, except where permitted by the Australian Privacy Principles and the GDPR.

Our policy is to minimise the amount of personal data we collect. Accordingly, we only collect personal data that is adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.

The personal data that we collect and how we use it is as follows:

• Job Applications: If you apply for a Job using Matchd then we will share the information you provide with the employer or recruitment agency that is recruiting. By applying for a Job you agree to share your details with the hiring team of the employer.
• Subscription/registration, payment, transaction and profile data: If you register or subscribe to our Cloud Services, we will collect and otherwise process the following categories of personal data: company details, names, telephone numbers, email addresses, credit card details. We will process this personal data in order to administer our end user subscriptions, registrations and accounts on the Cloud Services, for the purposes of providing our end users with access to and use of the Cloud Services, to enforce our end users’ obligations to pay the fees and charges to us and to otherwise enforce compliance by our end users with our Terms of Service and the contractual obligations that they owe to us. We will also process this personal data in order to provide our end users with information and assistance about the Cloud Services, and to communicate with our end users in connection with any maintenance notices (that we may issue when the Cloud Services are unavailable), renewal notices and service status updates for the purposes of keeping our end users informed and up to date about the status of our Cloud Services.
• Data entered into and/or uploaded into the Cloud Services by our Customers and/or end users when accessing the Cloud Services: We collect and process any personal data that our end users upload or enter into the Cloud Services either manually or via computer systems, smartphone devices and tablets, namely: names, telephone numbers, mobile numbers, email addresses, residential addresses, and work history, qualifications, skills and experience. The Cloud Services will also process any other personal information that our Customers and end users voluntarily enter or upload to MATCHD. We will process this personal data on behalf of our Customers and end users in our capacity as a processor in order to provide our Customers and end users with the Cloud Services and the functionality provided by the Cloud Services in accordance with their specific instructions (unless applicable law to which we are subject requires other processing of that personal data by us, in which case we will inform applicable Customers and end users of that legal requirement (unless that law prohibits us from doing so on important grounds of public interest). We will also process this personal data as a controller to monitor compliance with the terms and conditions of our Terms of Service, to maintain backups of our databases and to detect unauthorised use and faults with the Cloud Services (such as, by examining log files and error messages). The personal data will also be used to provide our end users with professional services (including technical support and training services) if and where required pursuant to our Terms of Service.
• Data relating to communications between us and our Customers and end users: When our end Customers and users contact us, we will collect and process personal data including the name of the Customer/end user, the IP address of the Customer/end user and any other personal data that Customers/end users provide to us during the communications. For example, our Customers and/or end users may contact us to ask questions about our Cloud Services, seek technical support or advice and to express their interest in subscribing to the Cloud Services or for the purposes of upgrading or modifying their accounts on our platform. We will process this personal data in order to provide our Customers and end users with information and assistance about the Cloud Services, and to communicate with them in connection with any breach, expiry, termination or suspension of the Cloud Services.
• Analytics data: We collect and process personal data known as analytics data for statistical and analytical purposes, designed to measure and monitor how our Cloud Services are being used and to highlight any areas for improvement, optimisation and enhancement of the Cloud Services, including user location, cookie data, the amount of time a user spent on our cloud platform and in which parts of the platform, and the path they navigated through the platform. We will process this personal data in order to monitor and detect unauthorised use of the Cloud Services and to establish how the Cloud Services are used and to highlight areas for potential improvement of the Cloud Services. We often aggregate this data with other data. However, where the data is classified as personal information (or in the case of GDPR Data, personal data) we treat it in accordance with this Privacy Policy.
• Cookies: We use cookies on MATCHD. However, we will not use cookies with a Customers and/or end users account on Matchd without express consent, unless the cookies are strictly required in order for us to provide the Cloud Services. Cookies are pieces of information that a web site transfers to a computer’s hard disk for record-keeping purposes. This helps us tailor and improve the information we present to you, promoting higher end user satisfaction when you visit our site. The use of cookies is common in the Internet industry, and many major web sites use them to provide useful features to their end users. A cookie may be used to tell when your computer or device has contacted MATCHD. Cookies may also be used to personalise your experience with us. Where we request your consent for a cookie we will explain to you what the cookie is proposed to be used for, what information it collects, and give you an opportunity to withdraw your consent to the placement of the cookie on your machine or device if you do consent. You may configure your web browser on your computer or device to reject or block cookies if you wish. If we request your consent to a cookie and you consent to our use of the cookie, you may withdraw your consent to our use of the cookie on your computer or device at any time by contacting us.

