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Privacy Policy

Effective as of January 2023

Policy Statement


1.1 Welcome to Compono

This site is owned by Compono Limited ACN 169 649 772 (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 Engage is a culture mapping, team and business composition, and hiring benchmarking software product.

Compono Hire is an intelligent hiring, hiring automation, and candidate analytics software product.

Compono Develop / Clui is a learning management and learning content delivery software product.

Compono Certified Skills is a learning and testing software product delivering reliable and valid learning content and assessments based on competency frameworks.


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 utilised 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.


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.


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



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


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. Compono is certified under ISO27001 – Information Security, Cybersecurity and Privacy in order to create as secure of an environment as possible for Users.


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 online so you can consider whether you wish to delete it.


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 your personal information. Where we have provided your Personal Information to a third party service provider and have the right to deal with that information, we will take reasonable steps to amend or delete your Personal Information. Where we do not have the right to deal with information provided to a third party service provider, we will assist you with requesting the third party service provider to amend or delete your Personal Information.


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.



7.1 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.


Our Site may contain links to websites operated by third parties. Those links are provided for convenience and may not remain current or be maintained. Unless expressly stated otherwise, we are not responsible for the privacy practices of, or any content on, those linked websites, and have no control over or rights in those linked websites. The privacy policies that apply to those other websites may differ substantially from our, so Privacy Policy we encourage individuals to read them before using those websites.


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.


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 top of this page.. 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.



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.


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.


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
Level 3/32 Duncan street
Brisbane QLD 4006 Australia
+61 (07) 3250 6800


13.1 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.

13.2 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.

13.3 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.

13.4 Data security

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

13.5 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 authorised by individuals. In relation to Compono Hire, 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.

13.6 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.

13.7 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 organisation. The law also allows 30 days for the respondent organisation 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


We have set out below, in a table format, a description of some of the ways we plan to use your personal information, and which of the legal bases which 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 tables below.

General Purpose

Purpose / Activity

Type of data

Lawful basis for processing including basis of legitimate interest

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)    First Name

(b)    Last Name

(c)    Contact information

(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 information

(c)    Profile

(d)     Usage data (such as what actions were performed within the application and how often users come back to the applications/products)

Necessary for our legitimate interests (to study how customers use our products / services, to develop our products, 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.

Usage data (such as what actions were performed within the application and how often users come back to the applications/products)

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 disclose to Third Party Service Providers as required for the delivery of the services/platform.

(a)    Cloud storage (Amazon Web Services)

(b)    Database (MongoDB)

(c)    Calendar management (Cronofy)

(d)    Analytics (Mixpanel)

(e)    CV Parsing (Daxtra)

(f)     Job posting and application handling (Idibu)

(g)    Learning management (SCORM)

(h)    Customer support (Zendesk)

Necessary to provide our services to you.


To develop the products and to add new features.

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 to provide you and others with a better experience, drive growth and also help Employers 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.



Purpose / Activity

Type of data

Lawful basis for processing including basis of legitimate interest

Information relating to employers

To register you as a hiring company, to create relevant job specifications to evaluate candidate fit to role requirements.

(a)    Company name

(b)    Company details

(c)    Company size

(d)    Industry

(e)    User / Recruiter name

(f)     Contact Information

(g)    General job details

(h)    Qualification and Skill requirements

(i)     Organisational fit and job fit requirements

(a) Performance of a contract with you and your company.
(b) Determine organisational / job – candidate fit.

To display your open job listings to candidates looking for work.

(a)    General job details

Performance of a contract with prospective employees or job candidates.

Information relating to candidates

To register you as a candidate, to develop organisation fit and job fit based on User responses and to develop aggregated personal work preferences content.

(a)    First Name

(b)    Last Name

(c)    Contact Information

(d)    Past employment details; dates, company name, skills

(e)    Education

(f)     CV information and other User supplied documentation

(g)    Organisation and work preferences

(a)    Performance of a contract with you.

(b)    Determine culture, personality, and job fit.

(c)    To match you to specific job relevant key selection criteria.

To evaluate, rank and screen (compare) you to other job candidates relative to a specific open role and its key selection criteria as set out by the employer

(a)    Work history and skills

(b)    Qualifications and certifications

(c)    Type of work environment preferences

(d)    Type of job duty and task preferences

(e)    Type of work behaviour preferences

Performance of a contract with employers.

To disclose to employers, job agencies and client employers you have previously applied for

(a)    List of previous application/s with that employer

(b)    Any messages and notes taken by the specific employer you have been a direct applicant.

(c)    Previous interview information

(d)    CV

(e)    Work history

(f)     Organisation and job fit preferences.

Performance of a contract with prospective employers.



Purpose / Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To provide insights to you as an employer on your organisation’s culture, employees personality, motivation, and skills/qualifications

(a)    Employee first name

(b)    Employee last name

(c)    Employee demographic information (job title, work department/division, tenure)

(d)    Employee work email

(e)    Opinions on company culture and subcultures

(f)     Individual preferences like job motivations and personality

(g)    Individual skills and qualifications

(a)    Performance of a contract with you and your company.

(b)    Aggregate data at demographic levels (combined culture data at a company, team or department level)


Develop / Clui

Purpose / Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To allow you as a customer to manage learners and administer courses

(a)    First name

(b)    Last name

(c)    Email address

(d)    Any other personal information as may be required by the customer

Performance of a contract with you and your company

To allow learners to complete courses

(a)    First name

(b)    Last name

(c)    Email address

(d)    any other personal information as may be required by the customer for users to enrol in a course

Performance of a contract with employers


Certified Skills

Purpose / Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To allow you as a customer to manager learners and administer courses

(a)    First name

(b)    Last name

(c)    Email address

Performance of a contract with you and your company

To allow learners to complete courses

(a)  First name

Performance of a contract with employers