Legal
Privacy Policy
Privacy Policy
Introduction
When does this Policy apply?
Elle.Be.O is a curated beauty network, which also provides a trusted operating and commerce layer for independent Technicians.
This Privacy Policy (Policy) applies to all the activities operated by Elle.Be.O Pty Ltd (ABN 11 696 711 207) (Elle.Be.O, 'we', 'us', 'our'). This includes:
the services we provide our customers, clients and users on our app and web-based interfaces (Service Users); and
the services Elle.Be.O provides to the independent beauty professionals (practitioners/technicians/founding members/subject matter experts) who are profiled in our app (Technicians).
References in this Policy to Elle.Be.O, we, us and our include Elle.Be.O Pty Ltd and, where the context permits, its current and future related bodies corporate, affiliates, successors and assigns, and any entity that owns, operates, acquires, assumes or receives all or part of the Elle.Be.O business, platform, assets or services through any restructure, reorganisation, merger, acquisition, investment, sale, transfer, assignment or novation. This Policy continues to apply to personal information handled in connection with the Elle.Be.O business, platform and services after any such transaction, subject to applicable law.
This Policy explains how we collect, use and disclose or provide access to personal information. Elle.Be.O is committed to protecting your privacy. We aim to maintain a safe and secure system of handling your personal information, while providing access to your personal information in accordance with law.
This Policy applies to prospective employees but does not apply to employee records.
Key definitions
In this Policy:
Personal information means any information or an opinion about an identified individual or an individual who is reasonably identifiable (whether true or not and whether recorded in a material form or not). It does not include information that is de-identified.
Sensitive information is personal information that includes information about an individual's racial or ethnic origin; political opinions; membership of a political association; religious beliefs or affiliations; philosophical beliefs; membership of a professional or trade association; membership of a trade union; sexual orientation or practices; criminal record. It also includes health information (including information about an individual's disability); genetic information about an individual that is not otherwise health information, or biometric information used for automated biometric verification or identification or biometric templates.
Health information means personal information about the health, illness, disability or injury of an individual, an individual's expressed wishes about the future provision of health services or a health service provided or to be provided to the individual, as well as other personal information collected to provide, or in providing a health service. Health information also includes other personal information collected in connection with the donation of body parts or organs, body substances or genetic information that could be predictive of the health of the individual or a genetic relative of the individual.
AI system means a machine-based system that, for explicit or implicit objectives, infers, from the input it receives, how to generate outputs such as predictions, content, recommendations, or decisions that can influence physical or virtual environments.
Dealing with us using a pseudonym or anonymously
Where possible and lawful, you can interact with us anonymously. However, for many of our functions and activities we need your name, contact information and other details to enable us to provide our services or products to you. If you do not provide your personal information to us, we may not be able to provide services or products to you.
Information for Elle.Be.O Service Users and Technicians
This section outlines how we handle personal information relating to Elle.Be.O Service Users, Technicians and other individuals who may receive or interact with Elle.Be.O services.
What personal information do we collect?
We only collect personal information about you that is reasonable and necessary for us to carry out our business functions. Individuals will be reasonably notified at or before the time of collection, or as soon as practical thereafter. The information we collect depends upon the nature of our dealings with you. This may include (but is not limited to) information such as:
your name, contact details, gender, date of birth, address, email address and phone number;
your interests and preferences;
your religious beliefs, sexual orientation, family type, country of birth, and language spoken at home;
information to assist in the resolution of complaints;
information about payment for services, including your bank account details;
any additional information you provide through our forms, app or website;
account login details, profile information and user preferences;
booking history, appointment details, service preferences, location information and communications with us or Technicians;
payment transaction information, deposit, refund, cancellation and dispute information;
reviews, ratings, referrals, gifting, loyalty activity, consent records and support requests;
health, treatment, medical history, consent, clinical or aftercare information where relevant to cosmetic medicine or other services;
for Technicians, professional profile information, ABN or business details, services, pricing, availability, work locations, portfolio images, qualifications, licences, certifications, insurance, verification information, endorsements, reviews, client records, income and payout information; and
device, app usage, analytics and technical information, including cookies, IP address, log data and security information.
How do we collect personal information?
As part of our functions, we may collect personal information about you directly from you, such as:
through your interactions with us;
when you complete a form (including in electronic format on our website);
when you create or use an account, complete a client or Technician profile, submit an application, request or manage a booking, make a payment, leave a review, use referral, gifting or loyalty features, use Guardian Hub, SOS, incident-reporting or support features, or otherwise communicate with us through our app, website, forms, email, phone, social media or other channels.
In some instances, we may receive information about you from third parties, such as from:
individuals nominated or authorised by you, to book services for you to receive from Technicians;
Technicians, salons, clinics, category leaders and approved professionals involved in referrals, vetting, bookings or service delivery;
payment processors, identity verification providers, booking and calendar providers, software, cloud hosting, analytics, communications, customer support and AI service providers;
publicly available sources, social media, websites, professional directories, regulators, professional bodies and other third parties with your consent; and
our professional advisers and business partners where reasonably necessary for our functions and activities.
We might also collect personal information through AI systems (e.g. large language model transcription services) when you or your representatives interact with them, or when information from bookings, profiles, reviews, support requests, Brand DNA prompts, consent records or other platform activity is processed by those systems. We may also use AI systems to generate personal information about you. The kinds of personal information that may be generated by AI systems include those set out above under the heading 'what personal information do we collect'.
Our AI systems have been assessed and approved by Elle.Be.O as meeting the security standards required for handling and managing personal information. If AI systems are used to generate or infer personal information about you, we will only use AI systems to generate or infer personal information about you that is reasonably necessary for our functions and activities, and only by lawful and fair means. Elle.Be.O will manage any personal information collected, inferred, or generated by AI systems in accordance with this Policy.
Purposes for which we collect, use and disclose personal information
We collect, use and disclose your personal information for the following purposes:
to provide our services;
to manage, improve, and conduct our business;
to obtain feedback or manage complaints;
to respond to queries;
to create and manage accounts, profiles, Technician applications and approved professional listings;
to facilitate discovery, bookings, rebookings, deposits, payments, refunds, cancellations, disputes and customer support;
to verify identity, licences, credentials, insurance, eligibility, vetting status and compliance requirements;
to operate reviews, referrals, gifting, loyalty, Guardian Hub, SOS, incident-reporting and safety features;
to personalise recommendations, communications and service discovery, and to operate approved marketing and Growth Studio tools with consent;
to meet legal, regulatory, insurance, accounting, tax, reporting and risk-management obligations; and
to develop, test, secure and improve our app, website, products, services, AI systems and business operations.
We may also use your personal information in technology systems, including AI systems, in connection with our functions and activities, including to:
support the performance and delivery of our services;
perform administrative tasks; and
support and improve the performance of our functions.
We may also de-identify your personal information. We may use de-identified information for various purposes, including:
quality improvement;
to satisfy our reporting obligations; and
analytics, product development, platform reporting, safety, compliance and risk monitoring, service quality, market insights, investor reporting, and improving matching, rebooking, reputation and Growth Studio features.
Automated decision-making
We do not currently use personal information in automated decision-making that substantially and directly affects an individual's rights or interests without human involvement. We may use technology systems, including AI systems, to assist with recommendations, matching, fraud or safety signals, booking prompts, support triage, content generation and operational workflows. These systems support human review and do not make final decisions about eligibility to join the curated network, suspension or removal of a user, complaint outcomes, or material access to services without appropriate human oversight.
How do we disclose personal information?
While providing our products and services to you, we may need to disclose your personal information to third parties, including the following:
Elle.Be.O's current and future related bodies corporate, affiliates, successors and assigns, including any group entity that owns, operates or supports any part of the Elle.Be.O platform, services or business;
your relatives, carers, or support persons, with your consent;
external contractors or third parties who provide services on our behalf such as software suppliers;
actual or prospective investors, purchasers, transferees, assignees, novatees, merger partners, restructure participants or other parties involved in any investment, financing, restructure, reorganisation, merger, acquisition, sale, transfer, assignment, novation or disposal of all or part of Elle.Be.O's business, shares, assets, platform or services, and their advisers;
government agencies, regulatory bodies, and law enforcement agencies, or other similar entities;
our professional advisers, including lawyers, accountants, or auditors;
where disclosure will prevent or lessen a serious or imminent threat to the life, health or safety of any individual, or to public health or safety, including where an in-app SOS, Guardian Hub or incident-reporting feature is activated; and
the disclosure is reasonably necessary to take appropriate action in relation to a suspected unlawful activity or serious misconduct.
Where personal information is disclosed to any third-party, we will take reasonable steps to ensure that the person receiving your personal information keeps it confidential and does not misuse it or improperly disclose it to any other person.
We may disclose some of your personal information to an overseas recipient. These organisations may be located in the United States of America, the United Kingdom, the European Union or European Economic Area, and other countries where our cloud hosting, software, payment, identity verification, analytics, communications, customer support, AI, booking integration and professional service providers store or process information.
Personal information may be shared within Elle.Be.O and with its current and future related bodies corporate, affiliates, successors and assigns. Where this occurs, the principles contained in this Policy will continue to apply to that personal information, subject to applicable law and any updated privacy notice issued in connection with a restructure, transfer, assignment, novation, merger, acquisition or sale.
Direct Marketing
With your consent, we may use personal information to send you information about other Elle.Be.O products and services which may be of interest to you, but we respect your right to ask us not to do this. If you no longer wish to receive those sorts of communications from us, you should contact our Privacy Officer and we will ensure that this is corrected. Where practicable, our marketing communications will include an unsubscribe or other opt-out facility. If we undertake direct-marketing we acknowledge that we are bound by the Spam Act 2003 (Cth) and the Do Not Call Register Act 2006 (Cth). Any other use or disclosure we make of your personal information will only be as required by law or permitted by the Privacy Act. We will not sell your personal information to other organisations.
Information for job applicants
This section applies to individuals who apply for a job (employment, contract of engagement, or volunteer position) with us.
What personal information do we collect?
We only collect personal information about you that is reasonable and necessary for us to carry out our business functions. The information we collect depends upon the nature of our dealings with you. If you are a contractor, or are applying for a job with us, we may collect your personal information, including:
your name and date of birth;
employment history and qualifications;
academic records;
references;
health information;
tax file number;
service provider number;
insurance documentation;
right to work status;
personal alternative contact details;
superannuation fund details;
sensitive information such as your criminal history record; and
any additional information you provide during the recruitment, contractor engagement or onboarding process, including interview notes, availability, remuneration expectations and communications with us.
How do we collect personal information?
If you apply for a job or hold a volunteer or contract position with us, we may collect personal information about you directly from you such as when you submit to us your CV. We may also collect personal information about you from third parties and publicly available sources, including:
recruiters;
government departments to verify your entitlement to work in Australia;
police agencies to obtain your criminal history record;
academic institutions;
consulting medical practitioner;
superannuation fund provider;
your current or previous employers;
your referees;
other third parties, with your consent.
We might also collect personal information by using approved technology systems, including transcription, scheduling, document management or AI-assisted administrative tools, when you or your representative interact with us during recruitment, contractor engagement or onboarding. We may also use those systems to generate administrative records, summaries or workflow information based on information you provide.
Our AI systems have been assessed and approved by Elle.Be.O as meeting the security standards required for handling and managing personal information in accordance with this Policy, the Privacy Act, and the APPs. If AI systems are used to generate or infer personal information about you, we will only use AI systems to generate or infer personal information about you that is reasonably necessary for our functions and activities, and only by lawful and fair means. Elle.Be.O will manage any personal information collected, inferred, or generated by AI systems in accordance with this Policy.
What are the purposes for collecting, using and disclosing personal information?
We collect, use and disclose your personal information for the following purposes, including (but not limited to):
considering your suitability for employment or a contractor or volunteer position and (if successful) engaging you;
administering your contract;
for insurance purposes;
conducting background, reference, right-to-work, qualification, insurance and compliance checks;
managing recruitment records, onboarding, workforce planning, payroll, tax, superannuation, insurance and workplace health and safety obligations; and
meeting legal, regulatory, reporting, governance and risk-management obligations.
Automated decision-making
We do not currently use personal information in automated decision-making to decide whether to employ, engage, reject, shortlist or otherwise materially assess job applicants, contractors or volunteers. Technology systems, including AI systems, may assist with administrative tasks such as scheduling, transcription, document management, workflow support or summarising information for human review, but employment, engagement and contractor decisions are made by Elle.Be.O personnel.
How do we disclose personal information?
If you apply for a job with us, we may disclose your personal information to third parties, including:
Elle.Be.O's current and future related bodies corporate, affiliates, successors and assigns, including any group entity that owns, operates or supports any part of the Elle.Be.O platform, services or business;
external contractors or third parties who provide services on our behalf, such as recruitment agencies;
actual or prospective investors, purchasers, transferees, assignees, novatees, merger partners, restructure participants or other parties involved in any investment, financing, restructure, reorganisation, merger, acquisition, sale, transfer, assignment, novation or disposal of all or part of Elle.Be.O's business, shares, assets, platform or services, and their advisers;
government agencies, regulatory bodies, and law enforcement agencies, or other similar entities;
our professional advisers, including lawyers, accountants, or auditors;
where disclosure will prevent or lessen a serious or imminent threat to the life, health or safety of any individual, or to public health or safety; and
the disclosure is reasonably necessary to take appropriate action in relation to a suspected unlawful activity or serious misconduct.
Where personal information is disclosed to any third-party, we will take reasonable steps to ensure that the person receiving your personal information keeps it confidential and does not misuse it or improperly disclose it to any other person.
We may disclose some of your personal information to an overseas recipient. These organisations may be located in the United States of America, the United Kingdom, the European Union or European Economic Area, and other countries where our recruitment, cloud hosting, communications, document management, accounting, payment, verification, AI-assisted administration and professional service providers store or process information.
Direct Marketing
We do not use personal information collected about job applicants for direct marketing purposes.
Cookies
Cookies
When you visit our website or app, we also use 'cookies' or other similar tracking technologies that help us track your website usage and remember your preferences. A cookie is a small data file that may be placed on the computer of a web user (usually in the browser software folder) the first time a computer visits a web site which operates cookies. Cookies are necessary to facilitate on-line transactions and ensure security. If you do not wish to receive any cookies you should set your browser to refuse cookies.
Whilst we do not use browsing information to identify you personally, we record certain information about your use of our website, such as which pages you visit, the time and date of your visit, search engine referrals and the internet protocol address assigned to your computer.
How we manage personal information?
How do we store and secure personal information?
We will hold your personal information primarily through secure electronic records, including cloud-based systems, with limited physical records where necessary. We will take reasonable and appropriate steps (including technical and organisational measures) to protect the information from misuse, loss or unauthorised access, modification or disclosure both physically and through computer security methods.
We will only keep your personal information for as long as it is required for the purpose for which it was collected, for example when you cease receiving services or close a transaction with us, or as otherwise required by applicable laws. If we no longer need to hold your personal information for any reason or we are no longer required by law to keep it, we will take reasonable steps to de-identify or destroy that information. These steps can vary depending on the nature of the information, the way it was collected and how it was stored.
How can you access and correct your personal information?
We will endeavour to ensure that the personal information collected from you is up-to-date, accurate, and complete.
If you want to access, correct or raise a query or concern about the personal information we hold about you, you should contact the Privacy Officer. We will need to verify your identity before responding to your request. Subject to any applicable exceptions or requirements, we will provide you with access to the personal information you request within a reasonable time and usually within 28 days. If we decide to refuse your request, we will tell you why in writing and how to complain.
Service Users or their representatives (including if the individual does not have capacity, or if a representative books a service on another person's behalf) can modify or withdraw consent for Elle.Be.O to access their personal information at any time. To do so, they should contact the manager of the care or service they are receiving and express their desired changes or withdrawal of consent.
How can you make a complaint?
If you have a complaint about a suspected breach of the APPs then you should put your complaint in writing and send it to the Privacy Officer using the details set out in this Policy. We will review and respond to your complaint within a reasonable timeframe and inform you of the next steps we will take in dealing with your complaint. We will advise you if we need further information to make a decision.
If you are not satisfied with our response, you can complain, including to the Office of the Australian Information Commissioner (OAIC) via the OAIC website, www.oaic.gov.au.
Privacy Officer Details
You can contact Elle.Be.O's Privacy Officer as follows:
Email: info@ellebeo.com
Mail: PO BOX 961, LANE COVE 1595
Updates or changes to this Policy
This Policy is subject to regular review. We may update this Policy from time to time by publishing the updated Policy on our website or app and, where appropriate, notifying users by email, in-app notice or other direct communication.
This Policy was last updated on 24 June 2026. The next review date is 24 December 2026.
Document version control
| Version | Date of publication | Comments |
|---|---|---|
| 1.0 | 24 June 2026 | Initial launch policy. |