Privacy Policy

OPEN LOTUS's commitment to maintaining your privacy

OPEN LOTUS's Privacy Statement has been created because we value our users and recognise their right to keep Personal Information private. OPEN LOTUS collects Personal Information and Personal Data from Site visitors for the purposes of providing services to our users, and (as described below) for the purposes of better customising our services to you. Any Personal Information and Personal Data collected from you will be used by us in accordance with and as described in this Privacy Statement. This Privacy Statement has been prepared by OPEN LOTUS.  OPEN LOTUS owns and operates the website located at openlotus.openlotus.com.au (“the Site”) across desktop, mobile, tablet and apps and including any subdomains such as openlotus.openlotus.com.au/pms 

Definitions

Where used in this Privacy Statement, the terms “Personal Information”, and “Australian Privacy Principle(s)” have the meaning attributed to those terms in the Privacy Act (Cth) 1988 (“Privacy Act”).In this Privacy Statement:

· any reference to “OPEN LOTUS”, “we”, “us” and “our” includes a reference to OPEN LOTUS Pty Ltd and each of OPEN LOTUS's related bodies corporate (as that term is defined in the Corporations Act 2001 (Cth)).

. "Advertiser" refers to individuals or entities that post job ads on our Site or use other products to source potential Candidates for job vacancies;

· "Candidates" refers to users of the Site and “Registered Users” refers to Candidates who register on the Site;

· Candidates, Advertisers and users who otherwise subscribe for OPEN LOTUS products, services or information offered via the Site are referred to generically in this Statement as “visitors”, "users" or "you", unless the context provides that only Candidates, Registered Users or Advertisers are being referred to;

· “Personal Data” has the meaning attributed to that term in the GDPR;

· "Talent Search" refers to a OPEN LOTUS product which allows Advertisers to search, refine and connect with Candidates who maintain a OPEN LOTUS Profile and have a privacy setting of Standard or Limited; and

· "Talent Search Connection Method" means a method by which an Advertiser using Talent Search is able to contact a candidate by sending a Candidate a copy of a job opportunity for which the Advertiser is recruiting, (by using the "send job" function), or sending a Candidate a customised email about a job opportunity, (by using the "message" function). Advertisers who use either of these functions do not, by using those functions, receive access to any Candidate’s Personal Information. 

Collecting other information on OPEN LOTUS visitors

OPEN LOTUS collects non-Personal Information on Site visits by users including, without limitation, which sections of the Site are most frequently visited, how often, and for how long. This data is always used as aggregated, non-Personal Information, and may be shared with OPEN LOTUS partners to provide them with information relating to how OPEN LOTUS visitors 'use' the Site. This is done for the purpose of providing you with the best and most efficient career management and recruitment services.IP Addresses OPEN LOTUS's web servers gather your IP address to assist with the diagnosis of problems or support issues with our services, and to monitor the use of our Site, including the monitoring of the location of our users.Cookies OPEN LOTUS uses cookies and applets to provide Candidates with a better browsing experience and tailor advertisements from or from our business partners that appear, (on the Site or other websites) to your browsing preferences and/or your OPEN LOTUS Profile, (as defined below).These cookies and applets collect non-Personal Information such as preferences and click activity for measurement and for features such as remembering your details for 'Auto Login' (provided you have chosen this option), and remembering your search criteria for the 'My Last Search' function. OPEN LOTUS uses cookies and scripts in respect of Advertisers to assist OPEN LOTUS in improving website performance, making business decisions, aiding in error reporting, aiding online payments and testing new functionality. These cookies and scripts collect non-Personal Information such as preferences and click activity for measurement and for features such as remembering your details for 'Auto Login' (provided you have chosen this option).If you do not wish to have cookies active whilst you browse the Site you can "opt out" by modifying the privacy options in your browser. However, doing so will prevent access to some areas of the Site and limit your use of some of the OPEN LOTUS services.In addition to the above, where users access the OPEN LOTUS mobile applications ("OPEN LOTUS Apps") we use third party software development kits (SDK's) and services which collect non-Personal Information relating to your use of the OPEN LOTUS Apps, including tracking of app installs and re-engagement. This information is used to tailor and measure advertisements to install and/or use the OPEN LOTUS Apps which appear on third party sites/apps and are targeted towards users' usage preferences.If you want to opt-out from the collection and usage of information for advertisement targeting you can do so by enabling "Limit Ad Tracking" (Settings>Privacy>Advertising) on your iOS device or by enabling the "Opting out of interest-based ads" option (Settings>Services>Ads) on your Android device. By opting out from ad targeting OPEN LOTUS and its third party providers will not use the collected information to target ads to you, however the information collected may continue to be used by OPEN LOTUS for, amongst other things, estimation of user numbers, advertising fraud detection and debugging. Third Party Measurement In order to better understand our users, OPEN LOTUS utilises third party measurement companies to assess Site and mobile Site traffic. A tracking code is used to collect the following information on the usage of the Site:

