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EFFECTIVE AS OF APRIL 2021

Compono Privacy Policy

1. INTRODUCTION


1.1 Welcome to Compono

This site is owned by Compono Pty Ltd (Compono). Compono is concerned about privacy issues and wants you to be familiar with how we collect, use, maintain and disclose information collected from users (each a User) from the Compono website (Site), mobile apps and web apps (Apps). This privacy policy applies to apps, site and all products and services (Services) offered by Compono.


1.2 Our commitment to you

Compono is an automated job-candidate screening, ranking, and matching tool based on Recruitment Science. Using Recruitment Science, Compono’s goal is to help companies find employees that best match their positions and unique organisational culture and help candidates to find the best jobs and organisations based on their skills, qualifications and their own personal needs.


2. INFORMATION COLLECTION


2.1 Non-personal identification information

We may collect non-personal identification information about Users whenever they interact with our Apps and Site. Non-personal identification information may include the browser name, the type of computer and technical information about Users means of connection to our Site, such as the IP address, the operating system and the Internet service providers utilized and other similar information.


2.2 Web browser cookies

Our Apps and Site may use “cookies” to enhance User experience. User’s web browser places cookies on their hard drive for record-keeping purposes and sometimes to track information about them. User may choose to set their web browser to refuse cookies, or to alert you when cookies are being sent. If they do so, note that some parts of the Site may not function properly.


2.3 You may also see ads for our Site on third party websites, including on social media. These ads may be tailored to you using cookies (which track your web activity, so enable us to serve ads to customers who have visited our Site). Where you see an ad on social media, this may be because we have engaged the social network to show ads to our customers, or users who match the demographic profile of our customers. If you no longer want to see tailored ads you can change your cookie and privacy settings on your browser and these third party websites.


2.4 Compono is committed to managing personal information in an open and transparent way and handles personal information in accordance with local privacy laws.


3. HOW WE PROTECT YOUR INFORMATION


3.1 We adopt appropriate data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of your personal information, username, password, transaction information and data stored on our Apps and Site.


3.2 Sensitive and private data exchange between the Apps and Site and its Users happens over a SSL secured communication channel and is encrypted and protected with digital signatures. Our Site is also in compliance with PCI vulnerability standards in order to create as secure of an environment as possible for Users.


4. STORAGE, DEACTIVATION AND RETENTION


You may delete your profile at any time. If you do not delete your profile, we will keep your personal information for the purposes set out above. If your profile is inactive and we have your email address, we may periodically remind you that your profile is still on line so you can consider whether you wish to delete it.


5. HOW YOU CAN ACCESS, CHANGE, OR DELETE YOUR PERSONAL INFORMATION


If you would like to revoke your consent, review, correct, update, or delete the personal information that you have provided via the Site, please contact us via email on privacy@compono.com with the subject line "Update my information". We will comply with your request within such timeframe required by applicable law or otherwise as soon as reasonably practicable. You may also be able to log on to the Site and access, correct or delete your personal information.


6. COMPLIANCE WITH CHILDREN’S ONLINE PRIVACY PROTECTION ACT


Protecting the privacy of the very young is especially important. For that reason, we never collect or maintain information at our Site from those we actually know are under 13, and no part of our website is structured to attract anyone under 13.


7. SHARING YOUR PERSONAL INFORMATION


7.1 We do not sell, trade, or rent Users’ personal identification information to others. We may share generic aggregated demographic information not linked to any personal identification information regarding visitors and users with our business partners, trusted affiliates and advertisers.

We may also share Users’ personal information with third parties in the following circumstances:


  • With our suppliers and service providers working for us, e.g. hosting service providers.
  • With our professional and legal advisors.
  • With law enforcement or other governmental authorities, e.g. to report a fraud or in response to a lawful request.
  • In the event that we sell any business assets, the personal data of our customers may be disclosed to a potential buyer. In this event, we will make reasonable attempts to ensure the buyer will be bound by the terms of this Privacy Policy.
  • Otherwise where we have your consent or are otherwise legally permitted to do so.

8. YOUR ACCEPTANCE OF THESE TERMS


By using this Site, you signify your acceptance of this policy. If you do not agree to this policy, please do not use our Apps and Site. Your continued use of the Site following the posting of changes to this policy will be deemed your acceptance of those changes.


9. CHANGES TO THIS PRIVACY POLICY


Compono has the discretion to update this privacy policy at any time. When we do, we will post a notification on the main page of our Apps or Site, revise the updated date at the bottom of this page and send you an email. We encourage Users to frequently check this page for any changes to stay informed about how we are helping to protect the personal information we collect. You acknowledge and agree that it is your responsibility to review this privacy policy periodically and become aware of modifications.


10. YOUR RIGHTS


10.1 Subject to the relevant applicable law, you may have certain rights in respect of your personal information, including rights to access, correct and request the erasure of your personal data, and to receive a copy of information you have provided to us in electronic form.


10.2 We will comply with any requests to exercise your rights in accordance with applicable law. Please be aware, however, that there are a number of limitations to these rights, and there may be circumstances where we are not able to comply with your request. To make any requests regarding your personal information, or if you have any questions or concerns regarding your personal information, you should contact us using the details below. You are also entitled to contact your local supervisory authority for data protection.