We only disclose personal data to third parties who perform services on our behalf to the extent necessary for them to perform those services. We do not sell personal data to third parties for their own marketing purposes and we only disclose the minimum amount of personal data required. We may disclose personal data that we collect to third parties for all or any of the following purposes:

• To provide you with the Cloud Services – in which case we disclose your personal data to our upstream hosting suppliers who host Matchd and the personal data that you enter into and/or upload in to the Cloud Services. Our hosting suppliers host that personal data on their computer servers;
• So that we can obtain assistance with the provision of the Cloud Services – in which case we may disclose your personal data to members of our corporate group who we may subcontract the provision of all or part of the Cloud Services to;
• Conducting publicity campaigns – in which case we may disclose your personal data to our marketing suppliers;
• Handling claims and complaints – in which case we may disclose your personal data to our lawyers and insurers;
• Sending out a newsletter – in which case we may disclose your personal data to our email and newsletter service providers;
• In order to identify our Customers and end users – when we are contacted with questions or concerns regarding the products and services we provide;
• In order to configure a new service for our Customers and end users;
• In order to record billing details – in which case we provide your bank account and credit card details to our bank and merchant facility providers;
• In order to interface with third party platforms – where you configure your account on MATCHD or use the Cloud Services to do so – in which case we will disclose personal data that you upload or enter into MATCHD as necessary for that interfacing to occur;
• For professional advice – when providing information to our legal, accounting or financial advisors/representatives or debt collectors for debt collection purposes or when we need to obtain their advice, or where we require their representation in relation to a legal dispute;
• If we sell the whole or part of our business of MATCHD or merge with another entity – in which case we will provide to the purchaser or other entity the personal data that is the subject of the sale or merger;
• Where required by law.

We may also provide your personal data to our lawyers, insurers and professional advisors and any court or administrative body, for one or more of the following purposes:

• For the purposes of obtaining professional advice;
• To obtain or maintain insurance;
• The prevention, detection, investigation, prosecution or punishment of criminal offences, breaches of a law imposing a penalty or sanction or breaches of a prescribed law;
• To protect or enforce our rights or defend claims;
• Enforcement of our claims against you or third parties;
• The enforcement of laws relating to the confiscation of the proceeds of crime;
• The protection of the public revenue;
• The prevention, detection, investigation or remedying of seriously improper conduct or prescribed conduct;
• The preparation for, or conduct of, proceedings before any court or tribunal, or implementation of the orders of the court or tribunal.
• Where disclosure is required to protect the safety or vital interests of employees, end users or property.

You may interact with social media platforms via social media widgets and tools such as the Facebook Like button and the Facebook pixel that may be installed on MATCHD. These widgets and tools may collect your IP address and other personal data. Your interaction with such widgets and tools, and any single sign-on services such as Open ID is governed by the privacy policies of the relevant social media operators and single sign-on service providers – please read them so that you are aware of how they process your personal data.

We take our privacy obligations very seriously. Accordingly, we only process personal data in a manner that ensures appropriate security of the personal data, including by protecting the personal data against unauthorised or unlawful processing and against accidental loss, destruction or damage using appropriate technical or organisational measures.

The technical and organisational measures that we have implemented are as follows:

• We maintain physical security measures in our buildings and offices such as door and window locks and visitor access management, cabinet locks, surveillance systems and alarms.
• We require all of our employees and contractors to comply with privacy and confidentiality terms and conditions in their employment contracts and subcontractor agreements.
• We carry out security audits of our systems which seek to find and eliminate any potential security risks in our electronic and physical infrastructure as soon as possible.
• We have a Data Breach Response Plan in place.
• We have data backup, archiving and disaster recovery processes in place.
• We have anti-virus and security controls for email and other applicable computer software and systems in place.
• We have processes in place to ensure integrity and resilience of systems, servers and personal data.

