Privacy Policy

Twoconnect is committed to protecting personal information and handling it openly, fairly and securely. This Privacy Policy explains how Twoconnect collects, uses, discloses, stores and protects personal information when individuals visit our website, communicate with us, enquire about our services, subscribe to updates, attend events or apply for employment opportunities.

In this policy, “Twoconnect”, “we”, “us” and “our” refer to the Twoconnect business entities relevant to the interaction, including Twoconnect Philippines, Inc. We operate in Australia and the Philippines and handle personal information in accordance with applicable privacy laws, including the Australian Privacy Act 1988 and the Philippines Data Privacy Act of 2012, together with applicable contractual obligations and our information security management framework.

1. Scope

This policy applies to personal information handled through the Twoconnect website and related external communications. Separate collection notices, client agreements, recruitment notices or employee privacy documents may apply to particular services, applications or relationships. Where a more specific notice applies, that notice should be read together with this policy.

2. Personal information we collect

We may collect personal information that an individual voluntarily provides when the individual:

• submits a website enquiry or service request;
• contacts our team;
• downloads resources or registers for an event;
• subscribes to marketing communications; or
• applies for an employment opportunity.

Depending on the interaction, this may include a name, company, job title, email address, telephone number, communication content and other information reasonably required to respond to the request.

Recruitment information

If an individual applies for a role, we may also collect information contained in the application, such as employment history, education, qualifications, work eligibility, professional references and other recruitment-related information.

Technical and usage information

When an individual uses our website, we may automatically collect technical information such as IP address, browser type, device information, referring pages, pages visited, dates and times of access, and website interaction data through cookies, logs and similar technologies.

Sensitive or unnecessary information

Please do not submit sensitive personal information, identity documents, account credentials, client confidential information or other information that is not reasonably necessary for the enquiry, unless Twoconnect specifically requests it through an approved channel.

3. How we collect personal information

We generally collect personal information directly from the individual. Where permitted by law, we may also receive personal information from recruitment platforms, referrers, clients, service providers, event partners or publicly available professional sources.

4. How we use personal information

We may use personal information to:

• respond to enquiries and provide information about our services;
• manage prospective and existing client relationships;
• process recruitment applications and communicate with candidates;
• administer events, downloads and subscriptions;
• operate, secure, analyse and improve our website and user experience;
• send relevant marketing communications where permitted by law;
• prevent, detect, investigate and respond to fraud, misuse or security incidents; and
• meet legal, regulatory, contractual, recordkeeping and dispute-resolution requirements.

5. Legal bases and consent

Depending on the applicable law and the purpose of processing, Twoconnect may process personal information with consent, to take steps requested before entering into a contract, to perform a contract, to comply with a legal obligation, or for a legitimate business purpose that is not overridden by the individual’s rights and interests. Where consent is required, consent may be withdrawn by contacting us, subject to legal and operational limitations.

6. Marketing communications

Twoconnect may send marketing communications where permitted by law. An individual may unsubscribe at any time through the unsubscribe link in the message or by contacting us. Twoconnect may still send non-marketing communications relating to an enquiry, application, service, security matter or legal obligation.

7. Sharing personal information

Twoconnect does not sell personal information. Where reasonably necessary for the purposes described in this policy, we may disclose or make personal information available to:

• Twoconnect entities and authorised personnel;
• trusted technology, hosting, analytics, communications, recruitment and other service providers;
• professional advisers such as auditors, insurers, lawyers or consultants;
• clients or business partners where disclosure is authorised, required for the relevant service or otherwise permitted by law; and
• regulators, law enforcement bodies, courts or other authorities where required or authorised by law.

Third parties that process personal information on our behalf are expected to maintain appropriate security and confidentiality and to process information consistently with applicable obligations and agreed purposes.

8. International data handling and transfers

Twoconnect operates in Australia and the Philippines. Personal information may be disclosed or made accessible to authorised personnel and service providers in those countries. Some technology providers may also process information in other countries or regions. Where overseas disclosure occurs, Twoconnect takes reasonable steps required by applicable law and its contractual arrangements to protect the information.

9. Cookies and similar technologies

Our website uses essential cookies required for website operation and may use analytics or marketing cookies to measure website use, improve content and support communications. Where required, non-essential cookies are used only after consent is provided. Available preferences may be managed through the website’s cookie settings and through browser controls.

Third-party analytics or embedded services may apply their own privacy practices. Additional information about cookie categories, providers and durations should be made available through the website cookie notice or consent interface.

10. Protecting personal information

Twoconnect uses administrative, technical and physical safeguards appropriate to the nature and risk of the information handled. These may include access controls, multi-factor authentication, encryption, endpoint security, monitoring, personnel awareness, incident management, secure information handling and supplier controls. Twoconnect’s information security practices are supported by its information security management framework and its ISO/IEC 27001:2022 certification scope.

No method of transmission or storage is completely secure. Twoconnect continually manages information-security risk and reviews safeguards as business, technology and regulatory requirements change.

11. Data retention and disposal

Twoconnect retains personal information only for as long as reasonably necessary for the purpose for which it was collected and to meet legal, regulatory, contractual, dispute-resolution and recordkeeping requirements. Retention periods vary according to the record type and applicable obligations. When information is no longer required, it is securely deleted, destroyed or de-identified in accordance with controlled retention and disposal processes. Information subject to a legal hold, investigation or audit may be retained for longer where required.

12. Individual rights and requests

Subject to applicable privacy law, an individual may contact Twoconnect to:

• request access to personal information;
• request correction of inaccurate or incomplete personal information;
• request deletion or restriction where a legal right applies;
• object to particular processing or withdraw consent where processing relies on consent;
• request information about how personal information is handled; or
• make a privacy complaint.

Twoconnect may need to verify the individual’s identity before acting on a request. Rights may be subject to legal exceptions, retention obligations and other lawful limitations. Twoconnect will assess and respond to requests and complaints in accordance with applicable privacy law.

13. Privacy and security incidents

Twoconnect maintains procedures to assess and respond to suspected privacy and information-security incidents. Where required by applicable law, Twoconnect will notify affected individuals and relevant regulators.

14. External websites and services

Our website may contain links to third-party websites, recruitment platforms, social networks or services. Their privacy practices are governed by their own notices. Individuals should review those notices before providing personal information to a third party.

15. Changes to this policy

Twoconnect may update this policy to reflect changes in services, legal obligations, technology or privacy practices. The current version will be published on the Twoconnect website with its effective date or last-updated date. Material changes may be communicated through an appropriate additional notice where required.

16. Contact us

For privacy questions, requests or complaints, contact: