Privacy Policy

1. Introduction

This Privacy Policy has been developed to outline People2.0's commitment to protect and manage Personal Information. It describes the information that may be collected by People2.0, the choices an individual can make to access and correct their Personal Information and how People2.0 protects and discloses Personal Information.

For the purpose of this policy, People2.0 includes all its affiliates, related parties, employees and personnels who may be handling Personal Information of individuals for and on behalf of People2.0.

People2.0 respects the Personal Information and the right to privacy of individuals including employees, prospective employees/candidates, Independent Professionals (IPros) and/or contractors, vendors, service provider personnels, customers, job applicants, shareholders, investors, clients and prospective client's contractors, including their representatives, authorised persons and any personnel or employee who may share their Personal Information with the company (hereinafter referred to as "Individuals"). Protecting privacy when handling Personal Information is very important to People2.0 and is fundamental to the way the company services everyone.

Personal Information means and includes any information that People2.0 holds about an Individual from which such Individual's identity is either apparent or can be reasonably determined.

This Privacy Policy applies to:

1. online websites operated by People2.0, which are used to provide access to information about our services and products;
2. 'Entity Online' (online Portal service);
3. 'Entity Mobile' (mobile phone application) which allows users to provide information and conduct certain transactions using electronic means;
4. Internal information management of Individuals; and
5. Any documents, agreements, forms or processes of People2.0 to which this policy is appended such as consent forms signed by candidates in recruitment process etc.

By visiting the websites, Entity Online or Entity Mobile of People2.0 or otherwise providing us with your Personal Information, you are accepting the practices of People2.0 with respect to the collection, storage and use of Personal Information.

2. Privacy Collection Statement

Personal Information is collected in accordance with local laws and may be sought from you when you:

1. apply for an available position;
2. are requested to provide Personal Information during an interview;
3. complete forms and provide documents when onboarding;
4. request information from People2.0;
5. provide any Personal Information to People2.0;
6. download certain documents and information;
7. register for a demonstration of certain products or services;
8. sign up or subscribe to a newsletter; or
9. various forms of business transactions.

Examples of Personal Information or sensitive Personal Information that People2.0 collects, includes names, addresses, email addresses, phone, emergency contacts, bank details, superannuation, national ID, biometric information and all information related to remuneration including bonuses and salary.

People2.0 may also collect statistical information regarding the use of its website or portal. The information collected includes the visitor's computer Internet Protocol (IP) address, the date and time of the visit, previous site visited and browser type. This information is collected to provide People2.0 with information about users, to help maintain and develop, to provide better information to users of the website, Entity Online or Entity Mobile.

People2.0's website and Entity Online use cookies for the purposes of session tracking. However, People2.0 does not collect any Personal Information from the cookies, including any habits when accessing the website or Entity Online.

Personal Information collected by People2.0 is for the primary purpose of providing services, and product information to certain Individuals. Personal Information may also be used for the following purposes:

1. To discharge any statutory or reporting obligations;
2. To provide information to you about People2.0's products and/or services;
3. To contact you and respond to your queries;
4. To enforce rights and to fulfil obligations under any agreement between People2.0 and its clients;
5. To enforce rights and to fulfil obligations under any agreement between you and People2.0;
6. To record statistical data for marketing analysis;
7. Any other purpose which is permitted under any agreement between you and People2.0;
8. Any purpose related to or in connection with employment of any Individuals;
9. For internal operational purposes of People2.0 or its clients such as record keeping, accounting and compliance with applicable taxation laws;
10. To comply with applicable law; and
11. To investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, or as otherwise required by law.

While People2.0 will endeavour to collect Personal Information directly from you, People2.0 may collect some of the Personal Information indirectly from others, such as the clients or prospective clients of People2.0, or your employer. Where People2.0 collects Personal Information about you from a third party, we will take reasonable steps, as soon as reasonably practicable, to notify you of:

• the fact that your Personal Information has been collected and the types of information involved;
• the purpose of collection;
• the parties or types of parties to whom the information may be disclosed;
• our identity and contact details; and
• your rights to access and correct your Personal Information.

We may rely on a third party to provide this information where we reasonably believe you have already been notified.

We may not provide notification where an exception applies under the New Zealand Privacy Act 2020 or where the third party from whom we receive your information has already notified you of the fact that such information will or has been shared with us.

