Privacy Policy

This Privacy Policy explains how HubCore Consulting LTD, trading as Talent Cluster (“we”, “us”, “our”), collects, uses, discloses, and protects personal information in connection with the Talent Cluster website and Service. It is written to comply with the New Zealand Privacy Act 2020 and its 13 Information Privacy Principles (IPPs). Where we handle the personal information of individuals in Australia, we also have regard to the Australian Privacy Act 1988 (Cth) and the Australian Privacy Principles.

1. Who We Are

HubCore Consulting LTD, a company registered in New Zealand, trades as Talent Cluster. We are the “agency” responsible for your personal information under the Privacy Act 2020. Our contact details are in Section 15.

2. Scope

This Policy applies to personal information we collect through talentcluster.co.nz and related applications, including from registered users (job seekers) and site visitors. It should be read together with our Terms of Service, which it is incorporated into by reference.

3. Information We Collect

We collect the following categories of personal information:

4. How We Collect Information

We collect personal information directly from you (or, if you choose to sign in with Google, from Google: your name and email address) when you register, use the resume/cover-letter builder, run an ATS check, subscribe to Premium, or contact support. We collect limited technical information automatically through your use of the Service (see Usage data above). We do not collect personal information about you from third-party data brokers.

5. Why We Collect and Use Your Information

We collect and use your personal information to:

• create and administer your account and provide the Service you request (resume/cover-letter generation, ATS scoring, dashboard, Job Market Insight);
• process AI-assisted drafting and scoring features, which requires sending relevant content to our AI processing sub-processor (see Section 7);
• process Premium subscription payments via Stripe and manage billing, renewals, refunds, and disputes;
• send service-related communications (e.g. account, billing, and security notices);
• with your consent, send product updates or marketing communications, each with a clear unsubscribe option, consistent with the Unsolicited Electronic Messages Act 2007 (NZ) and the Spam Act 2003 (Cth) for Australian recipients;
• maintain the security and integrity of the Service, prevent fraud, and comply with legal obligations; and
• analyze aggregated, de-identified usage trends to improve the Service.

We only use your personal information for the purpose it was collected for, or a directly related purpose, consistent with Information Privacy Principles 10 and 11 of the Privacy Act 2020.

6. Automated Processing and AI Features

When you use AI-assisted features, the resume, cover letter, or job-description text you provide is sent to our third-party AI processing provider to generate suggested content or an ATS compatibility score. This processing informs suggestions shown to you. It does not make any automated decision that has a legal or similarly significant effect on you — for example, it does not decide whether you get a job (see Terms of Service, Sections 9–10).

7. Who We Share Information With

We do not sell your personal information. We share personal information only with the following categories of recipients, each acting as our service provider (processor) under contract, or as otherwise described below:

We may also disclose personal information where required by law, to protect our rights or the safety of others, or in connection with a business transfer (e.g. a merger or acquisition), in which case we will take reasonable steps to ensure comparable protection continues to apply.

8. Overseas Disclosure

Some recipients listed in Section 7 are located, or process data, outside New Zealand — currently the United States (AI processing, payments, email delivery and sign-in) and Australia (hosting infrastructure). Before disclosing personal information to an overseas recipient, we take reasonable steps to be satisfied that the information will be subject to safeguards comparable to those in the Privacy Act 2020 (Information Privacy Principle 12), including through contractual protections with our service providers. Australia’s Privacy Act 1988 (Cth) and the Australian Privacy Principles provide a broadly comparable framework. For recipients in the United States, we rely on contractual data-protection terms with each provider. If you have questions about a specific overseas disclosure, contact us at info@talentcluster.co.nz.

9. Cookies

We use cookies that are strictly necessary to operate the Service, such as session and authentication cookies that keep you logged in. We do not use advertising cookies. You can control cookies through your browser settings, though disabling essential cookies may prevent the Service from working correctly. If we introduce analytics cookies in future, we will update this Policy and, where required, seek your consent.

10. Data Storage and Security

Account and resume data is stored in a PostgreSQL database hosted on AWS cloud infrastructure located in Australia. We apply reasonable technical and organizational measures — including password hashing, access controls, and encrypted connections — to protect personal information against loss and unauthorized access, use, modification, or disclosure, as required by Information Privacy Principle 5. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

11. Data Retention

We retain personal information for as long as your account remains active, and for a further period afterwards to comply with legal, accounting, or dispute-resolution obligations. As a general rule, where retention is not otherwise required by law, we delete or de-identify inactive account data within 24 months of account closure. Financial records related to a Premium subscription are retained for 7 years to meet New Zealand tax and accounting requirements. If you delete your account, we will delete or de-identify your personal information within a reasonable time, except where retention is required as described above.

Locked documents on downgrade or refund. Certain subscription events cause resumes and cover letters beyond your Free-plan limit to be locked rather than deleted, as described in our Terms of Service (Sections 7 and 8) — this content is retained with your account and automatically restored if you resubscribe to Premium. Where you use the optional “delete my content” step offered at the point of a self-service refund, the affected documents are permanently deleted and cannot be recovered. We recommend downloading any documents you wish to keep before requesting a refund or allowing your subscription to end.

12. Your Rights

Under the Privacy Act 2020, you have the right to:

• access the personal information we hold about you;
• correct personal information you believe is inaccurate, incomplete, or misleading; and
• request deletion of your account and associated personal information, subject to Section 11.

To exercise these rights, contact us at info@talentcluster.co.nz. We will respond within the timeframes required by the Privacy Act 2020 (generally as soon as reasonably practicable and no later than 20 working days). If you are not satisfied with our response, you may complain to the New Zealand Office of the Privacy Commissioner (www.privacy.org.nz). Individuals in Australia may also complain to the Office of the Australian Information Commissioner (www.oaic.gov.au).

13. Children’s Privacy

The Service is intended for users aged 18 and over and is not directed at children. We do not knowingly collect personal information from children.

14. Changes to this Policy

We may update this Privacy Policy from time to time to reflect changes to the Service or applicable law. Material changes will be notified via the Service or by email before they take effect.

15. Contact Us / Complaints

HubCore Consulting LTD, trading as Talent Cluster
Address: Level 2A, 10 College Hill, Freemans Bay, Auckland, New Zealand, 1011
Email: info@talentcluster.co.nz
Website: https://talentcluster.co.nz
Office of the Privacy Commissioner (New Zealand): www.privacy.org.nz · 0800 803 909
Office of the Australian Information Commissioner: www.oaic.gov.au