Privacy Policy

At Salus Pathways Pty Ltd ("Salus Pathways", "we", "us", or "our"), we value privacy and take reasonable steps to protect the personal information we collect and hold. This Privacy Policy explains how we collect, use, disclose, store, and otherwise handle personal information through www.saluspathways.com.au, our website forms, contact channels, and our application process.

1. Introduction and Scope

This Privacy Policy applies to personal information collected by Salus Pathways Pty Ltd through:

• www.saluspathways.com.au
• Website contact forms, lead forms, and enquiry forms
• Online application forms and recruitment-related submissions
• Email, phone, and other communications with us
• Any related services, platforms, or systems we use to manage enquiries, applications, and communications

This Privacy Policy applies to:

• Website visitors
• Individuals who contact us
• Applicants, candidates, and prospective candidates
• Other individuals whose personal information is provided to us in connection with an enquiry or application, where lawful

This Privacy Policy is designed with the Privacy Act 1988 (Cth) and the Australian Privacy Principles in mind, and also addresses key GDPR and UK GDPR considerations where applicable to individuals in the EU, EEA, and UK.

2. What Personal Information We Collect

The personal information we collect depends on how you interact with us, but may include:

2.1 Information you provide directly

• Full name
• Email address
• Phone number
• Location or address
• Employment or professional background
• Resume or CV
• Cover letter
• Answers submitted through application forms or questionnaires
• Uploaded documents
• Records of communications with us
• Any other information you choose to provide

2.2 Information collected automatically

When you visit our website or interact with online forms, we may collect technical and usage information such as:

• IP address
• Browser type and version
• Device type and operating system
• Date and time of access
• Pages viewed and website activity
• Referral URLs
• Cookies and similar tracking data
• Analytics and usage information

2.3 Information from third parties

Where lawful and appropriate, we may also receive personal information from third parties, such as:

• Service providers supporting our website, forms, communications, CRM, cloud storage, or application management
• Recruitment or referral partners
• Publicly available sources, including professional networking profiles or public resumes
• Individuals or organisations you ask to communicate with us in relation to your enquiry or application

We will only collect personal information from third parties where permitted by law.

3. How We Collect Personal Information

We collect personal information in several ways, including:

• Directly from you when you complete a form, submit an application, upload documents, email us, call us, or otherwise contact us
• Automatically when you use our website, including through cookies, analytics tools, and website logs
• From third parties where lawful, necessary, and relevant to our business activities

Where reasonably possible, we will collect personal information directly from you.

4. Why We Collect and Use Personal Information

We may collect, hold, use, and disclose personal information for purposes including:

• Responding to enquiries and requests
• Contacting you about your enquiry, application, or interest in our services
• Receiving, reviewing, and processing applications
• Assessing suitability for opportunities, programs, or services
• Managing candidate or applicant records
• Communicating with you about next steps, updates, or requested information
• Improving our website, forms, systems, and services
• Website analytics, performance monitoring, and troubleshooting
• Maintaining security, preventing fraud, misuse, and unauthorised access
• Meeting contractual, legal, regulatory, and compliance obligations
• Keeping appropriate internal records and audit trails
• Sending marketing or promotional communications where permitted by law
• Protecting our legal rights and resolving disputes

We will only use personal information for purposes that are lawful and reasonably related to our business activities, or for other purposes where you have consented.

5. Legal Bases for Processing Under GDPR

If the GDPR or UK GDPR applies to our handling of your personal information, we rely on one or more of the following legal bases, depending on the context:

5.1 Consent

We may process personal information where you have given consent, such as where you voluntarily submit information through a form or agree to receive marketing communications.

5.2 Contract

We may process personal information where it is necessary to take steps at your request before entering into a contract, or to perform a contract with you.

5.3 Legitimate Interests

We may process personal information where it is necessary for our legitimate interests, provided those interests are not overridden by your rights and interests. Examples may include:

• Managing enquiries and applications
• Operating and improving our website and services
• Securing our systems and preventing fraud
• Internal administration, recordkeeping, and business operations

5.4 Legal Obligation

We may process personal information where necessary to comply with applicable legal or regulatory obligations.

5.5 Legal Claims

We may process personal information where necessary to establish, exercise, or defend legal claims.

Where we rely on consent, you may withdraw that consent at any time, although this will not affect processing already carried out lawfully before withdrawal.

6. Cookies, Analytics, and Tracking Technologies

We may use cookies and similar technologies on www.saluspathways.com.au to:

• Keep the website functioning properly
• Understand how visitors use the website
• Improve user experience, content, and performance
• Support analytics and website administration
• Remember preferences where applicable

These technologies may collect information such as IP address, device information, browser details, and browsing behaviour.

Depending on your location and applicable law, we may rely on consent for non-essential cookies and tracking technologies. You may be able to manage cookies through your browser settings or any cookie preferences tool we make available on the website.

7. How We Share Information with Service Providers and Third Parties

We may share personal information where reasonably necessary for the purposes described in this Privacy Policy, including with:

• Website hosting providers
• Form processing providers
• Email and communication providers
• CRM and customer management providers
• Cloud storage and document management providers
• Analytics and website performance providers
• Recruitment or application management providers
• Professional advisers, including legal, compliance, and IT advisers
• Regulators, law enforcement, courts, or government bodies where required or authorised by law
• Other third parties with your consent or at your direction

Our service providers may process personal information on our behalf and under contractual or other legal arrangements designed to protect that information.

We do not sell personal information in the ordinary meaning of that term.

8. International Data Transfers

Because our website and service providers may operate internationally, personal information may be stored in or accessed from countries outside the country where you are located.

Where personal information is transferred internationally, we will take reasonable steps to ensure it is handled in a manner consistent with applicable privacy laws. Depending on the circumstances, these steps may include:

• Using reputable service providers with appropriate privacy and security measures
• Putting contractual protections in place
• Taking reasonable steps to ensure overseas recipients do not breach applicable privacy obligations
• Using lawful transfer mechanisms where required under GDPR or UK GDPR

If you are in the EU, EEA, or UK, international transfers may be made using lawful safeguards where required.

9. Data Retention

We retain personal information only for as long as reasonably necessary for the purposes described in this Privacy Policy, including to:

• Respond to enquiries
• Process and manage applications
• Maintain records and audit trails
• Comply with legal, regulatory, tax, accounting, or dispute-related obligations
• Enforce our terms and protect our legal interests

Retention may vary depending on the type of information, the purpose for which it was collected, and our legal obligations. When personal information is no longer required, we will take reasonable steps to delete, destroy, de-identify, or securely archive it as appropriate.

10. Data Security

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

• Access controls and role-based permissions
• Secure cloud storage and system protections
• Password and authentication controls
• Monitoring, backup, and system maintenance practices
• Secure handling of uploaded documents and application data
• Staff awareness and confidentiality measures where applicable

No system or method of internet transmission is completely secure. While we take reasonable precautions, we cannot guarantee absolute security.

11. Individual Rights

11.1 GDPR rights for EU/EEA/UK users

If the GDPR or UK GDPR applies, you may have the right to:

• Request access to your personal information
• Request correction of inaccurate or incomplete information
• Request deletion of your personal information in certain circumstances
• Request restriction of processing in certain circumstances
• Object to processing in certain circumstances, including some direct marketing and legitimate interest processing
• Request portability of certain personal information
• Withdraw consent where processing is based on consent
• Lodge a complaint with a relevant supervisory authority

These rights are not absolute and may be subject to legal exceptions.

11.2 Australian privacy rights and complaints process

If you are in Australia, you may request access to personal information we hold about you and request correction of inaccurate, out-of-date, incomplete, irrelevant, or misleading information, subject to lawful exceptions.

If you have a privacy concern or complaint, please contact us first using the contact details below so we can investigate and respond. If you are not satisfied with our response, you may contact the Office of the Australian Information Commissioner (OAIC).

12. How Users Can Access, Correct, or Delete Their Information

You may request access to, correction of, or deletion of your personal information by contacting us at info@saluspathways.com.au.

To help protect privacy and security, we may need to verify your identity before acting on your request.

Please note:

• We may refuse or limit a request where permitted by law
• We may need to retain certain information to comply with legal obligations, resolve disputes, enforce agreements, or maintain required records
• Deletion of some information may affect our ability to respond to you, process an application, or continue providing relevant services

13. Marketing Communications and Opt-Out Rights

Where permitted by law, we may send you marketing, updates, or promotional communications about our services, opportunities, or related information.

You can opt out of marketing communications at any time by:

• Clicking the unsubscribe link in an email, where available
• Contacting us at info@saluspathways.com.au
• Following any opt-out instructions provided in the communication

Even if you opt out of marketing, we may still send you service-related or transactional communications where necessary.

14. Children's Privacy

Our website and application process are not intended for children, and we do not knowingly collect personal information from children except where lawful and appropriate. If you believe a child has provided personal information to us without appropriate authorisation, please contact us so we can take appropriate steps.

15. Links to Third-Party Websites

Our website may contain links to third-party websites, platforms, or services. We are not responsible for the privacy practices, content, or security of those third parties. We encourage you to review their privacy policies before providing personal information to them.

16. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal obligations, or business operations. When we do, we will update the "Effective Date" above.

Where required by law, we will take reasonable steps to notify you of material changes.

17. Contact Us / Complaints

If you have questions, requests, or complaints about this Privacy Policy or our handling of personal information, please contact us:

If you make a privacy complaint, please provide enough detail for us to understand and investigate the issue. We will review your complaint and respond within a reasonable time.

If you are in Australia and are not satisfied with our response, you may contact the Office of the Australian Information Commissioner (OAIC).

If you are in the EU, EEA, or UK and the GDPR or UK GDPR applies, you may also have the right to lodge a complaint with the relevant data protection authority in your jurisdiction.