Klose Recruit Privacy Policy

1.About this policy

This policy explains how Klose Recruit Pty Ltd (ABN 69 701 342 172, ACN 701 342 172) handles personal information. We trade as Klose Recruit. In this policy, "Klose", "we", "us" and "our" mean Klose Recruit Pty Ltd. We are a Queensland company based in Brisbane, Australia.

This policy covers:

• our website, getkloserecruit.com
• the Klose Recruit platform, including our AI assistant Kip, decision maker data from Apollo and live job ads (the "Platform")
• our sales, onboarding, support and marketing activities.

We handle personal information in line with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs). Section 15 explains how we handle personal data when the EU or UK General Data Protection Regulation (GDPR) applies.

Please read this policy with our Terms and Conditions at getkloserecruit.com/terms.

2.The two roles we play

When we decide how information is used. We collect and manage personal information about website visitors, people who book a demo, our customers' account contacts and users, and people on our marketing lists. This policy applies in full to that information.

When we act for our customers. Our customers are recruitment agencies. They upload and manage candidate, client and contact records in the Platform ("Customer Data"). For Customer Data, we act on our customer's instructions. The agency decides what it collects, why it collects it and how long it keeps it. Under the GDPR, this makes us a "processor" and the agency the "controller".

If you are a candidate or a client contact of an agency that uses Klose Recruit, please contact that agency first. Their privacy policy applies to your information. If you contact us, we will pass your request to the agency where we can and help them respond.

3.What we collect

Demo and discovery call requests. When you book a call on our website, we collect your name, email, phone number, number of staff, industry or focus, the type of call you want, your preferred date and time and any notes you add. Our website host may also record your IP address and browser details with the form. A hidden field on the form helps us filter spam.

Customers and proposals. When your agency signs up, we collect your company name, ABN, business address, contact name, job title, email and phone number. We also keep your plan, number of users, subscription term, onboarding details, signed agreement and booking dates.

Platform accounts. For each user, we collect your name, work email, role, login details and settings. We may also collect usage records, such as when you log in and the features you use, plus your IP address, device and browser type, support messages and what you type into Kip.

Billing. We collect billing contact details and invoice records. If you pay by card, our payment provider processes the payment.

Website technical data. When you visit our website, our host Netlify receives standard technical information. This includes your IP address, browser type, the pages you request and the time of your visit. Our pages load fonts from Google Fonts, so your browser also connects to Google and shares your IP address and browser details with Google.

Marketing and communications. We keep records of emails, calls and meetings with you. If you interact with us on LinkedIn or Instagram, we may see your public profile and messages.

Decision maker data. The Platform lets customers find business contact details for decision makers at hiring companies. This data comes from Apollo.io ("Apollo"). It can include a person's name, job title, employer, work email, work phone number and LinkedIn profile link. If your details appear and you do not want them shown in the Platform, contact us. We will take reasonable steps to stop your details being shown in the Platform and tell you how to contact Apollo.

Live job ads. The Platform shows job ads from public job boards and other online sources. Job ads can include the name and contact details of a recruiter or hiring manager.

Sensitive information. We do not ask for sensitive information, such as health information or criminal records, for our own purposes. Agencies may store sensitive information about candidates in Customer Data, such as right to work or background check results. The agency must get any consent the law requires.

Dealing with us anonymously. You can ask us general questions without giving your name. We need your details to book a demo, set up an account or provide the Platform.

4.How we collect it

We collect personal information:

• directly from you, through our forms, emails, calls, meetings and agreements
• from your employer, for example when your agency adds you as a user
• from third parties, such as Apollo, public job ad sources, referrals and public business profiles
• automatically, through server logs and Platform usage records.

If we receive personal information we did not ask for and do not need, we will destroy it or make it anonymous where it is lawful and reasonable to do so.

5.How we use it

We use personal information to:

• respond to your enquiry and run demos and discovery calls
• prepare proposals, agreements and invoices
• set up, run, secure and support the Platform
• provide Kip, decision maker data and live job ads
• fix problems and improve the Platform
• send service messages, such as account, security and billing notices
• send marketing, if you have not opted out (see section 11)
• meet our legal, tax and accounting obligations
• protect our rights and prevent fraud or misuse.

We only use Customer Data to provide the Platform to the agency, follow its instructions, keep the Platform secure and meet our legal obligations.

We do not sell personal information.

6.AI processing and Kip

Kip is the AI assistant built into the Platform. When a user asks Kip a question, we send the request and the relevant Platform data to our AI model providers to create a response. This may happen through our Platform host, Base44.

• We choose AI providers that offer data protection terms for business customers.
• AI output can be wrong or incomplete. Users should check it before they rely on it.
• Kip helps users with their work. Agencies and their staff remain responsible for hiring and other decisions about people.

7.Who we share it with

We share personal information with service providers who help us run our business and the Platform. They may only use it to provide services to us. They include:

• Base44, which hosts the Platform
• Netlify, which hosts our website, receives website form submissions and runs our website functions
• Resend, which sends our form notification emails
• Google, for business email and website fonts
• Apollo, for decision maker data
• our AI model providers, for Kip
• our CRM and accounting providers, for sales, customer and financial records
• our payment provider
• our professional advisers, such as lawyers and accountants.

We may also share personal information:

• inside a customer account, where authorised users of that agency can see the agency's data
• with a buyer or investor, if we sell or restructure our business, under confidentiality terms
• where the law requires or allows it, for example to a court, regulator or law enforcement agency.

8.Overseas disclosure

Some of our service providers store or access personal information outside Australia. The countries are likely to include:

• the United States, where several of our providers are based, including Netlify, Resend, Apollo and Google
• Base44, which hosts the Platform on its cloud infrastructure. Personal information may be stored or processed in the United States and other countries where Base44 and its cloud providers operate.
• other countries where our providers store backups or provide support.

Before we disclose personal information overseas, we take reasonable steps to make sure the recipient handles it in line with the APPs. We do this mainly through contracts and by choosing reputable providers.

9.Storage, security and retention

We store personal information electronically with our service providers. The Platform is hosted by Base44 on its cloud infrastructure. This means personal information may be stored or processed outside Australia, including in the countries listed in section 8. A current list of our service providers (subprocessors) is available on request by emailing simone@kloserecruit.com.au.

We take reasonable steps to protect personal information from misuse, interference, loss and unauthorised access, change or disclosure. These steps include:

• encryption of data sent between your browser and our website and Platform
• access controls on our systems and accounts
• limiting staff access to the people who need it
• choosing providers with strong security practices.

No system is completely secure. Please keep your login details private and tell us straight away if you think your account is at risk.

We keep personal information only for as long as we need it for the purposes in this policy or as the law requires. For example:

• demo requests that do not lead to a sale: 24 months
• customer and agreement records: 7 years after the account ends
• Customer Data: we keep it during the subscription. Customers can export it for 30 days after the subscription ends. After that, we may delete it, unless the law requires us to keep it.

When we no longer need personal information, we delete it or make it anonymous.

10.Access and correction

You can ask for access to the personal information we hold about you. You can also ask us to correct it if it is wrong, out of date, incomplete, irrelevant or misleading.

Email support@kloserecruit.com.au. We will need to confirm who you are. We will respond within 30 days. We will not charge you to make a request.

If we refuse your request, we will tell you why in writing and explain how to complain. If we refuse to correct your information, you can ask us to add a note to it.

For Customer Data, please contact the agency that holds your information. We will help them respond.

11.Marketing and how to opt out

We may send you news, product updates and offers about Klose Recruit. We follow the Spam Act 2003 (Cth).

You can opt out at any time:

• use the unsubscribe link in any marketing email, or
• email support@kloserecruit.com.au.

We will action your request within 5 business days. We may still send service messages about your account, security or billing.

12.Cookies and similar tools

Our website. Our website does not currently set its own cookies. It does not use analytics, advertising or tracking tools. Google Fonts and Netlify receive the technical data described in section 3.

The Platform. The Platform may use cookies or similar browser storage to log you in, keep your session secure and remember your settings.

If we add analytics or advertising tools, we will update this policy first and offer choices where the law requires.

You can block or delete cookies in your browser settings. If you block essential cookies, the Platform may not work properly.

13.Data breaches

We follow the Notifiable Data Breaches scheme under the Privacy Act. If we suspect a data breach, we act quickly to contain it and assess it. We aim to finish our assessment within 30 days.

If a breach is likely to cause serious harm to anyone, we will notify the people affected and the Office of the Australian Information Commissioner (OAIC).

If a breach affects Customer Data, we will tell the affected agency promptly after we become aware of it and help it meet its own obligations.

14.Questions and complaints

If you have a question or complaint about privacy, contact our Privacy Officer using the details in section 18. Please tell us what happened and how you would like us to fix it.

We will acknowledge your complaint promptly and aim to respond in full within 30 days.

If you are not happy with our response, you can complain to the OAIC:

• website: www.oaic.gov.au
• phone: 1300 363 992 (from outside Australia: +61 2 9942 4099)
• post: GPO Box 5288, Sydney NSW 2001.

15.People in the EU and UK

This section applies when the EU GDPR or UK GDPR applies to your personal data. For example, it may apply if you are in the EU or UK and use our website or the Platform.

Our role. We are the controller of website, sales, account and marketing data. We are the processor of Customer Data. If you are a customer and need a data processing agreement, contact us.

Legal bases. We use your personal data where:

• we need it to perform a contract with you or take steps before one
• we have a legitimate interest, such as running and improving our business and replying to enquiries, and your rights do not override it
• you have given consent, which you can withdraw at any time
• we need it to meet a legal obligation.

Your rights. You can ask us to give you a copy of your data, correct it, delete it, limit how we use it or send it to another provider. You can object to our use of your data based on legitimate interests. You can object to direct marketing at any time. You can also ask about any decision made only by automated means that has legal or similarly significant effects on you. We will respond within one month.

International transfers. We are based in Australia and use providers in other countries, such as the United States. Where the law requires it, we protect transfers with recognised safeguards, such as the European Commission's standard contractual clauses or the UK International Data Transfer Agreement or Addendum.

Complaints. You can complain to your local data protection authority. In the UK, this is the Information Commissioner's Office (ico.org.uk).

Other countries. If you are outside Australia, the EU and the UK, your local privacy laws may give you extra rights. Contact us and we will help.

16.Children

Our website and Platform are for businesses. They are not aimed at children under 18. We do not knowingly collect personal information from children for our own purposes.

17.Changes to this policy

We may update this policy from time to time. We will post the new version on this page and change the "last updated" date. If we make a major change, we will tell customers by email or in the Platform.

18.Contact us

Privacy Officer: Simone Titus, Founder + Director
Klose Recruit Pty Ltd
Email: simone@kloserecruit.com.au
General requests: support@kloserecruit.com.au