Privacy Policy
Talent Formula respects your privacy and is committed to protecting the personal information entrusted to us.
This Privacy Policy explains how Talent Formula collects, uses, stores, shares and protects personal information when you visit our websites, communicate with us, apply for a role,
work with us, become a client or prospective client, attend one of our events, or use our services and technology. Talent Formula operates internationally and provides services to organisations
across Australia, the United Kingdom, Canada, the United States and other markets.
This Privacy Policy has been developed to address applicable privacy and data protection requirements across the regions in which we operate, including:
• the Australian Privacy Act 1988 and Australian Privacy Principles
• the UK General Data Protection Regulation, Data Protection Act 2018 and applicable UK data protection
legislation
• the Personal Information Protection and Electronic Documents Act and applicable Canadian provincial privacy
legislation
• applicable United States federal and state privacy laws
Additional rights and requirements may apply depending on where you are located and how you interact with Talent Formula. Talent Formula provides accounting
talent, outsourcing, technology, artificial intelligence, automation and related business services.
Our services may include:
• dedicated offshore accounting professionals and teams
• recruitment, onboarding and workforce management
• accounting delivery and workflow support
• automation services
• TFX, Talent Formula’s AI platform for accounting delivery
• Digital Employees and AI-enabled workflows
• technology integrations
• consulting, training and related professional services
References to Talent Formula, we, us or our mean the Talent Formula entity responsible for handling your personal information.
Depending on the circumstances, Talent Formula may act as the organisation responsible for determining how and why personal information is processed, or as a processor
or service provider acting on behalf of a client.
2. Scope of this Privacy Policy
This Privacy Policy applies to personal information collected through or in connection with:
• Talent Formula websites
• TFX and other Talent Formula technology platforms
• website forms and enquiries
• sales and business development activities
• email and telephone communications
• events, webinars and conferences
• marketing activities
• recruitment and employment processes
• client relationships
• supplier and partner relationships
• customer support
• professional networking and social media platforms
• Digital Employees, automation and technology integrations
• other interactions with Talent Formula
Where we process personal information solely on behalf of a client, that client may be responsible for determining
how the information is used. Their privacy policy may also apply.
3. Personal information we collect
The information we collect depends on your relationship with Talent Formula and the services you use.
Contact and professional information
We may collect:
• name
• business email address
• telephone number
• employer
• job title
• business address
• country or general location
• professional profile information
• LinkedIn or other publicly available professional information
Client and prospective client information
This may include:
• organisation details
• role and responsibilities
• accounting and staffing requirements
• technology and systems used
• service requirements
• communications and correspondence
• meeting notes
• proposals and contracts
• account and billing information
• support requests
• records of your interactions with Talent Formula
Recruitment and candidate information
We may collect:
• CV or résumé
• contact information
• employment history
• qualifications
• professional certifications
• skills and experience
• references
• interview notes
• salary expectations
• availability
• location
• right-to-work information
• identity information where necessary
• screening and background information where permitted by law
Where permitted and necessary, we may also process sensitive or special category information, such as information
relating to workplace adjustments, health, diversity or other protected characteristics.
We will only process this information where we have a lawful reason to do so and will apply additional protections
where required.
Website and technical information
When you use our websites or platforms, we may collect:
• IP address
• device information
• browser type
• operating system
• approximate location
• pages viewed
• links clicked
• referring website
• date and time of activity
• cookie identifiers
• analytics data
• campaign attribution information
• website form interactions
Marketing information
We may process information relating to:
• marketing preferences
• email engagement
• events or webinars attended
• content downloaded
• website activity
• areas of business interest
• previous interactions with Talent Formula
TFX and technology platform information
Where you use TFX or another Talent Formula technology service, information processed may include:
• user name and contact details
• account and authentication information
• user roles and permissions
• system activity
• connected system information
• workflow information
• prompts or instructions submitted through AI functionality
• documents and files uploaded or processed
• information extracted from documents
• generated outputs
• transaction and processing records
• audit logs
• security logs
• error and diagnostic information
The exact information processed depends on how the relevant client configures and uses the platform.
