Privacy Policy

New Horizon Code PTY LTD ("New Horizon Code", "we", "us", or "our") respects your privacy and is committed to protecting the personal information you share with us. This Privacy Policy describes how we collect, use, store, disclose, and protect your information in accordance with the Australian Privacy Act 1988 (Cth), the EU General Data Protection Regulation (GDPR), and any other applicable privacy laws.

By using our services, including our websites, web applications, customer support portals, and any software products (collectively, the "Services"), you consent to the practices described in this Privacy Policy.

This policy applies to all data collected through:

• Our websites and applications (including Diversity Sync'd, Carey, TobyHR, Profile Dock, Syrup, and other platforms developed or maintained by us)
• Our support services, via chat, phone, email, or ticketing platforms
• Marketing channels and social media pages
• Any platform or sub-service integrated with or operated by New Horizon Code

We may collect the following categories of personal information, either directly from you or automatically:

We work with trusted third-party service providers to deliver our services effectively. These sub-processors may have access to your personal information as necessary to perform their functions:

When you contact us by phone via our official support number (1300 980 034) or through any New Horizon Code-operated voice service, you acknowledge and agree to the following:

• Calls may be recorded, transcribed, or monitored, either manually or via automated systems
• AI-based tools may be used to transcribe calls, detect support topics, summarise interactions, or flag potential quality or compliance issues
• These systems may operate in real time or post-call, and data may be reviewed by authorised staff or systems only
• Recordings and transcripts are securely stored and only retained as long as needed for support, auditing, compliance, or training purposes

We process your personal information for the following legitimate business purposes:

We do not sell, rent, or otherwise commercially distribute your personal information to third parties. However, we may share your information in the following limited circumstances:

• With Your Consent: When you explicitly authorize us to share information
• Service Providers: With sub-processors as outlined in Section 5
• Legal Requirements: To comply with laws, court orders, or regulatory demands
• Business Transfers: In connection with mergers, acquisitions, or asset sales
• Safety and Security: To protect rights, property, or safety of users and the public

We implement industry-standard security measures to protect your personal information from unauthorized access, alteration, disclosure, or destruction:

Personal data is retained in accordance with our Data Retention Policy, which outlines retention periods for account data, call logs, AI interaction summaries, and support records. Voice recordings and call-related transcriptions are typically retained for no longer than 90 days, unless required by law or internal audit.

We retain information only as long as necessary to fulfill the purposes outlined in this policy, comply with legal obligations, resolve disputes, and enforce our agreements.

Depending on your location and applicable privacy laws, you may have the following rights regarding your personal information:

We use cookies and similar technologies to enhance your experience, analyze usage patterns, and deliver personalized content. You can control cookie settings through your browser preferences.

Your personal information may be transferred to and processed in countries outside Australia, including the United States and European Union, where our service providers operate. We ensure appropriate safeguards are in place through:

• Standard contractual clauses approved by relevant authorities
• Adequacy decisions recognizing equivalent privacy protections
• Binding corporate rules and certification mechanisms
• Explicit consent where required by applicable law

Our services are not directed to individuals under 16 years of age. We do not knowingly collect personal information from children under 16. If we become aware that we have collected information from a child under 16 without verified parental consent, we will take steps to delete such information promptly.

Parents and guardians who believe their child has provided personal information to us should contact us immediately using the details in Section 17.

Our services may contain links to third-party websites, applications, or services that are not owned or controlled by New Horizon Code. This Privacy Policy does not apply to such third-party services.

We encourage you to review the privacy policies of any third-party services before providing personal information. We are not responsible for the privacy practices or content of third-party services.

We may update this Privacy Policy to reflect legal, technical, or operational changes. We will notify users of material updates via email or platform alerts. Continued use of our services after an update constitutes acceptance of the new policy.

We recommend reviewing this policy periodically to stay informed about how we protect your privacy. The "Last updated" date at the top of this policy indicates when it was most recently revised.