Our Commitment to Privacy
At 360now, we understand that privacy is paramount when dealing with personal and professional feedback. This Privacy Statement outlines how we collect, use, protect, and disclose information in relation to our 360-degree review services.
Information We Collect
Personal Information: We collect personal data such as names, email addresses, and job titles from users to provide our services. This information is necessary to personalise feedback, send notifications, and manage accounts.
Feedback Data: The content of the reviews, including ratings and comments, is collected to generate insights for the users.
Coaching Conversation Data: If you use the AI Coach, we collect the questions you ask and the Coach's responses, along with any feedback you give on those responses (for example, marking an answer as helpful or unhelpful). This is linked to your account and your review results so the Coach can give relevant answers.
Sensitive Information: Because the comment fields in our surveys are free-text, a response may occasionally include sensitive information (for example, information about a person's health), as defined under the Privacy Act 1988 (Cth). We do not ask for sensitive information and it is not required to complete a review. Where such information is voluntarily included in a comment, you consent to us collecting and handling it for the purpose of preparing the feedback report, as described in this Privacy Statement. We ask that raters avoid including sensitive information about themselves or others in their comments.
This also applies to the AI Coach: because coaching conversations are free-text, you may occasionally choose to share sensitive information about yourself. We do not ask for sensitive information and it is not required to use the Coach. Where you voluntarily include it, you consent to us collecting and handling it for the purpose of providing coaching responses, as described in this Privacy Statement.
Usage Data: We automatically collect information on how our website and services are accessed and used, including IP addresses, browser type, and interaction data. If you use the "Ask 360now" chat on our public website, the messages you type are processed by our AI provider (see "AI Coach and Other AI Features" below) together with public information about 360now; that chat does not have access to any review data.
We only collect and use personal data where you have given clear, informed consent. You may withdraw your consent at any time.
How We Use Your Information
Service Provision: To conduct 360-degree reviews, deliver feedback reports, and provide customer support.
Coaching: To provide AI Coach responses based on your review results and your conversation history, to let you continue a coaching conversation across visits, and to send you the monthly roadmap emails that draw on your report (you can stop these at any time).
Improvement of Services: To analyse usage patterns for enhancing our platform's functionality and user experience.
Communication: To send you updates, security alerts, and marketing communications if you opt in.
Automated Processing: Feedback reports, including competency summaries and development recommendations, are generated using automated systems, including third-party artificial intelligence tools (see "AI Report Generation" below). These processes summarise and structure feedback already provided by raters; they do not make decisions about your employment, engagement, or any other outcome that affects your legal rights.
AI Coach responses and the monthly roadmap emails are also generated using automated systems, including third-party artificial intelligence tools (see "AI Coach and Other AI Features" below). Like report generation, the Coach summarises and responds to information already available in your report; it does not make decisions about your employment, engagement, or any other outcome that affects your legal rights, and it does not provide legal, medical, or HR advice.
Sharing of Information
Service Providers: We may share data with third-party service providers who assist us in delivering our services (e.g., hosting providers, analytics services). These providers are bound by confidentiality obligations.
Where Your Data Is Stored: 360now is hosted in the United States. Your account details, review responses, feedback reports and coaching conversations are stored on servers located in the United States, operated on our behalf by our hosting and database providers under contract. By creating an account or completing a review, you consent to your personal information being stored and processed outside Australia.
Overseas Disclosure: As well as hosting, we use service providers outside Australia – predominantly in the United States – for email delivery, payment processing, AI report generation (see "AI Report Generation" below), the AI Coach (see "AI Coach and Other AI Features" below), customer relationship management, and website analytics and advertising measurement (see "Cookies and Tracking" below). Each of these providers receives only the information reasonably necessary for the service it performs, and handles it as our service provider under contract rather than for its own purposes.
Because these recipients are overseas, we cannot control their handling of your information to the same extent as we control our own. Where we disclose your information overseas we take reasonable steps to ensure the recipient handles it consistently with the Australian Privacy Principles, including under contractual terms that restrict what the recipient may do with it. You may ask us at any time which providers currently hold your information and where, by contacting info@360now.com.au.
Legal Compliance: We will disclose information if required by law or in response to valid legal requests.
Aggregated Data: We may use de-identified, aggregated response data for research and marketing purposes, including instrument research and validation of our competency framework (see "Research and Instrument Development" below), which does not identify you personally.
Research and Instrument Development
We use de-identified, aggregated response data – data that has had names, contact details, and other identifying information removed, and is combined across multiple respondents – to research and improve the 360now assessment instrument. This includes validating the reliability of our competency framework, benchmarking results across industries, and refining how questions are scored.