If at any time you provide Personal Information about another individual to People2.0 you must ensure that the individual has read and understood this policy and separately consented to that Personal Information being used and disclosed by People2.0 for the purpose set out in this policy.

3. Disclosure

People2.0 trusts your discretion and judgement to provide Personal Information, and upholds the promise that Personal Information will not be disclosed except as follows:

1. Disclosure to Clients and Third Parties
   

   a) People2.0 may disclose Personal Information relating to employees, Independent Professionals (IPros) and contractors to its clients where those individuals are engaged to perform services for, or on behalf of, the client. Such disclosure is limited to information that is reasonably necessary to facilitate the delivery of services, including workforce engagement, onboarding, payroll, compliance, time and attendance, invoicing, and related operational purposes.

   b) Clients may, in turn, disclose such Personal Information to their own third-party service providers, including affiliated entities, professional advisers, technology providers, payroll providers, benefits administrators, banks and financial institutions, or other subprocessors, where required to support service delivery or to comply with applicable legal, regulatory or contractual obligations. People2.0 takes reasonable steps to ensure that disclosures are subject to appropriate confidentiality, data protection and security safeguards, consistent with applicable privacy and data protection laws.

2. Disclosure to agents and service providers
   

   a) People2.0 may disclose Personal Information, on a confidential basis, to agents and service providers that People2.0 uses in the ordinary operation of its business.

   b) People2.0 may also disclose Personal Information to People2.0's agents, contractors or third party service providers that process or will be processing your Information, on behalf of People2.0, including but not limited to those which provide administrative or other services to People2.0 such as mailing houses, telecommunication companies, information technology companies and data centres and third parties, such as service providers, to whom disclosure by People2.0 is for one or more of the purposes outlined in this policy and such third parties would in turn be collecting and processing your Information including Personal Information for one or more of the said purposes.

   c) People2.0 may disclose your information to other third parties where you consent to the use or disclosure.

3. Disclosure to Third-Party Platforms for Payroll and Related Services
   

   People2.0 uses third-party platforms and service providers to process payroll and deliver related workforce services, including payments, statutory deductions, tax reporting, benefits administration and compliance obligations. In doing so, People2.0 may disclose Personal Information to such third-party providers where reasonably necessary for these purposes. People2.0 takes reasonable steps to ensure that these providers are subject to appropriate contractual obligations regarding confidentiality, data protection and information security, in accordance with applicable privacy and data protection laws.

4. Disclosure required by law
   

   People2.0 may disclose your Personal Information where required or authorised by law.

Note:People2.0 may also use this Personal Information for secondary purposes closely related to the primary purpose, in circumstances where it would be reasonable to expect such use or disclosure. Personal Information that is "Sensitive Information" will not be disclosed without your consent.

4. Spam

When communicating electronically with any Individuals, People2.0 follows all local laws.

a – Consent
The company will only send commercial electronic messages with the addressee's consent — either express or inferred consent.

b – Identify
The company will include clear and accurate information about the person or business that is responsible for sending the commercial electronic message.

c – Unsubscribe
The company will ensure a functional unsubscribe facility is included in all commercial electronic messages and deal with unsubscribe requests promptly. Individuals can unsubscribe from mailing/marketing lists at any time by advising People2.0 (seeContact People2.0details on this page), or by following the steps outlined in the email communication.

5. Anonymity

Subject to an agreement to the contrary, you are not required to provide People2.0 with your Personal Information. However, the services and products offered by People2.0 rely on such information. If you do not provide your Personal Information, then People2.0 may not be able to engage you or provide services to you.

6. Security of Personal Information

Personal Information is stored in a manner that reasonably protects it from misuse, loss, unauthorised access, modification or disclosure in compliance with the applicable laws. The information is stored on secure servers, at a data warehouse, onsite, or at an external archiving facility. People2.0 employees are obliged to respect the confidentiality of any Personal Information held by People2.0.

However, security of communications cannot be guaranteed, and therefore absolute assurance that information will be secure at all times cannot be given. To the extent permitted by law, People2.0 does not accept responsibility for events arising from unauthorised access to Personal Information.

When Personal Information is no longer needed for the purpose for which it was obtained, the company will take reasonable steps to destroy or permanently de-identify Personal Information. However, most of the Personal Information is or will be stored in files which will be kept by the company for a minimum of seven (7) years.

