HR Navigator ABN 95 132 828 689

Effective Date: 31 July 2026

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1. Introduction

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1.1 About this Policy.

This Privacy Policy explains how HR Navigator (ABN 95 132 828 689) (“HR Navigator,” “we,” “us,” or “our”) collects, holds, uses, and discloses personal information. It applies to all personal information we handle, whether collected through our website at www.hrnavigator.com.au (the “Website”), through our consulting engagements, or by any other means.

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1.2 Our Commitment.

HR Navigator is committed to protecting the privacy of every individual whose personal information we handle. We comply with the Australian Privacy Principles (“APPs”) contained in the Privacy Act 1988 (Cth) (the “Privacy Act”) and any applicable state or territory privacy legislation. Where the small business exemption under section 6D of the Privacy Act may apply, we have elected to comply with the APPs as a matter of best practice and professional obligation.

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1.3 Scope.

This Policy covers personal information collected from: (i) visitors to our Website; (ii) individuals who submit enquiry, booking, or contact forms; (iii) clients and their employees, contractors, and representatives with whom we engage in the course of delivering HR consulting and advisory services; (iv) subcontractors and prospective employees of HR Navigator; and (v) any other individual whose personal information we receive in connection with our business.

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1.4 Consent.

By using our Website, submitting information to us, or engaging our services, you consent to the collection, use, and disclosure of your personal information in accordance with this Policy. Where we are required by law to obtain your express consent for specific uses, we will do so separately.

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2. Information We Collect

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2.1 Personal Information.

“Personal information” means information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information or opinion is true or not and whether recorded in a material form or not. The types of personal information we may collect include:

1. Identity and Contact Information — name, email address, phone number, postal address, job title, and employer or organisation name;

2. Engagement Information — details provided when booking a consultation, submitting an enquiry form, or entering into a Services Agreement, including the nature of your enquiry, your organisation’s size, industry, and workforce details relevant to the services requested;

3. Client Workforce Information — information about your employees, contractors, or other personnel that you provide to us in the course of an engagement, which may include names, positions, employment terms, performance records, disciplinary records, remuneration details, and other HR-related data;

4. Financial Information — billing details, bank account or payment information necessary to process invoices and payments;

5. Technical and Usage Information — IP address, browser type, device identifiers, pages visited, time spent on pages, referring URLs, and other data collected automatically when you visit the Website; and

6. Communications — records of correspondence between you and HR Navigator, including emails, phone call notes, and meeting records.

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2.2 Sensitive Information.

We do not generally seek to collect sensitive information (such as information about racial or ethnic origin, political opinions, religious beliefs, health, or criminal record). However, in the course of delivering workplace investigation, employee relations, or HR advisory services, clients may provide us with sensitive information about their personnel. Where this occurs, we handle that information with the heightened protections required under the APPs and only with consent or as otherwise permitted by law.

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2.3 Unsolicited Information.

If we receive personal information that we did not solicit and determine that we could not have collected it under the APPs, we will destroy or de-identify that information as soon as practicable, unless retention is required or authorised by law.

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2.4 Anonymity and Pseudonymity.

Where practicable, you may deal with us without identifying yourself or by using a pseudonym. However, if you choose not to provide personal information we request, we may not be able to provide our services to you or respond to your enquiry.

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3. How We Collect Information

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3.1 Direct Collection.

We collect most personal information directly from you through: (i) our Website booking and enquiry forms; (ii) email, telephone, and in-person communications; (iii) Services Agreements, Service Orders, and engagement documentation; and (iv) workshops, training sessions, and meetings.

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3.2 Collection from Third Parties.

We may collect personal information about you from third parties where: (i) your employer or organisation provides information about you in connection with an engagement (for example, employee details for a workplace investigation); (ii) a referee provides information about you in connection with recruitment; or (iii) publicly available sources provide information relevant to our services. Where we collect information about you from a third party, we will take reasonable steps to ensure you are made aware of this Policy.

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3.3 Automatic Collection.

When you visit the Website, we may automatically collect technical and usage information through cookies, web beacons, and similar technologies. You can manage cookie preferences through your browser settings. Disabling cookies may affect your experience on the Website. Details about the cookies we use are set out in Section 10.

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4. Purpose of Collection — How We Use Your Information

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4.1 Primary Purposes.

We collect, hold, and use personal information for the following primary purposes:

1. to respond to your enquiries and booking requests;

2. to provide HR consulting, advisory, and related professional services under our Services Agreements;

3. to manage our client relationships, including scheduling, invoicing, and communications;

4. to conduct workplace investigations, reviews, and assessments as engaged by our clients;

5. to administer our subcontractor and employment relationships;

6. to comply with our legal and regulatory obligations; and

7. to manage and improve our Website and business operations.

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4.2 Secondary Purposes.

We may also use your personal information for secondary purposes that are related to the primary purposes and that you would reasonably expect, including:

1. to send you information about our services, events, or resources that may be relevant to you (you may opt out of these communications at any time by contacting us or using the unsubscribe function in our emails);

2. to analyse Website usage and improve our online presence;

3. to seek feedback on our services; and

4. for internal training, quality assurance, and business development purposes, provided that client-identifying information is removed or de-identified where practicable.

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4.3 No Other Use.

We will not use or disclose your personal information for a purpose other than a purpose set out in this Policy, a purpose you would reasonably expect, or a purpose permitted or required by law.

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5. Disclosure of Personal Information

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5.1 Who We May Disclose To.

We may disclose your personal information to:

1. Subcontractors and Service Providers — freelance HR consultants, investigators, or other professionals engaged by HR Navigator to deliver services on our behalf, who are bound by confidentiality and privacy obligations under their agreements with us;

2. Professional Advisors — our legal advisors, accountants, auditors, and insurers as necessary for the operation of our business;

3. Technology Providers — third-party platforms that support our Website, booking system, email, cloud storage, and business operations, who are required to handle personal information in accordance with their own privacy policies and applicable law;

4. Regulatory and Law Enforcement Bodies — where required or authorised by law, including in response to a court order, subpoena, or regulatory request;

5. Your Employer or Organisation — where personal information is collected during a client engagement (such as a workplace investigation), we may disclose findings and related information to the client organisation as necessary to fulfil the engagement, subject to applicable legal requirements; and

6. Other Parties with Your Consent — where you have given express consent to the disclosure.

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5.2 No Sale of Personal Information.

We do not sell, rent, or trade personal information to any third party.

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5.3 Cross-Border Disclosure.

HR Navigator does not ordinarily disclose personal information to overseas recipients. If this changes, we will update this Policy and take reasonable steps to ensure that any overseas recipient handles personal information in accordance with the APPs, or that you consent to the transfer, or that the transfer is otherwise permitted under the Privacy Act.

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6. Data Security

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6.1 Security Measures.

We take reasonable steps to protect personal information from misuse, interference, loss, and from unauthorised access, modification, or disclosure. Our security measures include:

1. restricting access to personal information to authorised personnel and subcontractors who require it to perform their duties;

2. using password protection, encryption, and secure access controls for electronic records;

3. requiring subcontractors and employees to comply with confidentiality obligations;

4. storing physical records in secured locations; and

5. conducting periodic reviews of our information security practices.

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6.2 No Guarantee.

While we take reasonable precautions, no data transmission over the internet or electronic storage method is completely secure. We cannot guarantee the absolute security of personal information transmitted to or stored by us.

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6.3 Data Breaches.

In the event of an eligible data breach (or suspected eligible data breach) as defined under Part IIIC of the Privacy Act, we will comply with the Notifiable Data Breaches scheme, including assessing the breach, taking remedial action, and notifying the Office of the Australian Information Commissioner (“OAIC”) and affected individuals as required.

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7. Data Retention and Destruction

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7.1 Retention Period.

We retain personal information for as long as it is needed for the purposes for which it was collected, or as required by law. As a general guide:

1. client engagement records are retained for seven (7) years after the conclusion of the engagement;

2. financial and invoicing records are retained for seven (7) years as required by taxation legislation;

3. Website usage data is retained for twenty-four (24) months; and

4. enquiry and booking form data, where no engagement follows, is retained for twelve (12) months and then destroyed or de-identified.

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7.2 Destruction and De-identification.

When personal information is no longer needed for any purpose permitted under this Policy or required by law, we will take reasonable steps to destroy or de-identify it. Destruction methods include secure deletion of electronic records and shredding of physical documents.

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8. Access and Correction

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8.1 Your Right to Access.

You have the right to request access to the personal information we hold about you. To make a request, contact us using the details in Section 12. We will respond to your request within thirty (30) days and provide access in a manner that is reasonable in the circumstances.

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8.2 Exceptions to Access.

We may refuse access in the circumstances permitted by the Privacy Act, including where: (i) providing access would pose a serious threat to the life, health, or safety of any individual; (ii) providing access would unreasonably impact the privacy of others; (iii) the request is frivolous or vexatious; (iv) the information relates to existing or anticipated legal proceedings and would not be discoverable; or (v) providing access would be unlawful or would prejudice an investigation or enforcement activity. If we refuse access, we will give you a written explanation of our reasons.

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8.3 Correction.

If you believe that personal information we hold about you is inaccurate, incomplete, out of date, or misleading, you may request that we correct it. We will respond to correction requests within thirty (30) days. If we refuse to make a correction, we will give you a written explanation of our reasons and, if you request it, we will associate a statement with the information noting that you consider it inaccurate, incomplete, out of date, or misleading.

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9. Complaints

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9.1 Making a Complaint.

If you believe we have breached the APPs or otherwise mishandled your personal information, you may lodge a complaint with us using the contact details in Section 12. We will acknowledge your complaint within five (5) business days and investigate it promptly.

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9.2 Resolution.

We aim to resolve complaints within thirty (30) days. We will notify you of the outcome in writing, including any steps we have taken or propose to take.

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9.3 Escalation to the OAIC.

If you are not satisfied with our response, you may escalate your complaint to the Office of the Australian Information Commissioner:

Office of the Australian Information Commissioner GPO Box 5218, Sydney NSW 2001 Phone: 1300 363 992 Website: www.oaic.gov.au

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10. Cookies and Website Analytics

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10.1 What Are Cookies.

Cookies are small text files placed on your device when you visit a website. They help us understand how visitors use the Website and improve your browsing experience.

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10.2 Types of Cookies We Use.

1. Essential Cookies — required for the Website to function properly, including session management and security;

2. Analytics Cookies — used to collect information about how visitors interact with the Website, including pages visited, time spent, and traffic sources. We may use third-party analytics services such as Google Analytics for this purpose; and

3. Functional Cookies — used to remember your preferences and settings to improve your experience.

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10.3 Managing Cookies.

You can control and manage cookies through your browser settings. Most browsers allow you to refuse cookies, delete existing cookies, or set preferences for certain websites. Note that disabling certain cookies may affect the functionality of the Website, including the booking system.

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10.4 Google Analytics.

If we use Google Analytics, it collects information anonymously and reports website trends without identifying individual visitors. You can opt out of Google Analytics by installing the Google Analytics Opt-out Browser Add-on, available at tools.google.com/dlpage/gaoptout.

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11. Changes to This Policy

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11.1 Updates.

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. The updated Policy will be posted on the Website with a revised effective date.

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11.2 Notification. Where a change is material, we will take reasonable steps to notify you, including by posting a prominent notice on the Website. Your continued use of the Website or our services after a change constitutes acceptance of the updated Policy.

11.3 Prior Versions. Prior versions of this Policy are available on request.

12. Contact Us

12.1 Privacy Enquiries. If you have any questions about this Privacy Policy, wish to make an access or correction request, or wish to lodge a complaint, please contact us at:

HR Navigator ABN 95 132 828 689

Email: hello@hrnavigator.com.au Phone: 0418 839 905 Website: www.hrnavigator.com.au

13. Statutory Tort for Serious Invasion of Privacy

13.1 Your Rights. From 10 June 2025, individuals have a statutory right under the Privacy Act to take legal action for a serious invasion of their privacy. This right applies regardless of whether the entity involved is otherwise covered by the Privacy Act. HR Navigator takes its obligations seriously and has implemented the practices described in this Policy to protect your personal information and privacy.

14. Governing Law

14.1 This Privacy Policy is governed by and construed in accordance with the laws of Western Australia and the Commonwealth of Australia. Any disputes arising under or in connection with this Policy are subject to the jurisdiction of the courts of Western Australia.