MATCHD includes privacy tools that you can use to control how we process personal data that you upload and/or enter into MATCHD for us to process on your behalf. You can access these privacy tools by configuring your account on MATCHD at the following URL: https://app.matchd.com

You can only browse limited pages of MATCHD without registering as a subscriber or user of MATCHD, such as the pages that generally describe the services that we make available through MATCHD, and our Contact Us page. However, when you subscribe or sign-up to MATCHD, we need to collect personal data from you in order to identify you and setup an account for you on MATCHD. We will also collect personal data from you when you use the Cloud Services when you enter the personal data into MATCHD, when you contact us for technical support and assistance with your account, when gathering analytics data about your use of MATCHD and for the other purposes set out above in the Privacy Policy. It is not practical for us to provide you with the Cloud Services if you refuse to provide us with personal data.

We will only engage new third parties to process GDPR Data entered into and/or uploaded into the Cloud Services by you for us to process as a processor on your behalf (“subprocessors“) if you have authorised us to do so pursuant to a specific or general written authorisation and otherwise in compliance with the requirements of the GDPR.

We will not transfer GDPR Data about a person to any country or organisation outside of the European Union, except: 

• as reasonably necessary for us to provide or procure the provision of the Cloud Services; or
• as instructed by the person.

Unless otherwise agreed in writing by a data subject, any transfer by us of personal data that a data subject uploads and/or enters into the Cloud Services for us to process on their behalf (which is the subject of the GDPR) outside the European Union will not be carried out unless we have taken such measures as are necessary to ensure the transfer complies with all applicable data protection laws. This may include (without limitation) transferring pursuant to the standard contractual clauses approved by the European Commission (including those clauses annexed to Commission decision of 5 February 2010 (2010/87/EU) as amended or superseded), or transferring to a country or organisation in a country outside the European Union that the European Commission has determined provides adequate protection for personal data.

Where the personal data is not GDPR Data and is personal information for the purposes of the Privacy Act, within the 30 day period following the Processing Conclusion Date instead of destroying the personal information we will take such steps as are reasonable in the circumstances to de-identify the personal information that we hold about an individual where we no longer need it for any purpose for which it may be used in accordance with this Privacy Policy if the information is not contained in a Commonwealth record and we are not required by Australian law (or a court or tribunal order) to retain it.

Subject to the provisions and exceptions set out in the Privacy Act and GDPR, under the Privacy Act and/or GDPR, you have a number of rights, including:

• the right to request from us access to and rectification or erasure of your personal data or restriction of processing concerning your personal data;
• the right to object to the processing of your data;
• the right to data portability;
• the right to withdraw consent (where you have consented to the processing of your personal data for one or more specific purposes);
• the right to lodge a complaint with the Office of the Australian Information Commissioner or any supervisory authority;
• the right to not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or it similarly significantly affects you.

Please contact us if you wish to opt out of any communications that we send you or if you wish to exercise any of your rights under the GDPR. We will handle all such requests in accordance with our legal obligations.  If you withdraw your consent for processing, object to the processing of your personal data or request us to erase your personal data and as a result it is not possible or practical for us to continue providing you with the Cloud Services, we may terminate your subscription and/or access to MATCHD and charge you any applicable cancellation/termination fees in accordance with our Terms of Service.

MATCHD is licensed and operated by M Software Pty Ltd. If you wish to contact us for any reason regarding our privacy practices or the personal data that we hold about you, please contact us at the following address:

If you are not satisfied with the outcome of a complaint you make refer the complaint to the Office of the Australian Information Commissioner (OAIC) who can be contacted using the following details:

Call: 1300 363 992
Email: enquiries@oaic.gov.au
Address: GPO Box 5218, Sydney NSW 2001

In relation to GDPR Data, you may lodge a complaint with any relevant supervisory authority.