Privacy Policy

Effective date: 5 October 2026

Fin Darcy Pty Ltd (ABN 43 631 208 216) trading as Soteria 360 (“Soteria 360”, “we”, “us”, “our”) respects your privacy and handles personal information in line with the Privacy Act 1988 (Cth) and the Australian Privacy Principles. Our recruitment and career transition services are delivered under the Recruit360 name and are covered by this policy.

This policy explains how we collect, use, disclose and store personal information through our website, our services, our recruitment activities and our communications with clients, candidates and other contacts.

Who we are

Fin Darcy Pty Ltd trading as Soteria 360
16 Bancoura Parkway, Secret Harbour WA 6173
Website: soteria360.com.au
General and privacy enquiries: hello@soteria360.com.au
Recruitment and candidate enquiries: recruit@soteria360.com.au
Phone: 0435 774 696

What personal information we collect

Depending on how you deal with us, we may collect:

• your name, email address and phone number
• your organisation, job title and state or territory
• the service you are interested in and the information you give us in an enquiry or booking form
• newsletter, marketing and job alert preferences, including whether you have given marketing consent and when
• recruitment information, such as your CV, employment history, qualifications, licences, right to work in Australia and references
• career and capability assessment responses and the reports generated from them, where you choose to complete an assessment
• booking and payment details for our services (card payments are processed by our payment provider, Stripe, and we do not store full card details)
• vacancy or hiring information from employers
• records of our communications with you
• technical information about how you use our website, such as IP address, browser and device type, pages viewed, the page or advertisement that referred you, and cookie and analytics identifiers

Please do not include names or details of a specific incident, complaint, investigation or health matter in a website form. Tell us the type of help you need and we will discuss the details with you confidentially.

How we collect personal information

We collect personal information when you complete a form on our website, contact us by email or phone, book or buy a service, subscribe to updates, submit your CV or a vacancy, complete an assessment, interact with us on social media or advertising platforms, or browse our website. Where reasonable and practicable, we collect personal information directly from you.

Why we collect, hold, use and disclose personal information

We use personal information to:

• respond to enquiries and requests
• provide consulting, investigation, training, driver training, recruitment, career transition and related services
• manage our relationships with prospective and existing clients and candidates
• assess candidates for current or future opportunities
• send service updates, job alerts and marketing where you have agreed or the law allows
• measure and improve our website and advertising
• maintain and secure our systems
• comply with legal and regulatory obligations and protect our legal rights

Recruitment information

If you submit a CV or other recruitment information, we may use it to assess your suitability for current and future opportunities, contact you about roles, verify qualifications, licences, work history or references (only with your authorisation), and share relevant information with prospective employers or clients where reasonably necessary.

We will only contact your referees with your authorisation. If you give us information about another person, such as a referee, please make sure you are authorised to do so.

Registering with us, being represented to employers and being introduced to roles is free of charge. Buying any of our career services does not affect whether we put you forward for a role.

Career and capability assessments

Where you complete a career and capability assessment, your responses are used to generate your report and, if you are a candidate, to inform how we describe your strengths to you and, with your consent, to prospective employers. Assessments inform decisions made by people; they do not make decisions on their own. Results are held with your other recruitment information.

Use of technology

We use customer relationship, recruitment, assessment, booking and email platforms to manage our work. Personal information is stored only in systems we have approved for that purpose. We do not enter client or candidate personal information into artificial intelligence tools other than those we have specifically approved and that are subject to appropriate data handling terms.

Website tools, analytics and advertising

Our website uses cookies and similar technologies, including:

• Google Analytics 4, installed through Google Site Kit, to understand how visitors use the site, which pages they view and how they found us
• Google Tag Manager, which loads our measurement and advertising tags
• Google Ads conversion tracking and remarketing, including the conversion linker, to measure whether our ads lead to enquiries and to show our ads to people who have visited our site. When you submit a form, we send Google a protected (hashed) version of your email address and phone number with the enquiry, so Google can match it to an ad you clicked (this is known as enhanced conversions). We do not send the content of your enquiry.
• Meta Pixel and Conversions API, to measure the results of our Facebook and Instagram advertising and show our ads to relevant audiences. When you submit a form, we may send Meta a protected (hashed) version of your email address or phone number and the fact that an enquiry was made, so we can measure our ads. We do not send the content of your enquiry.

When you arrive from an advertisement, the website records the campaign tags and click identifiers in the address bar (such as utm codes, gclid or fbclid) and stores them with your enquiry so we know which advertising is working.

You can control cookies through your browser settings, opt out of Google Analytics using Google’s browser add-on, manage Google ad personalisation at adssettings.google.com, and manage Meta ad preferences in your Facebook or Instagram settings.

Disclosure of personal information

We may disclose personal information to:

• our directors, employees and contractors, including the contractors who operate our recruitment desk
• service providers who host, store or process information for us, including our website host (GoDaddy), website form processing (Vercel), form email delivery (Resend), customer relationship management, online booking and payment system (GoHighLevel, with card payments processed by Stripe), accounting and invoicing (Xero), email marketing (Brevo), Microsoft 365, and analytics and advertising providers (Google and Meta)
• recruitment clients, employers or hiring organisations
• training and operational partners where relevant to the services being delivered, such as Training Worx Australia (RTO 52508) for nationally recognised training
• professional advisers such as accountants, insurers and lawyers
• government agencies, regulators, law enforcement bodies, courts or tribunals where required or authorised by law

Overseas disclosure

Several of our service providers, including Vercel, Resend, GoHighLevel, Stripe, Xero, Google and Meta, may store or process personal information in the United States and other countries. Our recruitment desk includes team members based outside Australia who access candidate and client information through our approved systems. Where information is disclosed overseas, we take reasonable steps to ensure it is handled in a way that is consistent with the Australian Privacy Principles.

Direct marketing

We only send marketing to people who have agreed to receive it or where the law otherwise allows. When you give marketing consent on our website, we record the consent, the date and time, and the version of the wording you agreed to. You can opt out at any time using the unsubscribe link in our emails, replying STOP to our text messages, or contacting hello@soteria360.com.au.

Storage and security

We take reasonable steps to protect personal information from misuse, interference, loss and unauthorised access, modification or disclosure. These include secure and access-controlled systems, multi-factor authentication, restricted access to information and the use of reputable service providers. No method of electronic transmission or storage is completely secure, and we cannot guarantee absolute security.

Access and correction

You can ask for access to the personal information we hold about you and ask us to correct it if it is inaccurate, out of date or incomplete. Contact us using the details above. We may need to verify your identity before responding.

Retention

We keep personal information only for as long as reasonably necessary for the purposes it was collected for, or as required by law. Candidates may ask us at any time to remove their CV and recruitment information, and we will do so unless we are required to keep it.

Complaints

If you believe we have mishandled your personal information, please contact us at hello@soteria360.com.au with the details. We will consider your complaint and respond within a reasonable time. If you are not satisfied with our response, you can contact the Office of the Australian Information Commissioner (oaic.gov.au).

Third-party links

Our website may link to third-party websites, platforms or social media services. We are not responsible for their privacy practices and encourage you to read their privacy policies.

Changes to this policy

We may update this policy from time to time. The current version will always be published on our website.

© 2026 Fin Darcy Pty Ltd t/a Soteria 360