· The number of page views (or page impressions) that occur on the Site;

· The number of unique visitors to the Site;

. How long these unique visitors (on average) spend on the Site when they do visit; and

· Common entry and exit points into the Site.

This aggregated, non-Personal Information is collated and provided to OPEN LOTUS to assist in analysing the usage of the Site. This data is also accessible by media organisations and research companies, for the purpose of conducting industry comparisons with other Internet websites. 

Collecting information on Registered Users

As part of registering with OPEN LOTUS, we collect Personal Information about Registered Users in order for Registered Users to take full advantage of OPEN LOTUS's services. To do this it will be necessary for Registered Users to provide additional information to OPEN LOTUS.Registration Becoming a Registered User allows you to take advantage of more of the tools, services and resources that may assist you in finding a job. To become a Registered User you will need to submit some Personal Information such as your name and email address. You may access your information at any time by on 'the Site'. OPEN LOTUS may also use this information in order to customise the service we provide to you. For example, OPEN LOTUS may use this information to create a OPEN LOTUS Profile that you may choose to use in the future. However, we will never activate this OPEN LOTUS Profile (or any other service) without your express consent. 

Other information OPEN LOTUS may collect

OPEN LOTUS may also collect and use information about your job seeking needs, characteristics and priorities by collecting and analysing data about how you use, or interact with, the products and services offered on the Site (including, by way of example, usage patterns around how regularly you update your profile or how often you submit job applications). OPEN LOTUS may use this information, including through automated processes applying algorithms, for the purposes set out in this Privacy Statement, including without limitation to better tailor OPEN LOTUS’s offerings to your job seeking needs and to provide more targeted services to Advertisers and to Candidates including to allow more targeted job opportunities to be surfaced to Candidates and to create ‘signals’ to advertisers that you may be more or less approachable for job opportunities (Approach-ability Signal). 

Job Mail

Job Mail is an optional service available to Registered Users. OPEN LOTUS requests that Registered Users provide their email address, and information relating to their employment preferences, so that OPEN LOTUS can notify Registered Users via email of jobs within their specified criteria. Registered Users can modify or delete their Job Mail preferences (or their Job Mail account) at any time by going to the area of the Site.Users of the Site may also subscribe to Job Mail without creating a OPEN LOTUS Profile and becoming a Registered User by electing to do so when searching for jobs on the Site. If you choose to subscribe to Job Mail in this manner, any Personal Information you provide us when creating your Job Mail subscription will be stored and used by OPEN LOTUS in the same manner as if you were a Registered User. You will be able to unsubscribe from Job Mail subscriptions at any point in time by clicking on the unsubscribe link within the email. In order to best utilise OPEN LOTUS's services, we recommend creating a OPEN LOTUS Profile (see below). 

