Policy Statement

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 Hire (Shortlyster) is an applicant management, automated job-candidate screening, ranking, and matching tool based on Recruitment Science. Using Recruitment Science, Shortlyster’s goal is to help companies manage, screen, rank, and match candidates faster, better, and with less manual reviewing of CVs.

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. 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.

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

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 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 table below.