Privacy Policy

1. Information We Collect

Candidate Application Information

When you submit a candidate application through our website, we collect the following information:

• Full name, email address, and phone number
• Your current location and the role you are seeking
• Years of experience in the hospitality industry
• A written statement describing your career background and what you are looking for in your next role
• CV or résumé (uploaded as a PDF or Word document)
• Qualifications and certifications (uploaded documents or images, optional)
• Portfolio photographs of your work (up to three images, optional)
• Your public Instagram handle, where provided as an alternative portfolio link (optional)
• Any information you voluntarily include regarding visa or sponsorship requirements

Employer and Business Enquiry Information

When a business submits an enquiry through our website, we collect their email address, region, and hiring timeframe. In the course of follow-up communications, we may also collect the contact person's name, phone number, venue or business name, and details of the role or roles they are seeking to fill.

Additional Recruitment Information

In the course of the recruitment process, we may also collect employment history, right to work documentation (including VEVO checks where applicable), references provided by former employers, and other information relevant to assessing suitability for a role.

Age Requirement

Our services are intended for individuals aged 18 and over. We do not knowingly collect personal information from anyone under the age of 18. If you believe we have inadvertently collected information from a minor, please contact us and we will delete it promptly.

Website Usage Information

We collect anonymised information about interactions with our website, including pages visited, time spent on pages, and general device and browser information, for the purpose of improving user experience. This data does not identify you personally.

2. How We Collect Your Information and Why

• Directly from you: We collect information when you submit a candidate application, make a business enquiry, use our live chat, or communicate with us by any means.
• From third parties: We may receive information from references, former employers, or background screening agencies as part of the recruitment process.
• From social media platforms: As part of our recruitment activities, we may review publicly available profiles and information on LinkedIn, Facebook, Instagram, X (formerly Twitter), and WhatsApp to assess candidate suitability or identify potential candidates. We only collect information that is publicly available or that you have shared with us directly through these platforms.
• Legitimate interests: We collect and process personal information to conduct recruitment activities, assess candidate and client suitability, facilitate placements, and comply with our legal obligations under Australian law.

3. How We Use Your Information

• Candidate assessment: We use application information — including written statements, CVs, portfolio photographs, qualifications, and social media handles — solely to assess your suitability for permanent hospitality roles. Portfolio materials are reviewed by our recruitment team and are never published or shared publicly.
• Candidate presentation: With your explicit consent, we may share your profile (including relevant application materials) with prospective employers. We will always speak with you before presenting you to any client.
• Employer matching: We use employer enquiry information to identify and propose suitable candidates for their vacancies.
• Job advertising: When advertising a role on behalf of a client, we may include publicly available details about the client's business in the job description, such as their Instagram handle, website URL, or venue name. We will only include information that is already publicly available or that the client has provided to us for this purpose.
• Communication and direct marketing: We use your contact details to correspond with you about your application or enquiry, and to keep you informed of relevant opportunities. If you no longer wish to receive marketing communications, you may opt out at any time by clicking the unsubscribe link in any email or by contacting us directly.
• Website improvement: We use anonymised usage data to analyse trends and improve the performance and content of our website.

4. Information Sharing and Third-Party Services

We do not sell your personal information. We share it only as described below.

• Prospective employers (candidates only): With your prior consent, we may share relevant application materials with client businesses for the purpose of facilitating a placement.
• Cookaburra Ltd (sister company, United Kingdom): We may share personal information with our sister company Cookaburra Ltd, based in the United Kingdom, where relevant to recruitment activities or business operations. Any such sharing is conducted under confidentiality obligations and in accordance with the Australian Privacy Principles.
• Mailchimp (email marketing): When a business submits an enquiry through our website, their email address and enquiry details may be added to our Mailchimp audience for follow-up communications. Mailchimp is operated by The Rocket Science Group LLC (Intuit), a US-based service. Mailchimp's privacy policy is available at mailchimp.com/legal/privacy.
• Tawk.to and WhatsApp (live chat): Our website uses Tawk.to to provide live chat support, which is integrated with WhatsApp. If you use the chat feature, your messages may be processed by both Tawk.to and Meta Platforms, Inc. (WhatsApp). Tawk.to may collect your messages and, where provided, your name and email address. Tawk.to's privacy policy is available at tawk.to/privacy-policy. WhatsApp's privacy policy is available at whatsapp.com/legal/privacy-policy.
• Social media platforms: We maintain business profiles on LinkedIn, Facebook, Instagram, X (formerly Twitter), and WhatsApp. If you interact with us through these platforms, the relevant platform's privacy policy applies to that interaction. These platforms are operated by US-based companies (Meta Platforms, Inc.; LinkedIn Corporation; X Corp) and your information will be subject to their respective terms and privacy policies.
• Calendly (appointment scheduling): Our website uses Calendly to allow clients and candidates to book discovery calls. Calendly collects names, email addresses, and scheduling information. Calendly is a US-based service. Calendly's privacy policy is available at calendly.com/privacy.
• Granola (meeting recording): We use Granola to record and transcribe sessions with clients and candidates. Audio recordings and transcripts may contain personal information discussed during these sessions. Granola is a US-based service. We will inform participants before recording any session. Granola's privacy policy is available at granola.ai/privacy.
• Slack (internal communications): We use Slack for internal team communications. Personal information relating to candidates or clients may be referenced in Slack channels as part of our recruitment workflow. Slack is operated by Slack Technologies LLC (Salesforce), a US-based company. Slack's privacy policy is available at slack.com/privacy-policy.
• Artificial intelligence tools: We may use AI-powered tools including Grok (xAI Corp), Claude (Anthropic), and Dia (The Browser Company) to assist with tasks such as drafting communications or summarising information. Where personal information is used in conjunction with these tools, we take care to use only what is necessary. These tools are operated by US-based companies and are subject to their respective privacy policies.
• Google Tag Manager: We use Google Tag Manager to manage and deploy tracking scripts on our website, including Google Analytics and the Meta Pixel. Google Tag Manager itself does not collect personal information but facilitates the loading of other tools that may. Google Tag Manager is operated by Google LLC, a US-based company.
• Meta Pixel (Facebook advertising): Our website uses the Meta Pixel to track conversions from Facebook and Instagram advertising campaigns and to support remarketing. The Meta Pixel collects information about your visit to our website and shares it with Meta Platforms, Inc., a US-based company. Meta's privacy policy is available at facebook.com/privacy/policy.
• Google Analytics (website analytics): Our website uses Google Analytics to collect anonymised data about how visitors interact with our website, including pages visited and time spent on pages. Google Analytics uses cookies and may transfer data to Google LLC servers in the United States. You can opt out of Google Analytics tracking via your browser settings or the Google Analytics opt-out browser add-on.
• Microsoft Clarity (behaviour analytics): Our website uses Microsoft Clarity to record anonymised user sessions, including clicks, scrolls, and mouse movements, to help us improve the website experience. Session recordings may incidentally capture information entered into forms. We have configured Clarity to mask sensitive form fields. Clarity is operated by Microsoft Corporation, a US-based company. Microsoft's privacy policy is available at privacy.microsoft.com/privacystatement.
• Google Workspace (email): We use Google Workspace to send and receive email communications, including form enquiries and candidate applications submitted through our website. Emails and their attachments are processed and stored by Google LLC, a US-based company. Google's privacy policy is available at policies.google.com/privacy.
• Xero (accounting and payroll): We use Xero to manage our accounting, invoicing, and payroll obligations. Information relating to placed candidates and client businesses (such as names, contact details, financial information, and where applicable, Tax File Numbers) may be stored in Xero. Tax File Numbers are treated as sensitive information and are collected and held only as required by law. Xero is a New Zealand-based company and may process data outside Australia. Xero's privacy policy is available at xero.com/au/legal/privacy.
• Giig Hire (candidate management): We use Giig Hire, a UK-based recruitment platform, to store and manage candidate CVs and profiles. Candidate information held in Giig Hire is stored on servers located in the United Kingdom. By submitting an application, you consent to this transfer. Giig Hire's privacy policy is available at giighire.com/privacy-policy.
• Vercel Analytics: Our website uses Vercel Analytics for anonymised, aggregate website performance data. No personally identifiable information is collected by this service.
• Other service providers: We may share information with other trusted service providers who assist us in business operations (e.g., IT support, background screening) under confidentiality obligations.
• Legal compliance: We may disclose personal information when required by law or in response to lawful requests from government authorities.

Application and enquiry forms submitted through our website are processed by our own servers hosted in Australia (Sydney region). Where personal information is transferred outside Australia (for example, to Cookaburra Ltd or via Giig Hire in the United Kingdom, or via Google Workspace, Google Analytics, Google Tag Manager, Meta Pixel, Microsoft Clarity, Calendly, Granola, Slack, Mailchimp, Tawk.to, WhatsApp, Xero, AI tools, or social media platforms), we take reasonable steps to ensure it is handled in accordance with the Australian Privacy Principles.

5. Portfolio Materials and Creative Work

Photographs, documents, and other portfolio materials submitted as part of a candidate application are used only for internal assessment purposes. They are not published, displayed publicly, or shared with any party other than prospective employers (with your consent). You may request deletion of your portfolio materials at any time by contacting us.

6. Data Security

We employ reasonable industry-standard security measures to protect your personal information from unauthorised access, use, or disclosure. However, no transmission or storage method is 100% secure. We encourage you to contact us immediately if you believe your information has been compromised.

7. Notifiable Data Breaches

We are subject to the Notifiable Data Breaches (NDB) scheme under the Privacy Act 1988 (Cth). If we become aware of a data breach that is likely to result in serious harm to any individual whose personal information is involved, we will notify the affected individual(s) and the Office of the Australian Information Commissioner (OAIC) as soon as practicable. We maintain an internal data breach response procedure to ensure we meet our obligations under the NDB scheme.

8. Privacy Act 1988 (Cth) and Australian Privacy Principles Compliance

Two Birds Group Pty Ltd complies with the Privacy Act 1988 (Cth), the Australian Privacy Principles, and other applicable data protection laws and regulations.

10. Data Retention

We retain personal information for as long as necessary to fulfil the purposes outlined in this Policy, or as required by law. Candidate information is retained for a reasonable period after the conclusion of a recruitment engagement so that we may consider you for future opportunities, unless you request deletion. You may request that we delete your information at any time by contacting us.

11. Your Data Protection Rights

Under the Privacy Act 1988 (Cth) and Australian Privacy Principles, you have the following rights:

• Right of access: You may request copies of the personal information we hold about you.
• Right to rectification: You may ask us to correct personal information that is inaccurate or incomplete.
• Right to erasure: You may ask us to delete your personal information in certain circumstances.
• Right to restrict processing: You may ask us to limit how we process your personal information in certain circumstances.
• Right to object: You may object to the processing of your personal information in certain circumstances.
• Right to data portability: You may ask us to transfer your personal information to another organisation or directly to you in certain circumstances.

There is no charge for exercising these rights. We will respond to requests within a reasonable timeframe and no later than 30 days.

12. Cookies

Our website uses cookies and similar technologies for the following purposes:

• Consent: A cookie records whether you have accepted or declined our cookie notice.
• Analytics: Google Analytics and Microsoft Clarity use cookies to collect anonymised data about how visitors interact with our website, including pages visited, session duration, and user behaviour.
• Session recording: Microsoft Clarity records anonymised session replays (clicks, scrolls, mouse movements) to help us improve the website.
• Advertising: The Meta Pixel (Facebook) uses cookies to track conversions and support advertising on Facebook and Instagram.
• Live chat: Tawk.to sets cookies to support the live chat function on our website.
• Booking: Calendly sets cookies when you use the booking widget to schedule a call.

You can control cookies through your browser settings. Declining cookies via our cookie notice will prevent analytics, session recording, and advertising cookies from being set. Some functionality (such as live chat and booking) may be affected if cookies are disabled. For more information, see the privacy policies of the respective third-party services listed in section 4.

13. How to Complain

If you have any concerns about our use of your personal information, please contact our Privacy Officer in the first instance using the details in section 14. We will endeavour to resolve your concern promptly.

If you remain unsatisfied, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC):

14. Contact Us

To exercise your rights, request deletion of your data, or raise a privacy concern, please contact our Privacy Officer:

15. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. The effective date at the top of this page indicates when it was last revised. We encourage you to review this Policy periodically.