Storing resumes

Registered Users may elect to store up to 9 resumes in their Profile area, and use those resumes when applying for a job and to supplement their OPEN LOTUS Profile. Deleting a resume from the 'Profile' area will mean it is no longer accessible to the Registered User. Deleted records may still be stored by OPEN LOTUS in testing or backup systems for a period of time.Where resumes are held in testing environments, these are held in closed and secure environments and information is only used for the purpose of internal software testing. Information held in backup systems is only held for the purposes of backing up systems in the event of a data loss.If you choose a stored resume as your default resume OPEN LOTUS may use an algorithm that uses that resume, along with other factors, to calculate how you may rate against other candidates in relation to job opportunities that are surfaced to you following a job search or otherwise through OPEN LOTUS products. This assessment may be shown to you when you are viewing a job ad and may also be shown to hirers as an indication of OPEN LOTUS’s assessment of your suitability to a position that a hirer is trying to fill. 

OPEN LOTUS Profile

An OPEN LOTUS Profile can include a resume, employment and educational history, contact details, minimum salary expectations, and preferred job classifications and locations. You may populate this information on your OPEN LOTUS Profile or the information may be automatically populated using answers to questions you have provided as part of a job application. You can edit your OPEN LOTUS Profile at any time.Advertisers are able to search OPEN LOTUS's Profile database to find and contact relevant candidates. Upon registration, all Registered Users will be asked to create a personal OPEN LOTUS Profile ('OPEN LOTUS Profile') by providing some key information and selecting one of the privacy settings outlined below. Candidates without OPEN LOTUS Profiles will also be required to create a OPEN LOTUS Profile when they first apply for a job on the Site. Registered Users can elect how much of their OPEN LOTUS Profile they wish to share (if any) with Advertisers based on the following privacy settings: Standard If you elect a “Standard” privacy setting for your OPEN LOTUS Profile, then:

· except for your resume and contact details, your OPEN LOTUS Profile can be seen by Advertisers searching the Job Search database;

· if an Advertiser wishes to purchase access to your OPEN LOTUS Profile, your full OPEN LOTUS Profile including your resume and contact details will be emailed immediately to the relevant Advertiser;

· an Advertiser may contact you via a Talent Search Connection Method;

· if you choose to follow a company within the Company Reviews section of the Site, your OPEN LOTUS Profile, except for your resume and contact details, will be made available to that company; and

· OPEN LOTUS may parse information from your CV to populate your OPEN LOTUS Profile. 

Limited If you elect a “Limited” privacy setting for your OPEN LOTUS Profile, then:

· except for your resume and contact details, your OPEN LOTUS Profile can be seen by Advertisers searching the Job Search database (but Advertisers cannot purchase your resume and contact details);

· an Advertiser may contact you via a Job Search Connection Method; and

· if you choose to follow a company within the Company Reviews section of the Site, your OPEN LOTUS Profile, except for your resume and contact details, will be made available to that company.

Hidden If you elect a “Hidden” privacy setting for your OPEN LOTUS Profile, then your OPEN LOTUS Profile is completely hidden (thereby preventing Advertisers from viewing your OPEN LOTUS Profile).All information provided by you when creating a OPEN LOTUS Profile (including your name, resume, email address, telephone numbers, employment and educational history) may be used by OPEN LOTUS for the purpose of improving placement opportunities for you or for tailoring specific products to you. Registered Users can modify their resume at any time, or modify the privacy options in relation to their OPEN LOTUS Profile at any time, by going to the Profile area of the Site. To delete your OPEN LOTUS Profile you will need to delete your entire account with OPEN LOTUS. OPEN LOTUS reserves the right to disable an OPEN LOTUS Profile at its sole discretion (for example if information is found or believed to be untrue or being stored for improper purposes). 

Online Applications

Making an online application to a job advertisement on OPEN LOTUS is a free and optional service that requires Candidates to complete mandatory fields (for example first name, last name, telephone number and email) so that the Advertiser can identify and contact the applicant. When first applying for a job, Candidates who do not have a OPEN LOTUS Profile will also be required to create a OPEN LOTUS Profile based on the information contained in their application - you may subsequently edit your OPEN LOTUS Profile. Registered Users will also have the option of easily attaching a saved resume. When you apply for a job advertisement on the Site, applications, including attachments and cover letters, are:

· forwarded directly on to the Advertiser and/or its nominated representative; or

· stored in the OPEN LOTUS Advertiser Centre on behalf of the Advertiser. The OPEN LOTUS Advertiser Centre allows Advertisers to easily and effectively manage their recruitment process via one central facility made available by OPEN LOTUS.

Some advertisers may also require you to answer a list of questions selected by that Advertiser as part of your online application. By answering the Application questions you acknowledge that OPEN LOTUS will provide your answers to that Advertiser and may use your answers to populate your OPEN LOTUS Profile and enable Advertisers to surface that information when using Talent Search. OPEN LOTUS may also use your answers to improve our products, including through improving our search and matching capabilities. By applying to a position advertised on OPEN LOTUS you are requesting that OPEN LOTUS pass the information you provide to the relevant Advertiser and/or their nominated representative. Any questions you have relating to a position advertised on OPEN LOTUS, your online application and/or the status of your application should be directed directly to the Advertiser or their nominated agent, not OPEN LOTUS.OPEN LOTUS will also retain this information in order to customise the service we provide to Candidates. OPEN LOTUS reserves the right to disable or delete a saved resume or cover letter at its discretion. Advertisers are asked by OPEN LOTUS to comply with all relevant obligations relating to the use and disclosure of Personal Information that are outlined in the Privacy Act. The use of your information (personal or otherwise) by these Advertisers is not within the control of OPEN LOTUS and we cannot accept responsibility for the conduct of these companies. Candidates have the right to directly contact Advertisers to request access to any Personal Information that you have sent as part of an application or that has been provided to them as part of a OPEN LOTUS Profile. 

Advertisers

OPEN LOTUS collects the company name, business address and billing address of Advertisers. It also collects the name, email address and phone number of a primary contact (also referred to on the Site as the ‘administrator’). Advertisers can choose to add additional users to their account, in which case OPEN LOTUS will collect the name and email address of those other users. Advertisers can change the company name or billing address by emailing test.openlotus@gmail.com. OPEN LOTUS uses these details to manage your account, including sending Advertisers applications of Candidates, contacting Advertisers if there is an issue with their job ad and organising payment and invoicing of the account. 

Investor Information

Users may also subscribe on Site to receive investor information about and from OPEN LOTUS. In order to send you such information, OPEN LOTUS collects the first and last name of such users, the company for which they work (if this information is provided to OPEN LOTUS) and an email address. 

Communications to and from OPEN LOTUS

OPEN LOTUS may also provide you with selected information about job placement and career-related topics in email communications including in our email newsletter 'OPEN LOTUS News Update'. From time to time OPEN LOTUS may also contact you by telephone. OPEN LOTUS may also make Registered Users aware of additional products and services which form part of your relationship with OPEN LOTUS. Registered Users may 'opt-out' of receiving emails from OPEN LOTUS in the area of the site, otherwise Users may opt out by clicking 'unsubscribe' in the footer of an email received. When we speak to you over the phone we may record the calls for training, verification and quality assurance purposes. Any Personal Information collected on those calls is used in accordance with this Privacy Statement. 

Contractors

OPEN LOTUS may also disclose your Personal Information to OPEN LOTUS's service providers and contractors from time to time but only for the purpose of:

· assisting us to deliver the products and services we offer to you; or

· conducting market research about our products and services, the overall employment market and/or specific segments of the employment market.

 Related Bodies Corporate

OPEN LOTUS may also disclose your Personal Information to OPEN LOTUS's related bodies corporate from time to time but only for the purpose of assisting OPEN LOTUS and its related bodies corporate to deliver the products and services offered to you. OPEN LOTUS may also receive Personal Information from OPEN LOTUS's related bodies corporate from time to time in accordance with the privacy policy of those related bodies corporate and/or the Privacy Act (as applicable). 

