TalentFora Sub-Processor and Data Transfer Summary

1. Purpose and Platform Operations

TalentFora is an AI-assisted resume scanning tool and assistive technology platform designed to streamline recruitment processes. The Platform operates strictly as an assistive technology requiring mandatory human oversight and does not engage in solely automated decision-making. TalentFora uses group entities and third-party service providers to operate, host, secure, support, and improve the Platform.

This summary explains the main providers involved in processing or supporting customer and candidate data and outlines our compliance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).

2. Company and Group Structure

TalentFora is a product of the Forasoftware Group.

For customers located in Australia and globally (excluding India), TalentFora is sold, operated, and contracted by FORASOFTWARE AUSTRALIA PTY LTD (ACN: 685 226 706 | ABN: 25 685 226 706), with its principal place of business at U 1 29 HELEN ST. NEWTOWN QLD 4350.

In India, TalentFora is sold by Softfoora Services Pvt. Ltd. Softfoora Services Pvt. Ltd. may also provide critical engineering, development, support, debugging, maintenance, and infrastructure support for the Platform globally.

3. Current Providers and Processing Roles

• Entity / Provider: FORASOFTWARE AUSTRALIA PTY LTD (ACN: 685 226 706 | ABN: 25 685 226 706)
  Role / Purpose: Contracting entity for customers located outside India; platform operation, customer support, data governance, and privacy compliance.
  Location / Transfer Notes: U 1 29 HELEN ST. NEWTOWN QLD 4350, Australia.
• Entity / Provider: Softfoora Services Pvt. Ltd.
  Role / Purpose: Development, engineering support, maintenance, debugging, AI support, infrastructure support, and India customer operations.
  Location / Transfer Notes: India. Access is subject to applicable safeguards, internal access controls, role-based restrictions, and compliance with APP 8.
• Entity / Provider: Microsoft Azure
  Role / Purpose: Cloud hosting, storage, infrastructure, and security for Australian and applicable global Platform operations.
  Location / Transfer Notes: Australia (and other applicable global regions).
• Entity / Provider: Microsoft Azure / Microsoft India
  Role / Purpose: Cloud hosting, storage, infrastructure, and security for India customer data and India Platform operations.
  Location / Transfer Notes: India / Azure India.
• Entity / Provider: Stripe
  Role / Purpose: Payment processing, billing, subscription payments, and payment-related support.
  Location / Transfer Notes: Used for customers outside India. Provider locations may vary and are subject to Stripe's own processing terms and safeguards.
• Entity / Provider: Razorpay
  Role / Purpose: Payment processing, billing, subscription payments, and payment-related support.
  Location / Transfer Notes: Used for customers in India. Provider locations may vary and are subject to Razorpay's own processing terms and safeguards.
• Entity / Provider: Email, support, analytics, and communications providers
  Role / Purpose: Customer communications, support, analytics, monitoring, service improvement, and operational communications.
  Location / Transfer Notes: Provider locations may vary. TalentFora describes these providers by category because specific tools may change from time to time.

4. Cross-Border Data Access and International Transfers

Where personal information is accessed, disclosed, or processed outside of Australia, FORASOFTWARE AUSTRALIA PTY LTD takes reasonable steps to ensure that the overseas recipient does not breach the Australian Privacy Principles (APPs) in relation to the information, in strict accordance with APP 8 (Cross-border disclosure of personal information).

These reasonable steps and safeguards include:

• Data processing agreements binding recipients to APP-equivalent standards;
• Internal transfer and privacy impact assessments;
• Encryption in transit and at rest;
• Pseudonymisation of personal information where practicable;
• Strict role-based access controls;
• Comprehensive logging and monitoring of data access;
• Limiting access strictly on a need-to-know basis.

5. Australian Candidate Data and Privacy Rights

TalentFora's current data protection position is that Australian customer and candidate personal information is primarily hosted using Microsoft Azure infrastructure.

India-based support or engineering personnel (Softfoora Services Pvt. Ltd.) and overseas cloud infrastructure providers may access customer and candidate data, including resumes/CVs, where strictly necessary for support, debugging, maintenance, security, reliability, or service improvement purposes.

Such access is controlled through managed user groups, role-based access controls, limited employee access rights, internal access restrictions, logging/monitoring, tenant configuration, and other appropriate technical and organisational safeguards. TalentFora limits access by support role, employee title, managed user group, tenant configuration, or other access-control mechanisms where appropriate and technically available.

All data subject rights regarding personal information, including requests for access, correction, and privacy-related complaints, are managed in accordance with the APPs. Any unresolved complaints may be escalated to the Office of the Australian Information Commissioner (OAIC).

6. Customer Responsibility After Export & Australian Consumer Law

Where customers download, export, or otherwise access candidate data outside the Platform, they act as independent entities and are entirely responsible for the subsequent use, storage, security, sharing, transfer, retention, deletion, and legal compliance of that data under the Privacy Act 1988 (Cth).

7. Governing Law and Jurisdiction

This Summary, and any disputes arising out of or in connection with the processing of personal information or platform utilization, shall be governed by and construed in accordance with the laws of New South Wales and the federal laws of Australia. The parties irrevocably submit to the exclusive jurisdiction of the courts of New South Wales, Australia.

8. Updates

TalentFora may update this summary from time to time as providers, hosting arrangements, payment processors, or support tools change, or to reflect regulatory updates issued by the OAIC or amendments to Australian privacy legislation.