Our Commitment to Privacy
At 360now, we understand that privacy is paramount when dealing with personal and professional feedback. This Privacy Statement outlines how we collect, use, protect, and disclose information in relation to our 360-degree review services.
Information We Collect
Personal Information: We collect personal data such as names, email addresses, and job titles from users to provide our services. This information is necessary to personalise feedback, send notifications, and manage accounts.
Feedback Data: The content of the reviews, including ratings and comments, is collected to generate insights for the users.
Sensitive Information: Because the comment fields in our surveys are free-text, a response may occasionally include sensitive information (for example, information about a person's health), as defined under the Privacy Act 1988 (Cth). We do not ask for sensitive information and it is not required to complete a review. Where such information is voluntarily included in a comment, you consent to us collecting and handling it for the purpose of preparing the feedback report, as described in this Privacy Statement. We ask that raters avoid including sensitive information about themselves or others in their comments.
Usage Data: We automatically collect information on how our website and services are accessed and used, including IP addresses, browser type, and interaction data.
We only collect and use personal data where you have given clear, informed consent. You may withdraw your consent at any time.
How We Use Your Information
Service Provision: To conduct 360-degree reviews, deliver feedback reports, and provide customer support.
Improvement of Services: To analyse usage patterns for enhancing our platform's functionality and user experience.
Communication: To send you updates, security alerts, and marketing communications if you opt in.
Automated Processing: Feedback reports, including competency summaries and development recommendations, are generated using automated systems, including third-party artificial intelligence tools (see "AI Report Generation" below). These processes summarise and structure feedback already provided by raters; they do not make decisions about your employment, engagement, or any other outcome that affects your legal rights.
Sharing of Information
Service Providers: We may share data with third-party service providers who assist us in delivering our services (e.g., hosting providers, analytics services). These providers are bound by confidentiality obligations.
Overseas Disclosure: Some of our service providers, including our AI report-generation provider (see "AI Report Generation" below), are located outside Australia, including in the United States. Where we disclose your information overseas, we take reasonable steps to ensure the recipient handles it consistently with the Australian Privacy Principles.
Legal Compliance: We will disclose information if required by law or in response to valid legal requests.
Aggregated Data: We may use de-identified, aggregated response data for research and marketing purposes, including instrument research and validation of our competency framework (see "Research and Instrument Development" below), which does not identify you personally.
Research and Instrument Development
We use de-identified, aggregated response data – data that has had names, contact details, and other identifying information removed, and is combined across multiple respondents – to research and improve the 360now assessment instrument. This includes validating the reliability of our competency framework, benchmarking results across industries, and refining how questions are scored.
Because this data is de-identified and aggregated, it cannot reasonably be used to re-identify you. We do not use your individually identifiable feedback responses for this purpose without your separate consent.
AI Report Generation
To generate written summaries and development recommendations within your 360now report, we share relevant feedback content – including raters' comments and competency scores – with OpenAI OpCo, LLC, a United States-based artificial intelligence service provider. This may involve your feedback data being processed and stored on servers located outside Australia. We have reviewed OpenAI's data handling and retention practices and only share the information reasonably necessary to generate your report. OpenAI processes this data as our service provider under a data processing agreement and does not use it to train its models. We take reasonable steps to ensure this overseas handling is consistent with the Australian Privacy Principles.
Data Security
We implement industry-standard security measures to protect your data from unauthorised access, alteration, disclosure, or destruction. However, no method of transmission over the Internet or electronic storage is 100% secure.
Your Rights
Access and Correction: You have the right to access, update, or delete your personal information by contacting us.
Opt-Out: You can opt out of marketing communications at any time.
Data Portability: Upon request, we'll provide you with a copy of your personal data in a commonly used format.
Right to Erasure: You may request that we delete your personal data when it is no longer needed, consent has been withdrawn, or it was collected unlawfully.
Retention of Data
We retain personal information only for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements.
Changes to This Privacy Statement
We may update our Privacy Statement from time to time. We will notify you of any changes by posting the new Privacy Statement on this page.