Client information processed through our services Talent Formula personnel, Digital Employees, systems and workflows may process personal information supplied or
made available by our clients.
This may include personal information relating to a client’s:
• employees
• customers
• suppliers
• contractors
• business contacts
• other individuals
Where Talent Formula processes this information on behalf of a client, we generally act under the client’s instructions and contractual requirements.
4. How we collect personal information
We may collect personal information:
• directly from you
• from your employer or organisation
• from Talent Formula clients
• from recruitment agencies
• through job platforms
• from professional networking platforms
• from publicly available professional sources
• through our websites
• through TFX and connected systems
• from referrals
• at events and webinars
• from business partners
• from service providers
• through technology and software integrations
Where required by law, we will provide appropriate notice when personal information is collected from another source.
5. Why we use personal information
We use personal information only where we have an appropriate business and legal reason to do so.
Providing Talent Formula services
We may process information to:
• deliver accounting and outsourcing services
• recruit and manage dedicated accounting teams
• provide TFX
• operate Digital Employees
• manage accounting workflows and automation
• configure integrations
• provide client support
• administer accounts
• manage service delivery
• monitor service quality
Client and business relationship management
We may use information to:
• respond to enquiries
• arrange meetings
• understand business requirements
• prepare proposals and quotations
• enter into and manage contracts
• communicate with clients
• manage billing
• provide support
• maintain business relationships
Recruitment
We may use information to:
• assess applications
• identify suitable opportunities
• interview candidates
• verify qualifications
• undertake lawful screening
• match candidates with client requirements
• manage onboarding
• administer employment relationships
• provide training and development
Marketing and business development
We may use business contact information to:
• communicate about Talent Formula services
• send industry insights and newsletters
• invite contacts to webinars and events
• provide relevant content
• understand areas of interest
• personalise communications
• measure marketing performance
• manage sales and business development activities
We provide appropriate mechanisms to unsubscribe or object to marketing communications.
Security and legal compliance
We may use personal information to:
• protect our systems
• authenticate users
• manage access controls
• prevent fraud
• detect security incidents
• investigate suspected misuse
• maintain audit records
• comply with laws and regulatory requirements
• respond to lawful requests from authorities
• establish, exercise or defend legal claims
6. Legal bases for UK personal data
Where UK data protection law applies, our legal basis depends on why we are processing your personal data.
Contract
Where processing is necessary to enter into or perform a contract with you.
Legitimate interests
Where processing is necessary for our legitimate business interests or those of another organisation, provided those
interests are not overridden by your rights and interests.
Our legitimate interests may include:
• managing client relationships
• operating and developing our business
• providing and improving our services
• business-to-business marketing
• recruitment
• managing our technology
• protecting our systems
• preventing fraud
• maintaining appropriate business records
Where appropriate, we assess the impact of this processing on individuals.
Consent
Where we ask for your consent, including for certain marketing, cookies or sensitive information.
You may withdraw consent at any time.
Withdrawal of consent does not affect processing that occurred lawfully before consent was withdrawn.
Legal obligation
Where processing is necessary to meet a legal or regulatory requirement.
Other lawful grounds
We may rely on another lawful basis where permitted under applicable UK data protection law.
Where special category personal data is processed, we will also identify an appropriate condition for that
processing.
7. AI, TFX, automation and Digital Employees
Talent Formula uses artificial intelligence and automation within some of its services, including TFX and Digital
Employees.
Depending on how a service is configured, TFX and Digital Employees may assist with:
• reviewing documents
• extracting information
• categorising information
• comparing datasets
• identifying anomalies or exceptions
• undertaking workflow steps
• supporting reconciliations
• preparing draft content
• routing tasks
• supporting accounting and administrative processes
• assisting users with analysis and decision-making
Where AI or automation processes personal information, Talent Formula applies appropriate privacy, access,
security and governance controls.
AI-generated outputs may require human review depending on the nature of the activity and the way the relevant
service has been configured.
Talent Formula’s approach is to maintain appropriate human oversight where professional judgement, review or
approval is required.