External Service Provider
The websites Entity Online and Entity Mobile of People2.0 and its electronic mail servers may be managed by a third-party hosting service provider. When you access the websites, portals or mobile application of People2.0 or transmit electronic mail to People2.0, you may be communicating with a third party's server.

People2.0 and links to other websites
People2.0's website may contain links to other websites. These linked sites are not under the control of People2.0. People2.0 is not responsible for the information handling practices, conduct or the content of those sites.

Unsolicited Personal Information
If People2.0 receives Personal Information that the company did not solicit, the company will as soon as possible (and only if lawful to do so), destroy the information or ensure that the information is de-identified.

7. Access to Personal Information

People2.0 will, upon request, and subject to applicable privacy laws, provide Individuals access to Personal Information held by People2.0. If making a request, we ask that the type/s of Personal Information requested is clearly listed in writing and sent to your relevant People2.0 representative or by contacting the People2.0's Privacy Officer (seeContact People2.0details on this page).

The company will deal with the request in a reasonable timeframe and in most instances within 30 days of receipt of a request. In order to protect Personal Information, People2.0 will require identification before releasing such information. Personal Information sought by spouses or other third parties requires written authority by the individual the information is being sought for prior to making such a request. If the evidence is insufficient People2.0 may deny the request.

People2.0 will not charge for lodging a request but may recover reasonable costs incurred in supplying the information.

Exceptions:

The right to access Personal Information is not absolute. In certain circumstances the company may refuse a request for information, such as circumstances where:

• Access would pose a serious threat to the life or health of any individual;
• Access would have an unreasonable impact on the privacy of others;
• The request is frivolous or vexatious;
• The information relates to a commercially sensitive decision-making process;
• Access would be unlawful; or
• Access may prejudice enforcement activities, a security function or commercial negotiations.

8. Changes to or Deletion of Personal Information

You may review, correct, update, or change your Personal Information by emailing People2.0 atcompliance.apac@people20.com. You may also request People2.0 to delete your Personal Information, and People2.0 will comply with such requests within a reasonable time, unless the company is required to keep certain information for legal purposes.

9. Privacy Laws

People2.0 complies with the relevant legislation in each country it operates in:

10. Freedom of Information Laws (for data subjects in Australia)

In Australia, in addition to Privacy Laws, individuals may have rights to access their Personal Information contained in certain company documents. Details on how to apply for access to these documents are contained in the Freedom of Information Act 1982 (FOI Act).

11. Quality of Personal Information

It is an important part of providing services to our clients that Personal Information is up to date and the company takes reasonable steps to make sure that Personal Information is accurate, complete and up-to-date.

It is important that individuals advise People2.0 at the earliest opportunity of any changes to Personal Information so that People2.0's records can be updated. This can be done by contacting your relevant People2.0 representative or by contacting People2.0's Privacy Officer (seeContact People2.0details on this page).

12. Consequences of Breach of Privacy and Personal/Sensitive Information

Individuals (employees, IPros and/or contractors) are expected to act in a manner consistent with the matters set out in this policy where they have a responsibility with respect to Personal Information. Failure to do so may subject individuals to disciplinary action, and may result in warning letter, demotion or termination depending on the level or seriousness of the breach.

If anyone suspects or is aware of a breach of privacy, they have an obligation to report this breach to the People2.0's Privacy Officer so immediate action can be taken to eradicate the situation. Contact details of the Privacy Officer are provided in this policy under "Contact People2.0".

13. Policy Updates

This Privacy Policy may change from time to time. People2.0's Privacy Policy is available at the People2.0 offices, intranet, portal or website. People2.0 reserves the right to make changes to this Privacy Policy from time to time as business or technical needs require.

14. Complaints Procedure

An individual may make a complaint if they feel their Personal Information has been handled inappropriately by People2.0 and is in breach of People2.0's privacy obligations.

In the first instance, complaints must be directed to People2.0's Data Protection Officer in writing. People2.0 will investigate the complaint and prepare a response to the complainant in writing within a reasonable period of time.

If the complainant is not satisfied with People2.0's response or the manner in which People2.0 has dealt with the complaint, the individual may make a formal complaint to the relevant authority in their country.

Contact People2.0

Individuals are requested to alert People2.0 of any practices that breach local laws, to enable the situation to be remedied. People2.0 is committed to obtaining fair resolutions of any complaint or concern about privacy.

Please contact the People2.0 Data Protection Officer with a compliment, complaint or privacy question, via the following means: