1. Introduction

Associated Cleaning (“Company”, “we”, “our”, or “us”) is committed to protecting the privacy and personal information of all users of our mobile application (the “App”). This Privacy Policy explains how we collect, use, disclose, store, and protect your personal information when you use the App.

This Privacy Policy is prepared in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs) contained therein. It should be read in conjunction with our Terms and Conditions of Use.

By using the App, you consent to the collection, use, and disclosure of your personal information as described in this Privacy Policy. If you do not agree with this Privacy Policy, you must not use the App.

2. About Associated Cleaning

Associated Cleaning is a commercial cleaning company operating in Australia. The App is an internal tool designed for use by our authorised personnel, including contractors (cleaners) and administrative/office staff, to facilitate workforce attendance verification, task management, communication, and compliance.

Entity: Associated Cleaning Services Pty Ltd

ABN: 77 009 935 193

Address: 26 Commercial Road, Newstead QLD 4006

3. Information We Collect

We collect several categories of personal information through the App. The types of information collected depend on your role and how you interact with the App.

3.1 Information You Provide Directly

• Account and Profile Information: Your name, email address, mobile phone number, and role/user type (contractor, client, area manager) as assigned by Associated Cleaning.
• Authentication Credentials: Login details including your username/email and password used to authenticate via Salesforce.
• Task and Work Records: Data relating to tasks you mark as completed, schedules you view, and any notes or updates you submit.
• Communications: Messages, chat records, and other communications sent or received through the in-app messaging feature.
• Uploads and Submissions: Photos, documents, incident reports, near-miss reports, induction forms, consumable reorder requests, and other content you upload or submit through the App.
• Non-Attendance Reports: Reasons submitted for absences or non-attendance at assigned sites.

3.2 Information Collected Automatically

• Location Data: GPS coordinates (longitude and latitude) collected when you check in and out of sites, and during your shift for real-time geofencing and tracking. This includes background location data when the App is running in the background during active shifts.
• Device Information: Device type, operating system version, unique device identifiers, and App version.
• Usage Data: Information about how you interact with the App, including features accessed, timestamps, and session duration.
• Push Notification Data: Information relating to notification delivery and interaction.

3.3 Information from Third-Party Sources

We may receive information about you from our integrated systems and third-party services, including:

• Salesforce CRM: Schedule assignments, site information, task lists, audit scores, and contractor records managed by administrative staff.
• SafetyCulture (iAuditor): Audit reports, inspection data, and compliance records.
• Google Maps / Location Services: Address suggestions and location verification data.

4. How We Use Your Information

We use the personal information we collect for the following purposes:

4.1 Attendance and Workforce Verification

• To verify your physical presence at assigned cleaning sites using GPS geofencing.
• To record shift start times, and track attendance patterns.
• To manage and process non-attendance notifications.

4.2 Task and Schedule Management

• To push daily and periodic cleaning tasks and schedules to your device.
• To track task completion status and synchronise records with Salesforce.
• To manage site-specific work instructions and scope documents.

4.3 Communication

• To facilitate in-app messaging between cleaners and office staff.
• To send push notifications for schedule updates, task assignments, and other operational matters.
• To record and archive chat communications for compliance and record-keeping.

4.4 Safety, Compliance, and Quality Assurance

• To manage incident reports, near-miss reports, and induction records.
• To provide access to audit scores and safety compliance reports.
• To distribute training materials and safety documentation.

4.5 Operational and Administrative Purposes

• To manage consumable stock levels and process reorder requests.
• To monitor and improve the quality of cleaning services.
• To generate reports for management and client reporting.
• To administer user accounts, roles, and permissions.

4.6 App Improvement and Technical Support

• To diagnose and resolve technical issues.
• To monitor App performance, identify bugs, and implement improvements.
• To ensure the security and integrity of the App and its data.

5. Legal Basis for Processing

Under the Australian Privacy Principles, we collect and process your personal information on the following bases:

• Consent: You provide consent to the collection and use of your information when you accept these Terms and use the App, and when you grant location and notification permissions on your device.
• Contractual Necessity: Processing is necessary for the performance of your engagement as a contractor or employee of Associated Cleaning.
• Legitimate Interests: Processing is necessary for our legitimate business interests, including workforce management, operational efficiency, quality assurance, and compliance with contractual obligations to our clients.
• Legal Obligation: Processing may be required to comply with applicable laws, regulations, or legal proceedings.

6. Disclosure of Your Information

We may share your personal information with the following categories of recipients:

6.1 Internal Recipients

• Authorised management and administrative staff of Associated Cleaning who require access to perform their roles.
• Area managers responsible for overseeing cleaning operations at specific sites.

6.2 Third-Party Service Providers

We engage third-party service providers who process personal information on our behalf, including:

• Salesforce: CRM platform used for data storage, task management, scheduling, and reporting (data may be hosted in the United States or other jurisdictions where Salesforce operates).
• Amazon Web Services (AWS): Cloud hosting and infrastructure services.
• Agora: Chat and messaging SDK provider.
• Google (Maps Platform): Location and mapping services.
• SafetyCulture: Audit and compliance platform.
• App Distribution Platforms: Apple App Store and Google Play Store for app distribution and updates.

6.3 Other Disclosures

We may also disclose your personal information where:

• Required or authorised by law, including to comply with a court order, subpoena, or regulatory request.
• Necessary to protect the rights, property, or safety of Associated Cleaning, our users, or the public.
• In connection with a merger, acquisition, or sale of all or a portion of our business.
• With your express consent.

7. Overseas Disclosure of Personal Information

Some of our third-party service providers operate in jurisdictions outside of Australia. In particular, Salesforce and AWS may store and process your data in the United States or other countries where their data centres are located. The App development team is based in Australia and Nepal.

Before disclosing your personal information to an overseas recipient, we take reasonable steps to ensure that the recipient does not breach the Australian Privacy Principles in relation to that information, including by entering into contractual arrangements that require compliance with equivalent privacy protections.

8. Data Retention

We retain your personal information for as long as is necessary to fulfil the purposes for which it was collected, including to satisfy any legal, accounting, or reporting requirements. Specific retention periods include:

• Account and Profile Data: Retained for the duration of your engagement with Associated Cleaning and for a period of 7 years after the end of your engagement, or as required by law.
• Attendance and Location Records: Retained for a minimum of 7 years in accordance with employment record-keeping obligations under the Fair Work Act 2009 (Cth) and applicable state legislation.
• Task Completion Records: Retained for 7 years for compliance and audit purposes.
• Chat and Communication Records: Retained for 3 years from the date of the communication, unless a longer retention period is required by law or for dispute resolution.
• Uploaded Content: Photos, documents, and reports are retained for 7 years or as required by applicable workplace health and safety legislation.

When personal information is no longer required for any purpose for which it may be used or disclosed, we will take reasonable steps to destroy or de-identify the information.

9. Data Security

We take reasonable steps to protect the personal information we hold from misuse, interference, loss, and from unauthorised access, modification, or disclosure. Our security measures include:

•  Secure authentication via Salesforce login with role-based access controls.
• Encrypted data transmission using HTTPS/TLS protocols.
• Data encryption at rest within our hosting environment.
• Access controls and permissions based on user roles (contractor, client, area manager).
• Regular security testing, including vulnerability scanning and penetration testing.
• Application performance monitoring and logging via New Relic or equivalent tools.
•  Code quality and security analysis via SonarCloud or equivalent tools.

Despite our efforts, no method of electronic transmission or storage is 100% secure. We cannot guarantee absolute security of your personal information.

10. Your Rights

Under the Privacy Act 1988 (Cth) and the Australian Privacy Principles, you have the following rights in relation to your personal information:

10.1 Right of Access

You have the right to request access to the personal information we hold about you. We will respond to your request within 30 days, or such other period as required by law.

10.2 Right of Correction

You have the right to request the correction of any personal information that is inaccurate, out of date, incomplete, irrelevant, or misleading. You may update certain profile information directly through the App.

10.3 Right to Complain

If you believe that we have breached the Australian Privacy Principles, you have the right to lodge a complaint with us. We will investigate your complaint and respond within 30 days. If you are not satisfied with our response, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au.

10.4 Account Deletion

You may request the deletion of your account through the App. Please note that we may be required to retain certain information for legal and compliance purposes even after your account is deleted. Any data that has been synced to Associated Cleaning’s backend systems may be retained in accordance with our data retention policies.

11. Children’s Privacy

The App is not intended for use by individuals under the age of 18. We do not knowingly collect personal information from children under 18. If we become aware that we have collected personal information from a child under 18, we will take reasonable steps to delete that information.

12. Cookies and Similar Technologies

The App may use local storage, session tokens, and similar technologies to maintain your authentication state and improve your user experience. These technologies are essential for the App’s functionality and are not used for advertising or third-party tracking purposes.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of any material changes by posting the updated policy within the App and, where practicable, via push notification or other reasonable means.

The “Last Updated” date at the top of this Privacy Policy indicates when the most recent revisions were made. Your continued use of the App after any changes to this Privacy Policy constitutes your acceptance of the revised policy.

14. How to Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our handling of your personal information, please contact us at:

Associated Cleaning – Privacy Officer

Email: troy.cotterrell@associatedcleaning.com.au                              

Phone: (07) 3854 1336

Address: 26 Commercial Road, Newstead QLD 4006

If you wish to make a formal privacy complaint, please submit your complaint in writing to the address above. We will acknowledge your complaint within 7 days and endeavour to resolve it within 30 days.

15. Office of the Australian Information Commissioner

If you are not satisfied with our response to your complaint, you may contact the Office of the Australian Information Commissioner:

Office of the Australian Information Commissioner (OAIC)

Website: www.oaic.gov.au

Phone: 1300 363 992

Email: enquiries@oaic.gov.au

Address: GPO Box 5218, Sydney NSW 2001