AI privacy governance
Talent Formula maintains and continues to develop privacy governance for the use of AI and automated processing
within TFX and our wider services.
Our governance framework is designed to address:
• what personal information may be processed by AI systems
• why that information is being processed
• access permissions
• data minimisation
• security and confidentiality
• appropriate human oversight
• audit trails and logging
• review of AI-generated outputs
• management of exceptions
• the use of third-party AI or technology providers
• international data processing
• retention and deletion
• privacy impact and risk assessments
• monitoring for changes in legal and regulatory requirements
Talent Formula reviews new and materially changed AI functionality to determine whether additional privacy, security or data protection controls are required.
Automated decision-making
From 10 December 2026, amendments to Australia’s Privacy Act introduce additional transparency requirements for
certain automated decisions involving personal information.
Talent Formula is implementing these requirements as part of our AI privacy governance framework in advance of
their commencement.
Where the requirements apply, this Privacy Policy will provide information about:
• the kinds of personal information used by relevant computer programs
• the kinds of decisions made solely by those programs
• the kinds of decisions where a computer program performs an activity substantially and directly related to making the decision
These requirements apply where an automated decision could reasonably be expected to significantly affect the rights or interests of an individual.
Talent Formula will review TFX, Digital Employees and other relevant automated workflows to identify whether they
fall within these requirements.
Where AI or automated processing is used to make or materially support a decision that could significantly affect an
individual, we will provide any additional information, human review or safeguards required by applicable law.
8. When we process information for a client
Talent Formula regularly processes personal information on behalf of its clients.
For example, a client may provide Talent Formula personnel, Digital Employees or TFX with access to accounting
systems, documents or workflows containing personal information.
In these circumstances, the client generally determines:
• why the information is being processed
• what information is required
• which systems are used
• who may access the information
• how long the information should be retained
Talent Formula processes that information in accordance with:
• the client’s documented instructions
• the applicable services agreement
• confidentiality requirements
• data protection requirements
• applicable privacy legislation
Where required, we enter into data processing or service provider agreements with clients.
9. Disclosure of personal information
We may disclose personal information to:
• Talent Formula group entities
• authorised employees
• contractors and accounting professionals
• clients
• cloud and infrastructure providers
• IT providers
• cybersecurity providers
• CRM providers
• communications providers
• analytics providers
• recruitment providers
• HR and payroll providers
• professional advisers
• auditors
• insurers
• AI and technology providers
• integration providers
• event and webinar providers
• regulators and government authorities where legally required
We require service providers handling personal information on our behalf to use it only for authorised purposes and
to apply appropriate protections.
10. International data processing and offshore delivery
Talent Formula operates an international delivery model.
Personal information may therefore be accessed, processed or stored outside the country where it was originally
collected.
Depending on the client, service and technology involved, personal information may be processed, accessed or
stored in:
• Australia
• India
• United Kingdom
• Canada
• United States
These countries represent the principal jurisdictions in which Talent Formula operates, provides services or uses
approved infrastructure and service providers.
Information may also be processed through third-party systems selected by a client. Where this occurs, the location
and privacy practices of that provider may also apply.
Talent Formula takes appropriate steps to ensure international processing is undertaken in accordance with
applicable privacy and data protection requirements.
Offshore accounting delivery
Talent Formula’s services may involve authorised accounting professionals located in India accessing information
contained within client-approved or Talent Formula-approved systems.
Access is provided only where required for the relevant services and is subject to:
• contractual restrictions
• confidentiality obligations
• access permissions
• security controls
• client instructions
• applicable privacy and data protection requirements
Australian information
Where the Australian Privacy Principles apply and Talent Formula discloses personal information to an overseas
recipient, we take reasonable steps required by Australian privacy law to ensure that the overseas recipient handles
that information appropriately.
The countries in which overseas recipients are likely to be located include:
• India
• United Kingdom
• Canada
• United States
Where applicable, Talent Formula may remain accountable under Australian privacy law for the handling of
personal information by an overseas recipient.
