Privacy Policy

Operator: Clip-Board Hospitality Pty Ltd ACN 603 770 547.

Each of Clip-Board Hospitality Pty Ltd ACN 603 770 547 and Clip-Board Australia Pty Ltd ACN 603 794 976 (individually and collectively Clip-Board, Choosey, we, us or our) is committed to protecting your personal information.

This Privacy Policy explains how we collect, use, disclose and protect personal information through the Choosey app and website and the Clip-Board platform (together, the Platforms), and how you can contact us. It does not apply to how we handle personal information about our own employees.

1. Background

We operate the Clip-Board Platform and the Choosey App for our members (Members). A Member is a person who signs up to or joins a Platform through a registration process on our website or app. Our Members are generally part of the Australian hospitality industry and include employers, staff, suppliers, business owners, producers, entrepreneurs and industry experts.

The Clip-Board Platform helps Members connect and communicate with each other to share news and insights and create better opportunities, including employment and business opportunities.

The Choosey App connects hospitality businesses (Businesses) with workers (Workers) through two services: Choosey Shifts, for casual, short-term and event shifts, and Choosey Placements, for permanent, part-time and other ongoing roles. Choosey uses automated and artificial intelligence (AI) tools to match Workers with shifts and roles (see section 6).

We comply with the Australian Privacy Principles (APPs) in the Privacy Act 1988 (Cth) (Act), except where the Act does not require this. The APPs regulate how personal information is handled throughout its life cycle, from collection to use and disclosure, storage, accessibility and disposal.

Personal information is information or an opinion, in any form and whether true or not, about an identified individual or an individual who is reasonably identifiable. Special rules apply to sensitive information, which includes health information, biometric information, and information about a person’s racial or ethnic origin, political opinions, membership of political, professional or trade associations or trade unions, religious or philosophical beliefs, sexual orientation or practices, and criminal record.

2. The kinds of personal information we collect and hold

All Members

• Name and contact details, including email address, telephone number and postal address.
• Log-in details and account settings.
• Your position, education details and qualifications, and information about your business or employer.
• Employment status, employee status and business type.
• Content you post or upload, including messages, posts and images, and your communications with us.

Workers (Choosey)

• Profile information, including profile photo, work history, skills, roles of interest, availability, preferred locations and salary or rate expectations.
• CVs and information extracted from them, and voice recordings and transcripts if you choose to describe your experience by voice.
• Certificates, licences and qualifications (for example RSA, RSG, food safety and manager’s licences), including their expiry dates.
• Work rights information, including citizenship or visa status and any visa conditions, and identity documents where you provide them.
• ABN (for Workers who accept shifts as contractors).
• Shift, application and hire history, including invitations, acceptances, attendance, cancellations, hours worked and outcomes recorded by Businesses.
• Ratings and reviews given by and about you, Match Scores and Reliability Scores (see section 6).
• Payout information held by our payment provider Stripe. We do not store your full bank account details; we receive only limited information such as payout status and the last digits of the account.
• Information needed to assess and pay any Hire & Earn bonus.

Businesses and their users

• Business details, including entity name, ABN or ACN, venue names and locations, and the names, roles and contact details of your authorised users.
• Hiring requirements, job and shift postings and hiring briefs (including the Talent DNA Brief), whether typed or given by voice.
• Subscription, billing and transaction history. Card details are held by Stripe, not by us.
• Identity and business verification results. Verification is performed by Stripe, which may collect identity document images and facial images for that purpose and returns a verification result to us.
• Records of candidate unlocks, introductions, outcomes and hires.

Technical and usage information

• Device and log information, including IP address, device identifiers, operating system, app version, crash data and push notification tokens.
• How you use the Platforms, including pages and screens viewed and actions taken.
• Location information you enter (such as a suburb or venue address) and, if you allow it in your device settings, your device location.

Sensitive information

We do not ask for sensitive information unless it is reasonably necessary and you consent. Please do not include sensitive information (for example health information) in your CV or profile unless it is relevant. Where Stripe collects biometric information to verify identity, it does so under its own privacy policy. Stripe returns only a verification result to us, and we do not receive or store biometric information.

3. How we collect personal information (APPs 3 and 5)

To the extent required by the Act, we will only collect personal information that is reasonably necessary for one or more of our functions or activities, and only by lawful and fair means. We collect personal information:

• directly from you, when you register, complete your profile, upload a CV, use voice input, post a shift or role, apply for or accept work, message another Member, or contact us;
• from other Members, for example when a Business records an outcome, confirms hours or leaves a rating or review about a Worker, or a Worker leaves a rating or review about a Business;
• from third parties, including Stripe (payment and verification results), the Australian Business Register (ABN details), and, with your consent, the Clip-Board Platform; and
• automatically, through cookies, software development kits and similar technologies when you use the Platforms.

When we collect personal information directly from you, we will take reasonable steps at or before the time of collection to make you aware of certain key matters, such as the purposes of collection, the types of organisations to which we usually disclose information of that kind, your right to access the information and how to contact us.

4. Why we collect, use and disclose personal information (APP 6)

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

• create and manage accounts and give you access to the Platforms;
• match Workers with shifts and roles, rank and recommend Workers to Businesses, and send invitations;
• show Worker profiles to Businesses and, once a Business unlocks a profile, disclose the Worker’s identity, contact details and CV to that Business;
• verify identities, ABNs, certificates and work rights;
• process subscriptions, shift payments, placement fees, payouts and Hire & Earn bonuses;
• record introductions and outcomes and enforce our Terms of Use, including detecting engagements arranged outside the Platform to avoid fees;
• calculate ratings, Match Scores and Reliability Scores;
• prevent, detect and investigate fraud, misuse, safety issues and unlawful activity;
• send you service messages and notifications (including shift reminders and certificate expiry alerts);
• send you marketing from us and, with your consent, material from our partners (we will not give partners your contact details: we obtain their materials and send them to you ourselves);
• respond to enquiries and complaints; and
• maintain, analyse and improve the Platforms, including our matching tools.

If we use or disclose your personal information for a purpose (the secondary purpose) other than the main reason it was collected (the primary purpose), to the extent required by the Act we will ensure that:

• the secondary purpose is related to the primary purpose (and directly related in the case of sensitive information) and you would reasonably expect us to use or disclose your information in that way;
• you have consented to the use or disclosure;
• the use or disclosure is required or authorised by or under law; or
• the use or disclosure is otherwise permitted by the Act (for example, as a necessary part of an investigation of suspected unlawful activity).

We do not sell personal information.

5. Who we disclose personal information to

• Businesses — when a Worker is recommended for, invited to or applies for work, a Business can see a limited profile. Name, contact details, CV and other identifying details are hidden until the Business unlocks the profile, after which they are disclosed to that Business.
• Workers — details of Businesses, shifts and roles, and ratings and reviews of Businesses.
• Service providers who help us operate the Platforms. At the date of this Policy these are: Bubble (app platform, hosting and push notifications); Stripe (payments, subscriptions, payouts and identity verification); OpenAI (AI models used for matching, CV parsing, voice transcription and text generation); Brevo (email); Intercom (in-app messaging and customer support); and PostHog (product analytics). We require our service providers to use personal information only to provide their services to us and to comply with appropriate data quality and security requirements.
• Our related entities, including between Clip-Board Hospitality Pty Ltd and Clip-Board Australia Pty Ltd, and between the Clip-Board Platform and the Choosey App where you have consented to your accounts being linked.
• Professional advisers, insurers, auditors and debt collectors.
• Government agencies, regulators and law enforcement, where required or authorised by law.
• A purchaser or prospective purchaser of all or part of our business, subject to confidentiality obligations.

6. AI, matching and automated decisions (APP 1.7)

Choosey uses computer programs, including AI models, to process personal information. In particular we use them to:

• extract information from CVs and turn voice recordings into text, then into profile details or job posts;
• calculate Match Scores and rank Workers for a shift or role, and rank shifts and roles for a Worker, and write short explanations of each match;
• calculate Reliability Scores and risk indicators from attendance, cancellations, ratings and reviews; and
• monitor activity to identify introductions that have not been given an outcome.

Some of these programs make or substantially assist decisions that could significantly affect you, including which Workers are shown or invited first, and whether an automatic invitation is blocked because of a high non-attendance risk. The information used includes your profile, skills, experience, certificates, location, availability, pay or salary expectations and your activity history on Choosey.

The decision to engage a Worker is always made by the Business, not by Choosey. You can ask us to explain, or to have a person review, any score, ranking or automated limitation that affects you by emailing support@chooseyapp.com. You can also correct profile information at any time in the app.

This section is included to meet the transparency requirements for automated decisions in APPs 1.7 to 1.9, inserted into the Act by the Privacy and Other Legislation Amendment Act 2024 (Cth).

7. Transfer of personal information overseas (APP 8)

Some of our service providers store or process personal information outside Australia, principally in the United States (Bubble, OpenAI, Intercom and PostHog, and Stripe for some processing) and the European Union (Brevo). If we transfer personal information overseas, we will take reasonable steps to ensure that the overseas recipient does not breach the APPs in relation to that information.

This obligation will not apply if:

• we reasonably believe that the recipient is subject to legal obligations that have the effect of protecting the information in a way that, overall, is at least substantially similar to the APPs, and there are mechanisms you can access to enforce that protection;
• you consent to the disclosure after we expressly inform you that, if you consent, we will not be required to take reasonable steps to ensure that the overseas recipient does not breach the APPs; or
• we are otherwise required or authorised by law to do so.

8. Marketing (APP 7)

We may send you marketing about our services and those of our partners where you have agreed to receive it or where the law otherwise permits. Every marketing email includes a way to unsubscribe, and you can change your notification preferences in the app at any time. Service messages about your account, shifts, roles and payments are not marketing and will continue while you have an account. We send electronic marketing in accordance with APP 7 and the Spam Act 2003 (Cth), and we act on unsubscribe requests within 5 business days.

9. Data quality, security and retention (APPs 10 and 11)

To the extent required by the Act, we take reasonable steps to:

• ensure that the personal information we collect, use and disclose is accurate, complete and up to date;
• protect the personal information we hold from misuse, interference and loss, and from unauthorised access, modification or disclosure, including through access controls and encryption; and
• destroy or permanently de-identify personal information that is no longer needed for any purpose permitted by the Act.

We keep personal information for as long as your account is active and afterwards for as long as we reasonably need it, including to resolve disputes, enforce introduction protection periods and meet legal, tax and record-keeping obligations (including record-keeping obligations under the Corporations Act 2001 (Cth) and taxation laws, which generally require financial records to be kept for 5 to 7 years).

10. Cancelling your account and deleting your data

You can cancel your account (Choosey App and Clip-Board) and ask us to delete data related to your account at any time, in the app or by emailing support@chooseyapp.com or support@clipboardhospo.com. We will promptly cancel your account and delete or de-identify your data after receiving your request, except for information we are required or permitted by law to keep (for example transaction records and records of introductions within an active protection period). Information already disclosed to a Business after an unlock is held by that Business under its own privacy obligations.

11. Access and correction (APPs 12 and 13)

Please contact us at support@chooseyapp.com or support@clipboardhospo.com if you would like to access or correct the personal information we hold about you. You can also update most profile information directly in the app. We will generally provide access if practicable and will take reasonable steps to correct information that is incorrect. We will not charge you for making a request, although a reasonable fee may apply to the cost of giving access. In some circumstances we may refuse access or correction, in which case we will give you our reasons in writing, and how to complain about the refusal. We will respond to access and correction requests within 30 days.

12. Payment processing

All payments on the Choosey App, including subscriptions, shift payments, placement fees and payouts, are processed by our payment partner Stripe. Stripe also performs identity and business verification.

Clip-Board and Choosey do not store full card numbers or bank account details on our servers. Stripe is responsible for the security of the payment and verification information it collects and processes, in accordance with its own obligations and policies. Please review Stripe’s Privacy Policy at stripe.com/privacy for more information.

13. Notifiable data breaches

If we experience a data breach that is likely to result in serious harm to any individual (an eligible data breach under Part IIIC of the Act), we will notify affected individuals and the Office of the Australian Information Commissioner (OAIC) as soon as practicable, in accordance with the Act. Where we suspect an eligible data breach, we will carry out a reasonable and expeditious assessment within 30 days, as required by the Act.

14. Cookies and website data

When you use our website and apps we collect browser and device data, which we use to operate, optimise and secure the Platforms and to understand how they are used. We use cookies and similar technologies, including PostHog product analytics in our website and apps, which records how the Platforms are used (for example screens viewed and features used). A cookie is a small text file placed on your device that improves functionality or helps us analyse use of our website. If you do not wish us to use cookies, you can change your browser or device settings, although some features may not work as a result.

15. Children

The Choosey App is for people aged 18 and over. We do not knowingly collect personal information from anyone under 18 through the Choosey App.

16. Questions and complaints

Please contact our Privacy Officer at support@chooseyapp.com if you have any questions or complaints about the personal information we hold about you or the way we handle it. We will acknowledge your complaint as soon as possible and will seek to resolve it within 14 days, or within 30 days where the matter is complex.

If you are not satisfied with our response, you may complain to the OAIC at oaic.gov.au or on 1300 363 992.

17. Changes to this Privacy Policy

We may change this Privacy Policy from time to time. The current version will always be available in the Choosey App and on our websites. Where a change materially affects how we handle your personal information, we will notify you through the app or by email.

18. Contact us

Privacy Officer, Clip-Board Hospitality Pty Ltd
Level 2, 240 Chapel Street, Prahran VIC 3181
Email: support@chooseyapp.com or support@clipboardhospo.com
Or click Contact Us on our website.