Privacy

Last updated: December 2025

At AMillionPaths Pty Ltd (‘AMillionPaths’) we offer interactive career and contributor services through our Platform (our ‘Services’).

‘Platform’ means our website located at amillionpaths.com, and includes all related sub-domains, mobile or web-based application portals, and any other online services, systems or interfaces that we operate or control and through which you may access, create, upload, submit, view or otherwise interact with AMillionPaths’ content or Services (together, the ‘Platform’). References in this policy to the ‘website’ are references to the Platform unless the context requires otherwise.

We are at all times committed to protecting your privacy as a customer and an online visitor to our Platform. Our Platform guides you through a series of questions to help build your profile and share the story of your career journey. By reflecting on key life events—both inside and outside of work and education—you create a detailed map of the experiences that have shaped who you are today, that you think will be of use to others as they contemplate their future career.

The questions we ask are entirely up to you to answer or you may choose not to respond. We do not require you to answer all questions and we ask that you do not provide any personal information that you do not wish to be shared with others on or through the Platform. We also do not recommend providing any health or other personal details in your responses. Please consider that your information will be available and visible to others who you choose to use and access our Platform. If you do not want this information to be visible to others on the Platform please do not include it.

We only use the information we collect about you to maximise the services that we provide to you and other users who set up an account and may access our Platform, information and services (together ‘Users’). We respect the privacy and confidentiality of the information provided by you and adhere to the Australian Privacy Principles. Please read our privacy policy below carefully.

INFORMATION WE COLLECT FROM YOU

In the course of your visits to our Platform or use of our Services, we may obtain the following information about you: name, company name, email address, telephone number, job history, educational institutions you have attended, geographic location, IP address, survey responses, support queries, blog comments, information about your personal experiences inside and outside of work and education and other information you have provided to respond to our profile setup (together ‘Personal Data’).

Our Services are not directed to persons under 16 years of age and we do not knowingly collect Personal Data from anyone under 16. If we become aware that a child under 16 years of age has provided us with Personal Data, we will delete that information as quickly as possible. If you are the parent or guardian of a child and you believe they have provided us with Personal Data without your consent, then please contact us.

You can review, correct, update or delete your Personal Data by either logging into your account and making the changes yourself or contacting us directly to do so.

SENSITIVE INFORMATION

For the purposes of this policy, ‘sensitive information’ has the meaning given in the Privacy Act 1988 (Cth). It includes information about your health, medical conditions or disability, your racial or ethnic origin, political opinions, religious or philosophical beliefs, sexual orientation or sexual practices, trade or professional union membership, criminal record, genetic or biometric information, and any other information defined as sensitive information under that Act.

Some of the questions may invoke some experiences, memories or information that may be considered sensitive personal information for privacy law purposes. We do not recommend that you include such information in your profile if possible. Please be aware that this information will be made public and visible to other Users of the Platform and we cannot control how or where this information may be used. We recommend that you use only general terms in your profile to describe your experiences and do not include specific personal, medical or sensitive information. Remember that you are responsible for the information you enter.

HOW WE USE YOUR INFORMATION

Personally Identifiable Information

We use the information we collect to deliver our services to you, including: communicating with you, providing technical support, notifying you of updates and offers, sharing useful content, measuring customer satisfaction, diagnosing problems and providing you with a personalised Platform experience.

Non-Personally Identifiable Information

We also use the information we collect in aggregated and anonymised forms to improve our services, including: administering our Platform, producing reports and analytics, advertising our products and services, identifying user demands and assisting in meeting customer needs generally.

Any information you choose to make publicly available, such as blog comments and testimonials on our Platform, will be available for others to see. If you subsequently remove this information, copies may remain viewable in cached and archived pages on other Platforms or if others have copied or saved the information.

Current Access to User Data

Except as set out in this Privacy Policy, User-submitted data (other than contact details and birth year) is only viewable by:

1. individuals that the User intentionally invites to access their information, which may include persons who receive a forwarded invitation link; and
2. any person who accesses content that the User chooses to share externally (including via social platforms such as LinkedIn). Where a User chooses to generate or share a public link, any recipient of that link may view the shared content.

Contact details and birth year are not made viewable to other Users except where the User explicitly consents or discloses them in content they create.

Expected Future Functionality

The Service is being developed to enable Users to contribute career-related information that can be surfaced, navigated and reused by other Users. While features may evolve, the expected future capability is that:

1. when a User enters information (including roles, positions, events, or “nodes”), that information will become visible to other logged-in Users in some form;
2. that information may be attributed to the User or de-identified depending on the User’s chosen settings; and
3. aggregated and de-identified elements of that information may be used in the Service to support the creation of paths, discovery of roles, and other navigation functions.

These capabilities are described to assist Users in understanding the purpose of data collection. However, the final implementation details may vary, and we will notify Users before releasing new features or making material changes to how their personal information is handled.

ATTRIBUTION AND DE-IDENTIFICATION

Attributed Nodes

If a User elects to attribute a node, it will be presented to other Users with the identifying information that the User has attached to it (e.g. “John Doe was Head of Operations at XYZ Pty Ltd”).

De-Identified Nodes

If a User elects to de-identify a node:

1. that node will not appear as part of the User’s attributed path when other Users view the User’s profile or path as a whole;
2. the node may still appear in the general network of roles or path segments available to other Users, but without attribution (e.g. “Head of Operations at XYZ Pty Ltd”); and
3. associated insights entered by the User will remain visible to other Users, but they will not be linked to the User.

Account-Level De-Identification

If a User chooses to de-identify their account at a global level, their full path may still be viewable, but it will appear without any personal attribution.

Other Users may discover a User’s (attributed or de-identified) path through navigation features of the Service. For example, by viewing a page for a role and seeing that a number of Users held that role and then selecting one of those Users to explore their path and how it overlaps with that role.

NOTIFICATIONS AND MATERIAL CHANGES

We will notify Users of any material changes to how personal information will be handled. Notification will be sent to the email address registered to the User’s account.

We will also notify Users ahead of the release of new features that materially change the visibility, use or sharing of their personal information, and again at the time those features are released.

NOTICE PERIOD FOR MATERIAL CHANGES TO POLICY‍

We will provide reasonable advance notice before making material changes and at least 14 days’ notice (‘Notice Period’) before such material changes take effect. The notice period will give Users sufficient time to review the changes and, if they choose, adjust their privacy settings or discontinue use of the Service. It is up to the User to ensure they act within this Notice Period.

STORAGE AND SECURITY OF YOUR INFORMATION

We will use all reasonable means to protect the confidentiality of your Personal Data while in our possession or control. All information we receive from you is stored and protected on our secure servers from unauthorised use or access.

To enable us to deliver our services, we may transfer information that we collect about you, including Personal Data, across borders for storage and processing in countries other than Australia. If your Personal Data is transferred and processed outside Australia, it will only be transferred to countries that have adequate privacy protections.

We retain your personal information for as long as needed to provide services to you and as otherwise necessary to comply with our legal obligations, resolve disputes and enforce our agreements.

In the event there is a breach of our security and your Personal Data is compromised, we will promptly notify you in compliance with the applicable law.

If you wish at any time to have your information deleted and/or destroyed, please contact us directly and we will effect your request as soon as reasonably possible.

COOKIES AND PIXELS

A cookie is a small file placed in your web browser that collects information about your web browsing behaviour. Use of cookies allows a Platform to tailor its configuration to your needs and preferences. Cookies do not access information stored on your computer or any Personal Data (e.g. name, address, email address or telephone number). Most web browsers automatically accept cookies but you can choose to reject cookies by changing your browser settings. This may, however, prevent you from taking full advantage of our Platform.

Our Platform uses cookies to remember you when you log in, analyse Platform traffic, provide social media sharing and liking functionality and help us provide a better Platform visitor experience. In addition, cookies and pixels may be used to serve more relevant information including promotional material to Platform visitors.

SHARING YOUR INFORMATION WITH THIRD PARTIES

We do not and will not sell or deal in Personal Data or any User information.

Your Personal Data details are only disclosed to third party suppliers when it is required by law, for goods or services which you have purchased, for payment processing or to protect our copyright, trademarks and other legal rights. To the extent that we do share your Personal Data with a service provider, we would only do so if that party has agreed to comply with our privacy standards as described in this privacy policy and in accordance with applicable law. Our contracts with third parties prohibit them from using any of your Personal Data for any purpose other than that for which it was shared.

DISCLOSURE OF YOUR INFORMATION

We may from time to time need to disclose certain information, which may include your Personal Data, to comply with a legal requirement, such as a law, regulation, court order, subpoena, warrant, in the course of a legal proceeding or in response to a law enforcement agency request. Also, we may use your Personal Data to protect the rights, property or safety of AMillionPaths, our customers or third parties.

If there is a change of control in one of our businesses (whether by merger, sale, transfer of assets or otherwise) customer information, which may include your Personal Data, could be transferred to a purchaser under a confidentiality agreement. We would only disclose your Personal Data in good faith and where required by any of the above circumstances. We will email you at the email address associated with your account if this type of change is imminent.

RETENTION OF YOUR INFORMATION

We keep the personal information you provide only for as long as it is needed to provide our Services using this Platform and to comply with our legal obligations.

If you are actively using your account, we will retain your information to allow you to access and use the Platform, including your profile, interactions, and any contributor connections.

If you stop using the Platform or your account becomes inactive, we may retain your personal information only as long as it is needed for legal, regulatory, or legitimate business purposes, such as tax or accounting obligations, dispute resolution, or compliance with other laws. As the purpose of the Platform is to use the career paths of others to help people understand better how to build their own potential future career paths, we may retain all or part of your de-identified career path for that purpose.

If we are unsure whether you are still an active user, we will periodically review your account. If your personal information is no longer required, we will take reasonable steps to securely delete or de-identify it, although we may retain your career path.

OUR RESPONSIBILITIES UNDER GENERAL DATA PROTECTION REGULATION (GDPR)

If you are a resident of the EU or UK you have certain rights and protections under the GDPR regarding the processing of your Personal Data.

We collect, use and store your Personal Data to enable us to provide you with our goods or services and information about them. We rely on the following lawful means of processing your Personal Data:

• Where it is necessary to fulfil a contract with you. This includes where we collect your Personal Data to enable us to send you our goods or provide you with our services.
• Where you have given us valid consent to use your Personal Data. We will rely on that consent and only use the Personal Data for the specific purpose for which you have given consent. This includes where we email newsletters or send mobile phone notifications.
• We may also process your Personal Data where it is to further our legitimate interests which could include usage statistics, analytics and internal analysis so we can improve our services to you and other users.

YOUR RIGHTS AS AN EU OR UK RESIDENT

If you are a resident of the EU or UK you have various rights including the:

• Right to be informed;
• Right of access;
• Right to rectification;
• Right to object;
• Right to restriction of processing;
• Right to erasure or to be forgotten;
• Right to data portability; and
• Right not to be subject to automated processing.

If you want to access your Personal Data or ask for the information to be corrected, please contact us. In some circumstances, you also have a right to object to or ask that we restrict certain processing activities or delete your Personal Data. If you would like to limit or request deletion of your Personal Data or exercise any other rights you can do so by contacting us.

MARKETING COMMUNICATION

Marketing communications are only sent to you if you have requested or subscribed to them. You can opt out of our marketing communications at any time by unsubscribing or emailing us and your request will be actioned immediately.

WITHDRAWING YOUR CONSENT

You can withdraw your consent to our collection or processing of your Personal Data. You can do so by contacting us or by opting out of email newsletter communications by following the instructions in those emails or by clicking unsubscribe. If you withdraw your consent to the use of your Personal Data, you may not have access to our services and we might not be able to provide you with our services. In some circumstances, where we have a legal basis to do so, we may continue to process your information after you have withdrawn consent. For example, if it is necessary to comply with an independent legal obligation or if it is necessary to do so to protect our legitimate interest in keeping our services secure.

CHANGE IN PRIVACY POLICY

As we plan to ensure our privacy policy remains current, this policy is subject to change from time to time. We may modify this policy at any time, in our sole discretion and all modifications will be effective immediately upon our posting of the modifications on this Platform. We will email you when we make any material changes. Please return periodically to review our privacy policy.

CONTACT US

If you have any questions or concerns at any time about our privacy policy or the use of your Personal Data, please contact us at amillionpaths.com and we will respond within 2 business days.