91±¬ÁÏ

1.  Overview

At 91±¬ÁÏ, we take privacy seriously. This policy explains how we collect, use, and protect your Personal Data as a HeroForce Worker, someone who is legally employed by an 91±¬ÁÏ affiliate entity, but performs day-to-day work for one of our clients (referred to in this policy as the “Client“).

Because of how HeroForce works, your Personal Data is handled a little differently to a typical employment relationship. This policy is designed to give you a clear picture of who processes your data, why, and what rights you have.

We process your Personal Data in accordance with applicable privacy and data protection laws in the jurisdictions in which we operate. Where those laws give you specific rights or impose particular obligations on us, we honour them, and we will tell you where this is relevant throughout this policy.

2.  Who does this policy apply to?

This policy applies to individuals who are employed by an 91±¬ÁÏ entity under our HeroForce Employer of Record (EOR) service, including current and former HeroForce Workers.

This policy does not cover:

• Candidates applying to work at 91±¬ÁÏ directly, please refer to our Applicant Privacy Policy.
• Platform customers, business users, or visitors to our website, please refer to our Customer Privacy Policy.

 3.  Who are we?

91±¬ÁÏ Pty Ltd and its affiliates (“91±¬ÁÏ”, “we”, “us”, “our”) operate the HeroForce EOR service globally. When you use HeroForce, the specific 91±¬ÁÏ entity that acts as your legal employer of record is an entity within the 91±¬ÁÏ Group that is established in your country of employment. 

In some cases, we may deliver HeroForce services through a Nominee, a third-party entity appointed to act as your employer of record in a particular jurisdiction. Where a Nominee is your employer of record. This policy applies equally whether your employer of record is an 91±¬ÁÏ entity or a Nominee.

4.  Understanding the HeroForce relationship

HeroForce is an Employer of Record (EOR) service. This means that while 91±¬ÁÏ (or our Nominee) is your legal employer, responsible for your employment contract, payroll, and compliance with employment laws, your day-to-day work, direction, and operational management are provided by the Client.

This creates a relationship involving multiple parties, each of which may handle your Personal Data in different ways:

Party	Role	What this means for your data
91±¬ÁÏ / Nominee	Your legal employer of record	Processes your Personal Data to fulfil its obligations as your legal employer, including paying you, maintaining employment records, and complying with applicable laws.
The Client	Your day-to-day manager	Provides us with the details of your employment (including your role, pay, duties, and hours) and directs your work on an operational basis. The Client also processes your Personal Data independently for its own purposes, such as performance management, IT access, and workplace policies. The Client is an independent data controller for that processing.
91±¬ÁÏ Platform	Technology provider	We operate the platform through which your employment is administered. See our Platform Privacy Policy for how the platform processes data.

5.  What Personal Data do we collect?

Categories of Personal Data	Specific data
Identity and contact information	Your name, date of birth, residential address, personal email address, phone number, and emergency contact details
Identity verification documents	Passport, national identity card, driver’s licence, or other government-issued identification documents used to verify your identity and right to work.
Right to work information	Visa status, work authorisation documents, and any other information required to confirm your legal entitlement to work in your jurisdiction.
Employment and payroll information	Job title, employment start date, contract terms, salary, bonuses, expense claims, bank account details, tax identification numbers, superannuation or pension details, social and/or health insurance information, payslips, and leave records. Depending on applicable labor laws and regulations, the personal information may include religion, ethnic origin, criminal records, health certificate or related data.
Performance and conduct records	Performance reviews, disciplinary records, grievance matters, and other records generated during the course of your employment.
Health and wellbeing information	Medical certificates, fit notes, occupational health referrals, and information about health conditions where relevant to managing your employment, for example, in connection with sick leave, workplace adjustments, or legal obligations. This is sensitive information and is handled with additional care and in accordance with applicable laws.
Immigration and mobility information	Where relevant to your employment arrangement, visa applications, work permit details, and related documentation.
Platform usage information	Information generated through your use of the 91±¬ÁÏ platform, including login activity and communications made through the platform.

6.  How do we collect your information?

We collect your Personal Data from the following sources:

• Directly from you: when you complete onboarding, submit documents, update your profile, or contact us.
• From the Client: prior to and during your employment, the Client provides us with information needed to set up and administer your engagement. This may include your personal details, identity and work rights documents, and employment information such as your job title, duties, work location, hours, salary, and any changes to those details over time. We require Clients to confirm they have your authority to share this information with us.
• From third-party verification providers: where identity verification or background checks are conducted as part of your onboarding.
• From government agencies and regulatory bodies: such as tax authorities and immigration departments, where required by law.
• From the 91±¬ÁÏ platform: information generated through your use of platform features.

7.  Why we process your information

We process your Personal Data for the following purposes:

• Establishing and administering your employment, including issuing your employment contract and onboarding you onto the 91±¬ÁÏ platform.
• Verifying your identity and your legal right to work in the relevant jurisdiction.
• Conducting necessary pre-employment targeted background checks. These may include criminal record assessments, occupational health checks, verification of educational and professional qualifications, employment history and reference checks and/or sanctions check.
• Processing your payroll, including calculating and paying your salary, withholding applicable taxes, and making superannuation or pension contributions.
• Administering leave, expenses, and benefits.
• Managing your employment records, including performance, conduct, and grievance matters.
• Complying with our legal obligations as your employer under applicable employment, tax, and workplace health and safety laws.
• Managing the termination of your employment, including processing final pay and any required regulatory notifications.
• Communicating with you about your employment.
• Protecting our legitimate business interests, including the prevention of fraud.

The legal or lawful basis on which we rely to process your Personal Data will depend on the jurisdiction in which you are employed and the nature of the processing activity. In most cases, our processing is necessary to perform your employment contract, to comply with a legal obligation, or is otherwise justified under applicable law. Where we rely on a different basis, such as legitimate interests or, for sensitive information, an employment law exception, we will tell you.

8.  How we share your information

We share your Personal Data only where necessary and with the following parties:

• The Client: we share your employment information with the Client to the extent necessary to administer your employment and deliver our EOR service. This may include confirming your employment status, sharing payroll summaries, and facilitating day-to-day HR administration. The Client is an independent data controller of the information it receives and you should refer to the Client’s own privacy policies for how they handle that data.
• Nominees: where we appoint a Nominee to act as your employer of record, we will share your Personal Data with that Nominee to the extent necessary to perform your employment. The Nominees are responsible for how they handle your information.
• 91±¬ÁÏ group entities:  including entities that support the operation of the HeroForce services and employment infrastructure.
• Payroll and benefits providers: including superannuation funds, pension administrators, insurers, and salary packaging providers.
• Government agencies and tax authorities: where required by applicable law in your jurisdiction.
• Background check and identity verification providers: where applicable as part of your onboarding.
• Professional advisers: including legal, financial, and HR advisers engaged by Remote Hero.
• Regulators and law enforcement:  where we are required or permitted to do so by applicable law.

We do not sell your Personal Data to third parties, and we do not share your Personal Data with any party for their own marketing purposes.

9.  International data transfers

91±¬ÁÏ is a global company. As part of providing the HeroForce service, your Personal Data may be transferred to and processed in countries other than the one in which you are employed. This includes countries where 91±¬ÁÏ group entities, the Client, or our service providers are located.

When we transfer Personal Data across borders, we take steps to ensure that appropriate safeguards are in place to protect your information in accordance with applicable privacy and data protection laws. These safeguards may include contractual arrangements with recipients, reliance on adequacy decisions or frameworks recognised by applicable law, or other lawful transfer mechanisms. 

10.  Security and accuracy

We take reasonable and appropriate technical and organisational steps to protect your Personal Data against misuse, interference, loss, and unauthorised access, modification, or disclosure. Our security measures include encryption, access controls, multi-factor authentication, and regular security assessments.

You are responsible for keeping your platform login credentials secure and for notifying us promptly if you suspect any unauthorised access to your account.

If you believe any of the Personal Data we hold about you is inaccurate or out of date, please contact us or update your details directly through the 91±¬ÁÏ platform.

11.  Data retention

We retain your Personal Data for as long as is necessary to fulfil the purposes set out in this policy and to comply with our legal obligations. Employment records are generally retained for a minimum period following the end of your employment in accordance with applicable laws in your jurisdiction.

At the end of the applicable retention period, your Personal Data may be securely deleted or anonymised. Where data is held on behalf of or shared with the Client, it may be returned to or deleted at the Client’s direction in accordance with our agreement with them.

12.  Your rights

Depending on the country in which you are employed and the applicable laws, you may have a number of rights in relation to the Personal Data we hold about you. These may include the right to:

• Access the Personal Data we hold about you.
• Request correction of inaccurate or incomplete information.
• Request erasure or deletion of your Personal Data in certain circumstances.
• Object to or restrict certain types of processing.
• Receive your Personal Data in a portable format where technically feasible.
• Not be subject to solely automated decision-making that produces significant effects on you.
• Complain in regard to how your data is processed. 

Not all rights apply in all jurisdictions. We will tell you if a right is not available to you in your location when you make a request.

To exercise any of these rights, please contact us via privacy@employmenthero.com. We will respond within the timeframe required by the laws applicable to your jurisdiction.

Data breach notification

If we become aware of a data breach that is likely to result in serious harm to you, we will notify you and the relevant regulatory authority to the extent required by applicable law in your jurisdiction.

13.  How to contact us

If you have any questions about this policy, wish to exercise your rights, or want to raise a concern about how we handle your Personal Data, please contact us at privacy@employmenthero.com.

14.  Complaints

If you are not satisfied with how we have handled your Personal Data or responded to a privacy request, you have the right to lodge a complaint with the relevant privacy or data protection authority in your jurisdiction.

15.  Changes to this policy

We may update this policy from time to time to reflect changes in our practices, the services we provide, or applicable law. Where changes are material, we will notify you via the 91±¬ÁÏ platform or by email before the changes take effect.

The effective date at the top of this policy indicates when it was last updated. Archived versions of this policy are available at employmenthero.com/legals/archived.