Because this data is de-identified and aggregated, it cannot reasonably be used to re-identify you. We do not use your individually identifiable feedback responses for this purpose without your separate consent.
Coaching conversations: Where you rate an AI Coach response as helpful or unhelpful, a member of our team may review that exchange (your question and the Coach's answer) in order to improve the Coach. Beyond that, we analyse coaching conversations only in de-identified, aggregated form, for example which competencies leaders ask about most and how often responses are rated helpful. We do not use your identifiable coaching conversations for research without your separate consent.
AI Report Generation
To generate written summaries and development recommendations within your 360now report, we share relevant feedback content – including raters' comments and competency scores – with OpenAI OpCo, LLC, a United States-based artificial intelligence service provider. This may involve your feedback data being processed and stored on servers located outside Australia. We have reviewed OpenAI's data handling and retention practices and only share the information reasonably necessary to generate your report. OpenAI processes this data as our service provider under a data processing agreement and does not use it to train its models. We take reasonable steps to ensure this overseas handling is consistent with the Australian Privacy Principles.
AI Coach and Other AI Features
To power the AI Coach and the monthly roadmap emails, we share your report data – including your competency scores, rater comment summaries, and recommendations – along with the questions you ask the Coach, with Anthropic, PBC, a United States-based artificial intelligence service provider. This may involve your data being processed and stored on servers located outside Australia. Your coaching conversations are private to your account and are not visible to your raters, your manager, or anyone else at your organisation. Anthropic processes this data as our service provider under its commercial terms and does not use it to train its models. We only share the information reasonably necessary to provide these features, and we take reasonable steps to ensure this overseas handling is consistent with the Australian Privacy Principles.
The same provider powers the "Ask 360now" chat on our public website, which receives only what a visitor types and public information about 360now.
The AI Coach coaches leadership behaviour only. It is designed to steer questions about wellbeing, legal, or HR matters toward appropriate professional support rather than answering them directly. Rater comments are provided to the Coach only as summaries, and the Coach will not attribute feedback to any rater.
Cookies and Tracking
We use cookies and similar technologies to keep you logged in, understand how our website is used and measure our marketing. These include Google Tag Manager, which we use to manage our analytics tools (currently Google Analytics and the LinkedIn Insight Tag), and the Meta Pixel, which helps us measure the results of our Facebook and Instagram advertising and show relevant ads. These tools may collect information such as your IP address, browser type, pages visited and actions taken on our site. They do not have access to your review data, reports or coaching conversations.
You can block or delete cookies through your browser settings, though some parts of the site may not work properly without them. You can manage how Meta uses your information for advertising in your Facebook or Instagram ad preferences.
Measuring our advertising: when you complete a Self360 or purchase a review, we tell our advertising platforms – currently Meta and LinkedIn – that the action happened, so we can tell which of our ads are working. This is sent both from your browser and from our own servers, and it includes an irreversibly hashed form of your email address, which those platforms use only to check whether you are someone who saw one of our ads. We do not send them your review responses, your scores, your report or your coaching conversations. These platforms are located outside Australia (see "Overseas Disclosure" above).
Data Security
We implement industry-standard security measures to protect your data from unauthorised access, alteration, disclosure, or destruction. However, no method of transmission over the Internet or electronic storage is 100% secure.
Your Rights
Access and Correction: You have the right to access, update, or delete your personal information by contacting us.
Opt-Out: You can opt out of marketing communications at any time.
Data Portability: Upon request, we'll provide you with a copy of your personal data in a commonly used format.
Right to Erasure: You may request that we delete your personal data when it is no longer needed, consent has been withdrawn, or it was collected unlawfully. This includes your Coaching Conversation Data. You may request deletion of your coaching conversation history at any time by contacting us.
Retention of Data
We retain personal information only for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements. Coaching conversations are retained while your account is active so you can continue them across visits. They are deleted when your account is deleted, or earlier if you ask us to delete them.
Account closure: If your account has been inactive for 24 months, holds no unused credits and has no AI Coach access remaining, we may close it after giving you at least 30 days' notice by email. You can also ask us to close your account at any time by contacting info@360now.com.au. When an account is closed, we delete or de-identify your personal information, reports and coaching conversations within 90 days, unless we are required by law to keep them. Rater responses form part of the leader's report and are deleted or de-identified along with it. Copies of deleted data may remain in secure backups until they are overwritten in our normal backup cycle. Backups are kept only for disaster recovery and are not otherwise accessed.
Self360: Self360 does not create an account. We keep your Self360 responses for 12 months, then delete or de-identify them. If you opted in to marketing communications, we keep your email address until you unsubscribe.
Changes to This Privacy Statement
We may update our Privacy Statement from time to time. We will notify you of any changes by posting the new Privacy Statement on this page.