United Kingdom information
Where UK personal data is transferred outside the United Kingdom, we use an international transfer mechanism
permitted under UK data protection law where required.
This may include:
• UK adequacy regulations
• the International Data Transfer Agreement
• the UK Addendum to approved contractual clauses
• another safeguard or exception permitted under UK law
Where required, Talent Formula also assesses the risks associated with international transfers and implements
additional safeguards.
Canadian information
Personal information relating to Canadian individuals may be processed outside Canada, including in:
• Australia
• India
• United Kingdom
• United States
Talent Formula uses contractual, technical and organisational measures designed to provide appropriate protection
for this information.
Information processed in another jurisdiction may be subject to lawful access by courts, law enforcement or
government authorities in that jurisdiction.
Where Québec privacy law applies, additional privacy impact assessment and contractual requirements may be
implemented before personal information is transferred outside Québec.
United States information
Personal information may be transferred between the United States and Australia, India, the United Kingdom and
Canada where required to provide Talent Formula services.
Where applicable US privacy legislation imposes specific requirements on processors, contractors or service
providers, Talent Formula implements appropriate contractual and operational restrictions.
11. Information security
Talent Formula maintains technical and organisational measures designed to protect personal information from:
• unauthorised access
• misuse
• interference
• loss
• alteration
• unauthorised disclosure
• destruction
Depending on the service and system, controls may include:
• role-based access controls
• user authentication
• access permissions
• audit trails
• logging and monitoring
• encryption
• network security
• security testing
• confidentiality obligations
• staff security training
• incident management procedures
• vendor assessments
• data retention controls
Security measures are reviewed as technology, threats and regulatory requirements change.
No system or method of electronic transmission can be guaranteed to be completely secure.
12. Data and privacy incidents
Talent Formula maintains procedures for identifying, assessing, investigating and responding to suspected privacy or
information security incidents.
Where notification is required by applicable law, Talent Formula will notify the appropriate:
• client
• affected individuals
• privacy regulator
• government authority
within the timeframes required by applicable legislation.
Where Canadian PIPEDA requirements apply, Talent Formula maintains records of qualifying breaches of security
safeguards and reports breaches presenting a real risk of significant harm where required.
Where Talent Formula processes information on behalf of a client, we will assist the client with its incident response
obligations in accordance with our contract and applicable law.
13. Retention and deletion
We retain personal information only for as long as reasonably necessary for:
• the purposes for which it was collected
• service delivery
• contractual obligations
• recruitment requirements
• legal and regulatory requirements
• accounting and financial obligations
• dispute resolution
• security
• legitimate business requirements
Retention periods vary depending on the information involved.
When personal information is no longer required, we take reasonable steps to securely delete, destroy or de
identify it, subject to applicable legal requirements and technical limitations.
Where we process information on behalf of a client, retention may be determined by that client’s instructions.
14. Marketing
Talent Formula may communicate with existing and prospective business contacts about:
• accounting talent
• AI and automation
• TFX
• Digital Employees
• events
• webinars
• resources
• company updates
• other Talent Formula services
We comply with applicable electronic marketing and privacy requirements in the countries in which we operate.
You can unsubscribe from marketing emails using the unsubscribe mechanism contained in the communication or
by contacting us at [email protected].
Opting out of marketing does not prevent us from sending necessary administrative, contractual, security or service
related communications.
15. Cookies, analytics and advertising technologies
Our websites may use cookies, pixels and similar technologies for:
• website functionality
• website security
• remembering preferences
• analytics
• understanding website usage
• measuring marketing performance
• campaign attribution
• advertising
Cookies may include both first-party cookies placed by Talent Formula and third-party cookies associated with
approved technology, analytics, advertising or marketing providers.
UK website visitors
Talent Formula maintains separate cookie controls for visitors subject to UK requirements.
For UK visitors, non-essential cookies and similar tracking technologies will not be activated until appropriate
consent has been provided, except where an applicable legal exemption permits their use.