11. CONTACTING US


If you have any questions, comments, requests, or concerns related to this Privacy Policy or the information practices of this site, or if you would like to opt out of future communications, please contact us as follows:


Privacy Officer

Compono Pty Ltd

Suite 2, Level 3, 189 Kent Street

Sydney, NSW, 2000,

Australia

1300 716 004

privacy@compono.com

12. PRINCIPLES


12.1 Notice. We will provide you with notice of our data collection and processing practices in our privacy policy, including describing what personal information we collect, how we use that information, the categories of third parties with whom we may share such information (and the purposes for which we do so), the individual’s right to access such information, the choices and means through which the individual may limit the use and disclosure of personal information, and other disclosures consistent with the notice principle.


12.2 Choice. If we wish to (i) disclose your personal information to a third party (other than to a service provider who is acting on our instructions) or (ii) use it for a purpose materially different from the purposes for which it was originally collected, as set out in our Privacy Policy, we will:

1. Offer you the opportunity to opt-out of such disclosure or use; or

2. In the case of sensitive personal information, not disclose or use your personal information in this way unless we have your affirmative consent.


12.3 Onward transfers (transfers to third parties). We may transfer personal information to certain third parties, as described in our Privacy Policy. Where we transfer personal information to a third party, we will take reasonable and appropriate steps to ensure that the third party processes personal information for limited and specified purposes.


12.4 Data security. We take reasonable and appropriate measures to protect personal information from loss, misuse and unauthorized access, disclosure, alteration and destruction. We have implemented appropriate physical, electronic and managerial procedures to help safeguard and secure personal information from loss, misuse, unauthorized access or disclosure, alteration or destruction.


12.5 Data Integrity, Purpose Limitation and Access. We will process personal information in a manner that is compatible with and relevant to the purpose for which it was collected or authorized by individuals. Candidates will have access to Compono’s recruitment platform to allow candidates to update their personal information so that their personal information is current and valid.


12.6 Lawful Requests. We may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.


12.7 Contact Compono and Recourse. If you are concerned about how the personal information which you provided to us has been used, please address your inquiry or complaint first to us at the address listed above. We will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of personal information in accordance with the Principles. Please note guidance from the Office of the Australian Information Commissioner (”OAIC”) requires that any complaint must first be made to the respondent organization. The law also allows 30 days for the respondent organization to reply before a complainant may make a complaint to the OAIC.

You can obtain further general information about your privacy rights and privacy law from the OAIC by:


  • calling their Privacy Hotline on 1300 363 992
  • visiting their web site at http://www.oaic.gov.au
  • writing to:
    • The Australian Information Commissioner

      GPO Box 5218

      Sydney NSW 2001


13. PURPOSE FOR WHICH WE WILL USE YOUR PERSONAL INFORMATION


We have set out below, in a table format, a description of all the ways we plan to use your personal information, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.


Please note that we may process your personal information for more than one lawful ground depending on the specific purpose for which we are using your information. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.


Purpose / Activity Type of data Lawful basis for processing including basis of legitimate interest
To register you as a candidate, to develop organisational fit and job fit profiles based on User responses and to develop aggregated personal work preferences content. (a) Name
(b) Contact Information
(c) Past employment details; dates, company name, skills
(d) Education
(e) Organisation and work preferences
(a) Performance of a contract with you.
(b) Determine company and job fit.
(c) To match you to jobs.
To register you as a hiring company, to create relevant job specifications to evaluate candidate match to role requirements. (a) Company Name
(b) User / Recruiter Name
(c) Contact Information
(d) General job details
(e) Qualification and Skill requirements
(f) Organisational fit requirements
(a) Performance of a contract with you and your company.
(b) Determine company – candidate job fit.
To enable a third party payment system for hiring companies and recruiters to undertake secure payment (a) Company Name
(b) Contact information
(c) Payment details (credit card details)
(a) Performance of a contract with you.
(b) Necessary for our legitimate interests (to recover debts due to us).
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave a review or take a survey
(a) Name
(b) Contact information
(c) Marketing and Communications
(a) Performance of a contract with you.
(b) Necessary to comply with a legal obligation.
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products / services).
To deliver relevant website content to you and measure or understand the effectiveness of the content we serve to you. (a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Communications
Necessary for our legitimate interests (to study how customers use our products / services, to develop them, to grow our business and to inform our marketing strategy).
To use data analytics to improve our website, products / services, marketing and communications with you, customer relationships and experiences. (a) Usage Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy).
To display your profile to prospective employers and compare your profile to other job candidates. (a) Type of work environment preferences
(b) Type of duty preferences
(c) Type of work behaviour preferences
Performance of a contract with prospective employers.
To disclose to Third Party Service Providers who host the system. (a) Google Cloud
(b) Google Kuberenetes
Used for cloud storage and analytics.
To disclose to recruiters, job agencies and client employers. (a) Work History
(b) Work preferences
(c)All personal information is anonomysed before disclosure to a recruiter/job agency.
Hiring companies have to “invite” candidates to a job role and the candidate has to accept the invitation before Compono shares the candidate personal contact information.
To develop the products with new features to collect new data. All data collected in relation to future development will be aggregated and anonymous data. Compono uses data collected to conduct research and development for future features on our platform in order to provide you and others with a better experience, drive growth and also help Companies and Candidates connect to each other for employment opportunities.
To provide Services where the personal information we process is subject to GDPR. (a) The processing is necessary to provide our Services to you.
(b) You have consented to us using your personal information (e.g. where you add optional information to your account profile or if you consent to receive marketing from us).
It is in our legitimate interests as an online service provider to maintain and promote our Services. We use information about you to tailor your view of the website, to make it more interesting and relevant, to develop aggregated profiles as described above, and to improve the Services we offer.
To display your active job listings to candidates looking for work or to invite candidates to apply to your job listings. (a) General job details
(b) Qualifications required in job
(c) Skills required for job
Performance of a contract with prospective employees or job candidates.