Storage & Security of Personal Information

OPEN LOTUS takes all reasonable steps to ensure the security of our system and to protect your information from misuse, interference and loss as well as unauthorised access, modification or disclosure. OPEN LOTUS allows you to access your information at any time to keep it accurate and up to date. Any information which we hold for you is stored on secure servers, either in Australia or overseas (including the United States of America), that are protected in controlled facilities. In addition, our employees and the contractors who provide services related to our information systems are obliged to respect the confidentiality and privacy of any Personal Information held by OPEN LOTUS. Except in the case of breaches of our obligations under the Privacy Act to protect your Personal Information, OPEN LOTUS will not be held responsible for events arising from unauthorised access of your Personal Information. In the event of a data breach, OPEN LOTUS is committed to complying in all respects with the requirements of all Australian Privacy Laws and where required, the provisions of the GDPR. You can also play an important role in keeping your Personal Information secure, by maintaining the confidentiality of any password and accounts used on the Site. Please notify us immediately if there is any unauthorised use of your account by any other Internet user, or any other breach of security relating to your account.Access to Your Information unless you become a Registered User, subscribe to Job Mail and/or submit a job application online, or become an Advertiser, OPEN LOTUS does not collect information that identifies you personally. If you become a Registered User, you are able to change or update your Profile at any time by logging in to 'Profile area of the Site. Users who are Job Mail subscribers but not Registered Users do not have access to this additional functionality, however you are able to unsubscribe from Job Mail. In addition, any user is able to at any time request that OPEN LOTUS deletes any Personal Information held by us by accessing the Site, logging in to your account and accessing the setting section. Candidates who have applied for any position on the Site should be aware that the Advertiser to whom their application is sent may also be holding their Personal Information and should you wish to access that information this should be requested directly from those Advertisers. 

Data retention

We retain information you provide to us and which we collect about you, including Personal Information and Personal Data, for so long as we continue to provide services to you and specifically until such time as you request us to delete your Personal Information and Personal Data.

 Data Transfers

Sometimes, we transfer or disclose information to third parties including to persons and businesses outside Australia including in New Zealand, United States of America, Ireland and India. These transfers are made in order to assist us to provide you with the products and services, and/or to improve the products and services we offer you. Where we transfer information to persons outside Australia we take reasonable steps to ensure that the recipients of such information do not breach the Australian Privacy Principles (and where appropriate the GDPR) in relation to that information by entering into binding contractual arrangements with such third parties

 Feedback and Complaints about privacy and the OPEN LOTUS website

OPEN LOTUS welcomes ideas and feedback about all aspects of the Site. OPEN LOTUS stores feedback that users send to us. This feedback may be used to administer and refine the service we provide and may be shared with OPEN LOTUS partners either in aggregate form or with specific identifying characteristics removed. If you have any complaints about our dealings with your Personal Information including any breaches by us of any Australian Privacy Principles or any questions regarding this Privacy Statement you are able to submit that complaint or query by contacting us at test.openlotus@gmail.com or by telephone or post using the methods detailed in the “Contact Us” paragraph below. Any complaints received by us will be referred to our compliance team for prompt investigation and a written response will be provided to you as soon as possible. Should you not be satisfied with the resolution of any complaints made you are able to seek further redress through the Office of the Australian Information Commissioner (see http://www.oaic.gov.au/ for further information).Contact Us If you have any feedback or questions about this Privacy Statement, the practices of this Site, or your dealings with OPEN LOTUS, you can contact us in the following ways: Email: test.openlotus@gmail.com.

 Provision of Copy of Privacy Statement If you require a hard copy of this Privacy Statement or a copy in some other format to suit your particular needs please contact us using any of the methods detailed in the “Contact Us” paragraph above, and we will arrange for a suitable copy to be provided to you.