UK visitors will be provided with a mechanism that allows them to:
• accept non-essential cookies
• reject non-essential cookies
• manage cookie categories and preferences
• change or withdraw their cookie preferences
Strictly necessary cookies may be used without consent where permitted by law because they are required to
provide the website or service requested by the visitor.
Talent Formula will maintain a separate Cookie Policy setting out further information about the cookies and similar
technologies used on the website, including their purposes and, where relevant, duration and third-party providers.
Other regions
Where the law of another jurisdiction requires consent or another mechanism for cookies or tracking technology,
Talent Formula will provide the appropriate controls.
Where applicable US privacy legislation provides a right to opt out of targeted advertising, sale or sharing of
personal information, Talent Formula will provide an appropriate mechanism to exercise that right.
Where required by applicable US law, we will also recognise applicable browser-based universal opt-out signals,
including Global Privacy Control.
16. Your privacy rights
Your rights depend on your location and the law applying to the processing of your personal information.
Talent Formula will not unlawfully discriminate against an individual for exercising an available privacy right.
Australia
Where the Australian Privacy Act applies, you may have the right to:
• request access to personal information we hold about you
• request correction of inaccurate, incomplete or outdated information
• opt out of direct marketing
• make a complaint about how we have handled your personal information
We will respond to requests and complaints in accordance with applicable Australian privacy requirements.
If you remain dissatisfied after raising a privacy complaint with Talent Formula, you may be able to contact the
Office of the Australian Information Commissioner.
United Kingdom
Subject to applicable conditions and exemptions, you may have the right to:
• access your personal data
• correct inaccurate information
• request deletion
• restrict processing
• object to processing
• object to direct marketing
• receive certain information in a portable format
• withdraw consent
• raise concerns about applicable automated decision-making
• complain to the Information Commissioner’s Office
These rights do not apply in every circumstance.
Canada
Depending on the applicable federal or provincial legislation, you may have the right to:
• request access to personal information
• understand how your information has been used and disclosed
• request correction of inaccurate information
• withdraw consent where applicable, subject to legal or contractual restrictions
• challenge our compliance with applicable privacy requirements
• complain to the relevant privacy regulator
You may contact our Privacy Officer with questions or complaints.
Depending on your location, you may also have a right to complain to the Office of the Privacy Commissioner of
Canada or the applicable provincial privacy authority.
United States
Depending on your state of residence and whether the relevant law applies to Talent Formula, you may have rights
including the right to:
• confirm whether we process your personal information
• access personal information
• correct inaccurate information
• request deletion
• obtain a portable copy of certain personal information
• opt out of qualifying targeted advertising
• opt out of the sale of personal information
• opt out of qualifying sharing of personal information
• opt out of certain profiling activities
• limit certain uses of sensitive personal information
• appeal certain decisions relating to privacy requests
• exercise your rights without unlawful discrimination
The precise rights available depend on applicable state legislation.
17. California privacy information
Where the California Consumer Privacy Act, as amended, applies to Talent Formula, California residents may have
additional rights.
Depending on how you interact with us, categories of personal information we may collect include:
• identifiers
• contact information
• professional and employment information
• commercial information
• internet and electronic activity
• approximate geolocation information
• account and authentication information
• information contained within communications
• sensitive personal information where necessary for recruitment, employment, security or service delivery
• inferences derived from business or website interactions
We may collect these categories from:
• you
• your employer
• our clients
• professional networks
• publicly available sources
• recruitment sources
• our website and technology
• approved service providers
We use this information for the purposes described in this Privacy Policy.
We may disclose relevant categories of information to the categories of recipients described in this Privacy Policy.
Talent Formula does not sell personal information in exchange for monetary payment.
Certain advertising, analytics or digital marketing activities may potentially be regarded as a “sale”, “sharing” or
“targeted advertising” under some US privacy laws even where no money is exchanged.
Where applicable, Talent Formula will provide the legally required mechanism to opt out of this processing.
Where required, California residents may use an authorised agent to submit a request on their behalf.
We may take reasonable steps to verify privacy requests.
18. Sensitive personal information
Talent Formula limits the collection and use of sensitive personal information to circumstances where it is
reasonably necessary and permitted by law.
