Last updated: 9 February 2026
Hoogly Pty Ltd (ABN 93 650 454 041) (Hoogly, we, us, our) is committed to protecting the privacy and security of personal information and personal data.
This Privacy Policy explains how we collect, hold, use, disclose, store, and protect personal information when you:
This Privacy Policy is intended to comply with applicable privacy and data protection laws, including:
Please read this Privacy Policy carefully, as it contains important information about how and why your personal information is processed and the rights available to you.
Where you access Hoogly as an employee, contractor, or authorised user of an organisation that has subscribed to the Hoogly platform, your employer or engaging organisation acts as the data controller for the purposes of applicable data protection law.
In these circumstances:
Hoogly does not determine the purposes for which employee personal data is processed and does not act as a joint controller.
Where you interact with Hoogly directly (for example, by visiting our website, requesting a demo, or contacting us), Hoogly acts as a data controller in respect of that information.
When you visit our website or communicate with us directly, we may collect personal information such as your name, work email address, organisation name, contact details, job title, and any information you choose to provide in correspondence or enquiry forms. We may also collect technical information relating to your interaction with our website, including IP address, device type, browser information, and usage data through cookies and similar technologies.
Where your organisation subscribes to Hoogly, we may process personal information provided by or on behalf of your organisation, including your name, work email address, team name, manager name, and assigned user role (such as employee, manager, HR user, or administrator). Your organisation may also choose to provide optional employment-related attributes, such as location, employment type, or other demographic attributes, for the purpose of filtering, segmentation, and aggregation within the platform.
As part of the platform's functionality, Hoogly processes employee feedback content, which may include survey responses, free-text comments, AI-assisted conversational inputs, and derived insights. Hoogly is designed so that such feedback is processed in aggregated and anonymised form, and individual responses are not disclosed in an identifiable manner.
Personal information may be collected directly from you, indirectly from your organisation, or automatically through your use of the website or platform. This includes information collected when you create an account, participate in surveys or check-ins, communicate with us, or when your organisation integrates its systems (such as HRIS or collaboration tools) with the Hoogly platform.
We collect and process personal information for the purposes of providing, operating, and improving the Hoogly platform, administering customer relationships, communicating with users and customers, maintaining platform security, complying with legal obligations, and supporting aggregated insight generation and reflective conversations within organisations.
Hoogly does not use employee personal data for advertising purposes and does not sell personal information.
Hoogly uses artificial intelligence and automated processing techniques to support the generation of insights, summaries, and reflective prompts. AI functionality is designed to support understanding and development and does not constitute legal, medical, psychological, or employment advice.
Hoogly does not train cross-tenant AI models on identifiable personal data without explicit written consent from the customer. Any permitted training for platform improvement purposes uses anonymised, aggregated, and de-sensitised data only.
Personal information may be disclosed to trusted service providers and sub-processors engaged to support the operation of the platform, such as cloud hosting providers, integration partners, and communication service providers. These entities are bound by contractual obligations to protect personal information and to process it only for authorised purposes.
Where Hoogly provides information to a subscribing organisation, it does so in aggregated or anonymised form and in accordance with the platform's anonymity safeguards.
We may also disclose personal information where required or authorised by law.
Where a customer is established in the European Union, or where the processing of personal data is subject to the GDPR, Hoogly stores and processes Sensitive Employee Content exclusively within data centres located in the European Union.
For such customers, authentication, identity management, and other non-content platform services may be processed using Hoogly's core infrastructure located within the European Union and, where required for operational purposes, the United States. In all cases, appropriate safeguards are implemented to ensure that any international transfers of personal data comply with applicable data protection laws, including the GDPR.
For customers established outside the European Union and not subject to the GDPR, personal data may be stored and processed in the United States or other jurisdictions where Hoogly or its authorised sub-processors maintain infrastructure, subject to appropriate contractual and technical safeguards.
Personal information is retained only for as long as necessary to fulfil the purposes for which it was collected, including to comply with legal, accounting, or reporting requirements. Upon termination of a customer relationship, personal data may be exported for a limited period and is subsequently permanently deleted in accordance with contractual and legal requirements.
Hoogly implements appropriate technical and organisational security measures to protect personal information against misuse, interference, loss, unauthorised access, modification, or disclosure. These measures include encryption, access controls, monitoring, and incident response procedures.
Depending on your location and the applicable law, you may have rights to access, correct, erase, restrict, or object to the processing of your personal information, and to lodge a complaint with a supervisory authority. Where Hoogly acts as a processor, requests should generally be directed to your employer or organisation as the data controller.
We use cookies and similar technologies to operate our website and analyse usage. You can manage cookie preferences through your browser settings.
Hoogly may use anonymised and de-identified data for research, analytics, and service improvement purposes. Such data does not identify individuals and is not subject to this Privacy Policy.
For privacy or data protection enquiries, please contact:
Email: legal@hoogly.com
We may update this Privacy Policy from time to time by publishing an updated version on our website. The latest version will always be available online.