Privacy Policy

1. About this policy

Laveeka Pty Ltd (ABN 83 700 544 449, ACN 700 544 449) (“Laveeka”, “we”, “us” or “our”) is committed to protecting the privacy of everyone whose personal information we hold. This Privacy Policy explains what personal information we collect, how we collect it, why we collect it, how we use, store and disclose it, and how you can access, correct, or complain about the handling of your personal information.

This Privacy Policy is intended to comply with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs), which set out the standards, rights and obligations for the handling of personal information in Australia. We commit to handling personal information in accordance with the APPs, regardless of whether Laveeka is, at any given time, entitled to rely on the small business exemption under that Act.

This policy applies to everything Laveeka does: our website at laveeka.com (the “Website”), the consulting and technology services we deliver to clients and the software we provide to clients. Where we deliver services under a client engagement, this policy sits alongside that agreement rather than replacing it. If a term of a signed client agreement conflicts with this policy, the agreement governs the relationship between Laveeka and that client, and this policy still describes the standard we hold ourselves to.

2. Who we are

Laveeka is a technology-led business and recruitment transformation consultancy based in Sydney, Australia.

3. The four ways we handle personal information

Different parts of this policy apply depending on how you came into contact with us. It is worth knowing which one you are, because your rights are the same in each case but what we hold is very different.

• Website visitors and enquirers. You visited laveeka.com, or sent us an enquiry or an email.
• Client and prospective client contacts. You work at a business we advise, are talking to or have talked to. We hold your work contact details and a record of our dealings with you.
• Meeting participants. You took part in a meeting or call with us that we recorded, transcribed or took notes from. Section 6 explains this in full.
• People whose information sits inside software we provide. We supply software to client businesses. Where a client uses it to hold information about their own contacts, candidates or staff, that client decides what goes in and why. Laveeka holds that information on their behalf and does not use it for our own purposes. If you want that information accessed, corrected or removed, the fastest route is the business you dealt with, and we will help them do it. You can also come to us and we will pass it on.

4. What personal information we collect

We only collect personal information that is reasonably necessary for the purposes described in this policy.

From website visitors and enquirers:

• identity and contact information you provide when you submit an enquiry, such as your name, work email address, company name, job title and phone number;
• the content of any message or enquiry you choose to send us;
• correspondence you send us directly by email, including your email address and the content of that correspondence;
• where you ask us for a value scan, the website address you gave us and what the scan read from that public website, such as the sector and approximate size of the business;
• a record of the consent wording shown to you at the time you gave us your details, the time you gave them, and whether you agreed to be contacted later about work like this; and
• limited technical information generated as part of standard web server operation, which may include IP address, browser type and pages visited.

From client and prospective client contacts:

• your name, work email address, phone number, job title, employer and business location;
• a record of our dealings with you, such as notes of calls and meetings, emails, tasks and the stage a piece of work has reached;
• calendar entries for meetings involving you, including the meeting title, time and the other attendees; and
• where a meeting was recorded, the recording, its transcript and the summary produced from it. See section 6.

Inside software we provide to a client: whatever that client chooses to record about their own contacts, candidates or staff. That can include contact details, work history, availability, pay expectations, right to work and compliance documents and notes written by that client’s own people.

We do not seek sensitive information (as defined in the Privacy Act, such as health information, racial or ethnic origin or criminal record information) and we ask that you do not send it to us unless we have specifically asked for it and explained why. Where a client uses software we provide to record information of that kind about their own candidates, they are responsible for having a lawful basis to do so.

5. How we collect personal information

Wherever it is reasonable and practicable, we collect personal information directly from you: from an enquiry form, an email, a conversation or a meeting you took part in.

We also collect personal information in these ways:

• from the business you work for, or a colleague of yours, when they introduce you or include you in a piece of work;
• from our own calendar and email systems, where a meeting or message involves you;
• from publicly available sources, such as a company website or a professional profile, where we are researching a business we may work with; and
• from a client, where they load information into software we provide to them.

Where you send us an enquiry, the details you give us are recorded in our own client record system so that we can answer you and keep track of the conversation. This happens at the same time as the enquiry reaches us by email. It is the same system in which we hold our client and prospective client records, described above, and it sits on servers in Australia. See section 10.

Where we collect information about you from someone other than you, we take reasonable steps to make sure you are aware of this policy and of why we hold it.

6. Recording, transcribing and summarising meetings

Some of our meetings and calls are recorded, and the recording is turned into a written transcript and a short summary that is filed against our record of the relationship. This is how we keep an accurate account of what was agreed rather than relying on memory.

How we do it, every time:

• We say it out loud. We announce at the start of the meeting that it is being recorded, before any recording begins.
• We put it in writing. A written notice is posted into the meeting chat as well, so the notice is on the record and anyone joining late can see it.
• We ask, and you can say no. If any participant does not want the meeting recorded, we do not record it. Saying no costs you nothing and we take written notes instead.
• You can change your mind. Tell us at any point, during the meeting or afterwards, and we will stop recording and delete the recording, the transcript and the summary.
• We never record covertly. We do not make recordings without the knowledge of the people in the conversation, and we do not accept recordings from anyone else that were made that way.

Recordings, transcripts and summaries are held under the same security described in section 13, kept for the period described in section 12 and disclosed only as described in sections 9 and 10.

If you would like a copy of a transcript or summary of a meeting you took part in, or would like it deleted, contact us at hello@laveeka.com.

7. Why we collect, use and disclose personal information

We collect, hold, use and disclose personal information to:

• respond to your enquiry and correspond with you;
• provide, manage and improve the consulting and technology services we deliver;
• keep an accurate record of our dealings with the businesses we work with;
• operate, support and secure the software we provide to clients;
• meet our legal, accounting and record-keeping obligations; and
• any other purpose disclosed to you at the time of collection, or to which you have consented.

We do not sell personal information. We do not disclose personal information to third parties for their own marketing.

Information held inside software we provide to a client is used only to run that software for them and to support and secure it. We do not use it for our own purposes and we do not use it to train models.

8. Direct marketing

We may use your work contact details to send you information about our services where you would reasonably expect it, for example after an enquiry or in the course of a business relationship. Every such message includes a simple way to opt out, and you can opt out at any time by replying or emailing hello@laveeka.com. We will action it promptly and it will not affect any work we are doing for you.

9. Who we disclose personal information to

We may disclose personal information to:

• our own personnel, where they need it to do their job;
• service providers who help us run the business, such as hosting, transcription, email, calendar and accounting providers. These providers act on our instructions and are bound to keep the information confidential and secure. We publish the list of them, and where each one holds data, at laveeka.com/subprocessors;
• a client, where the information relates to work we are doing for them;
• our professional advisers, such as lawyers and accountants, where reasonably required; and
• a regulator, court or other body, where required or authorised by law.

We do not otherwise disclose personal information to third parties without your consent, unless required or authorised by law.

10. Where your information is stored and overseas disclosure

Our platform database is hosted in Sydney, Australia. It was moved there from South Korea on 2 September 2026, and the copy that was held in the former South Korean project as a fallback while the move was proven was deleted on 4 September 2026. No Laveeka database is held outside Australia. Some of the service providers we rely on do hold or process data outside Australia. The categories of provider, what each handles and the country each operates in are published at laveeka.com/subprocessors and we keep that up to date as things change. The named providers are supplied on request.

At the date of this policy, personal information may be disclosed to, or held on servers located in, the United States and other countries listed on that page.

Before disclosing personal information to an overseas recipient, we take reasonable steps to ensure that recipient does not breach the Australian Privacy Principles in relation to that information, including by using providers that maintain their own security and privacy commitments. In some circumstances an overseas recipient may not be subject to privacy obligations equivalent to those imposed under Australian law, and it may be difficult for us to take further action if that occurs.

If you would prefer not to have your information handled by a particular provider, tell us and we will discuss what alternatives are practical.

11. Cookies and tracking technologies

We do not use cookies, analytics services or advertising trackers on the Website. Standard web server logs are generated by our hosting provider as part of delivering the site, and we do not use them to identify individuals.

Software we provide to clients uses only the browser storage necessary to keep you signed in and to remember your own display preferences. It carries no advertising or analytics trackers.

12. How long we keep personal information

We keep personal information only as long as we need it for the purpose we collected it, or as long as the law requires, and then we destroy it or de-identify it.

• Enquiries that do not become a relationship: kept while we are in contact and then removed.
• Client and prospective client records: kept for the life of the relationship and for as long afterwards as we need them for our legal, tax and record-keeping obligations.
• Meeting recordings, transcripts and summaries: kept for as long as they are useful to the work, and deleted on request at any time.
• Information inside software we provide to a client: kept according to the retention period that client sets, and deleted when they delete it or when their agreement with us ends.

Deleting a record removes the information filed against the person, including the file attachments held with it. Free text that another person wrote elsewhere may still mention someone by name, and we deal with that case by case on request.

13. Data quality and security

We take reasonable steps to ensure the personal information we collect, use and disclose is accurate, up to date and complete. You can help by keeping us informed if your details change.

We take reasonable steps to protect personal information from misuse, interference, loss and unauthorised access, modification or disclosure. In practice that includes:

• separating each client’s data in the database itself, so one client’s system cannot read another’s;
• limiting access to the people who need it, with different levels of access for different roles;
• encrypting information in transit and at rest;
• holding uploaded files in private storage that is never served from a public address; and
• showing only the minimum necessary information on any page shared outside the business.

No method of storage or transmission over the internet is completely secure, and we cannot guarantee absolute security.

14. Access and correction

You can ask us for a copy of the personal information we hold about you, and you can ask us to correct it if it is wrong. Email hello@laveeka.com. We will respond within 30 days.

There is no charge for asking. If a request takes substantial work we may charge a reasonable cost, and we will tell you the amount before we do anything.

In limited circumstances the Privacy Act allows us to refuse access or correction. If that happens we will tell you in writing why, and how to complain about it.

If your information sits inside software we provide to a client, see section 3. The client controls that record, and we will help them action your request.

15. Data breaches

If we become aware of a data breach involving personal information that is likely to result in serious harm, we will comply with our obligations under the Notifiable Data Breaches scheme in Part IIIC of the Privacy Act, including notifying affected individuals and the Office of the Australian Information Commissioner (OAIC) as required.

We maintain a written response plan setting out who does what, how quickly we assess a suspected breach and how we notify. Where a breach affects information we hold for a client, we will tell that client promptly so they can meet their own obligations.

16. How to contact us or make a complaint

If you have a question about this policy, wish to access or correct your personal information, or wish to make a complaint about how we have handled your personal information, please contact us first:

We will acknowledge your complaint and aim to resolve it within 30 days. If you are not satisfied with our response, or do not receive a response within a reasonable time, you may lodge a complaint with the Office of the Australian Information Commissioner:

17. Children’s privacy

Our services are directed at businesses and business professionals. They are not intended for, and we do not knowingly collect personal information from, children. If you believe a child has provided us with personal information, please contact us and we will take reasonable steps to delete it.

18. Changes to this policy

We may update this Privacy Policy from time to time to reflect changes in our practices or in the law, including forthcoming changes to the Privacy Act, such as the automated decision-making transparency requirements commencing 10 December 2026. The updated policy will be posted on this page with a new “last updated” date. We encourage you to review this policy periodically.