Depending on the circumstances, sensitive information may include:
• government identification information
• account credentials
• health information
• information relating to workplace accommodations
• certain demographic information
• other information classified as sensitive under applicable law
We apply additional protections where appropriate.
Where applicable law requires consent before processing sensitive personal information, we will seek that consent.
19. Children’s privacy
Talent Formula’s websites and commercial services are intended primarily for businesses and working professionals.
They are not designed or directed towards children.
We do not knowingly collect children’s personal information for behavioural advertising or general business
marketing.
Where information relating to a child is contained within information processed on behalf of a client, we process
that information in accordance with the client’s instructions and applicable law.
20. Third-party platforms and integrations
TFX and Talent Formula websites or services may integrate with or contain links to third-party services.
These may include accounting, productivity, communications, artificial intelligence, analytics or other technology
systems selected by Talent Formula or a client.
Where a third party independently determines how personal information is processed, its own privacy policy will
apply.
We encourage users to review the privacy practices of relevant third-party services.
21. Exercising your privacy rights
To ask a privacy question, exercise a privacy right or raise a concern regarding your personal information, contact:
Talent Formula Privacy Team
Email: [email protected]
Website: www.talentformula.co
Please provide enough information for us to understand and respond to your request.
We may need to verify your identity before providing access to information or completing certain requests.
We will respond within the timeframe required by the law applicable to your request.
Where permitted by law, an authorised person may make a request on your behalf.
22. Privacy complaints
Privacy complaints should initially be directed to the Talent Formula Privacy Team at:
[email protected]
We will:
1. acknowledge and review your complaint
2. investigate the circumstances
3. communicate with relevant teams where necessary
4. respond within an appropriate or legally required timeframe
5. take corrective action where required
You may also have the right to contact an external privacy regulator.
Australia
Office of the Australian Information Commissioner.
United Kingdom
Information Commissioner’s Office.
Canada
Office of the Privacy Commissioner of Canada or the applicable provincial privacy authority.
United States
The relevant state Attorney General, privacy agency or other competent regulator.
23. Privacy and AI governance
Talent Formula maintains privacy and data governance practices designed to support responsible handling of
personal information across our business and technology.
Our privacy framework may include:
• assigned privacy responsibilities
• privacy policies and procedures
• staff privacy and security training
• privacy and data protection assessments
• AI privacy and governance assessments
• review of automated decision-making
• security controls
• access management
• vendor and technology provider due diligence
• data processing agreements
• international transfer safeguards
• retention and deletion procedures
• incident response processes
• procedures for handling privacy rights and complaints
• review of new technologies and material changes to TFX
As part of our AI governance programme, Talent Formula is incorporating the Australian automated decision-making
transparency requirements that commence on 10 December 2026 into our processes ahead of their
commencement.
This includes reviewing relevant TFX and Digital Employee workflows to understand:
• whether personal information is being used by an automated system
• the types of personal information involved
• whether the system makes or substantially contributes to a decision
• whether that decision could significantly affect an individual’s rights or interests
• whether human review or additional controls are appropriate
• what additional transparency is required
Talent Formula will continue to review its AI governance framework as privacy, artificial intelligence and automated
decision-making regulation develops across Australia, the United Kingdom and North America.
24. Changes to this Privacy Policy
We may update this Privacy Policy to reflect changes to:
• our business
• our services
• TFX
• Digital Employees and AI technology
• our data processing practices
• service providers
• international operations
• privacy, AI and data protection legislation
The latest version will be published on our website and will show the date of the most recent update.
Where applicable law requires additional notice or consent for a material change, we will provide that notice or
obtain consent.
25. Contact Talent Formula
For questions about this Privacy Policy, the way Talent Formula manages personal information, or to exercise a
privacy right, please contact:
Talent Formula Privacy Team
Email: [email protected]
Website: www.talentformula.co
Talent Formula operates across Australia, India, the United Kingdom, Canada and the United States.
Additional legal entity and registered office information may be provided on our website, contracts or other
corporate documentation as applicable.