Privacy Policy
Last updated 20 August 2026
1. Introduction
1.1 This Privacy Policy explains how Compozer Pty Ltd (ABN 24 631 334 944) (Compozer, we, us or our) collects, uses, discloses, and protects personal information. Compozer operates Compozer, a cloud-based eLearning authoring platform (Service), available at compozer.com (Website).
1.2 We handle personal information in accordance with the Privacy Act 1988 (Cth), including the Australian Privacy Principles in Schedule 1 to that Act, and, where they apply, the General Data Protection Regulation (Regulation (EU) 2016/679) (EU GDPR), the UK GDPR, and other applicable data protection laws. In this policy, personal information includes personal data as defined in those laws.
1.3 This policy describes the personal information for which we are the controller, including information about visitors to our Website, our customers, and the personnel of our customers. Where our customers use the Service to process personal information within their own content, we act as a processor on their behalf, and our Data Processing Agreement at compozer.com/trust/dpa governs that processing rather than this policy.
2. The personal information we collect
2.1 Depending on how you interact with us, the personal information we collect may include:
- (a) your name;
- (b) your email address;
- (c) phone number;
- (d) your mailing or business address;
- (e) your username and account credentials;
- (f) billing and payment information;
- (g) information you provide when you contact us,
- (i) take part in a survey or promotion,
- (ii) or apply for a role with us;
- (h) usage, device, and analytics information, such as your IP address; and
- (i) any other information you choose to provide to us.
2.2 We do not seek to collect sensitive information (as defined in the Privacy Act 1988 (Cth)) or special category data (as described in Article 9 of the EU GDPR) about you through the Website in the ordinary course, and we ask that you do not provide it unless we specifically request it.
3. How we collect personal information
3.1 We collect personal information directly from you when you use the Website or Service, create or manage an account, contact us, subscribe to updates, or otherwise deal with us. We also collect information automatically through cookies and similar technologies, as described in our Cookies Policy at compozer.com/trust/cookies, and we may receive information from third parties, such as our service providers and, where you are the personnel of a customer, from that customer.
4. How we use your personal information
4.1 We use personal information for the purposes set out below. For individuals in the United Kingdom and the European Economic Area, the table also identifies our legal basis under Article 6 of the UK GDPR and EU GDPR.
| Purpose | Legal basis (UK/EU) |
|---|---|
| To provide, administer, and support the Service and your account, and to respond to your enquiries. | Performance of a contract with you, or taking steps at your request before entering into a contract. |
| To process payments and manage billing. | Performance of a contract, and compliance with our legal obligations. |
| To secure the Website and Service, prevent fraud and misuse, and maintain the integrity of our systems. | Our legitimate interests in keeping the Website and Service secure. |
| To analyse and improve the Website, Service, and customer experience, including through analytics. | Our legitimate interests in operating and improving our business. |
| To send you marketing and promotional communications about our products and services. | Your consent, or our legitimate interests in marketing to existing customers, subject to your right to opt out. |
| To comply with our legal obligations, resolve disputes, and enforce our agreements. | Compliance with a legal obligation, and our legitimate interests in protecting our rights. |
| To consider your application if you apply for a role with us. | Our legitimate interests in recruitment, and taking steps before entering into a contract. |
4.2 Where we rely on your consent, you can withdraw it at any time. You can opt out of marketing communications at any time by using the unsubscribe facility in the communication or by contacting us. We handle marketing communications in accordance with the Spam Act 2003 (Cth) and other applicable laws.
5. AI features and your content
5.1 The Service includes features that use third-party artificial-intelligence providers to help our customers generate and enhance course content. When a customer uses those features, the relevant content is sent to the applicable AI provider to generate the output. Those providers are engaged as subprocessors and are listed on our Subprocessor List at compozer.com/trust/subprocessors. Where that content includes personal information, our customer is the controller of it and our Data Processing Agreement governs how we and our subprocessors process it.
6. When we share your personal information
6.1 We do not sell your personal information. We share it only as described in this policy, including with:
- (a) our service providers and subprocessors, who help us operate the Website and Service, including for hosting and infrastructure, database services, authentication, payments, email delivery, product and marketing communications (such as Mailchimp), analytics, customer support, and AI features. Our current subprocessors are listed on our Subprocessor List at compozer.com/trust/subprocessors;
- (b) our professional advisers, such as accountants, auditors, and lawyers, where reasonably necessary;
- (c) a purchaser or potential purchaser of our business or assets, in connection with an actual or proposed sale, merger, or reorganisation, subject to appropriate confidentiality protections; and
- (d) a person to whom we are required or authorised to disclose it by law, or to protect our rights, property, or safety or those of others.
6.2 Where we share personal information with a third party, we take reasonable steps to require the third party to handle it consistently with this policy and applicable law.
7. International data transfers
7.1 Some of our service providers and subprocessors are located, or store or process data, outside Australia and outside the United Kingdom and the European Economic Area, including in the United States and the European Union, as indicated on our Subprocessor List. Some of those countries may not provide the same level of data protection as your own.
7.2 Where we transfer personal information protected by the UK GDPR or EU GDPR to a country that is not subject to an adequacy decision, we put in place appropriate safeguards, such as the standard contractual clauses approved by the European Commission and the United Kingdom's international data transfer addendum. You can contact us for more information about those safeguards.
8. How we keep your information secure
8.1 We maintain technical and organisational measures designed to protect personal information against loss, misuse, and unauthorised access, alteration, or disclosure, as described in our Security Policy at compozer.com/trust/security. These include encryption in transit and at rest, access controls, and confidentiality obligations for our personnel. No system is completely secure, and we cannot guarantee the absolute security of your personal information.
9. How long we keep your information
9.1 We keep personal information only for as long as we need it for the purposes for which we collected it, including to provide the Service, maintain our records, and satisfy our legal, accounting, and reporting obligations, and then we securely delete or de-identify it. If you would like more information about our retention periods, please contact us.
10. Your privacy rights
10.1 Subject to applicable law, you have rights in relation to your personal information, which may include the right to: access the personal information we hold about you; ask us to correct it if it is inaccurate or out of date; ask us to delete it; object to, or ask us to restrict, our processing of it; withdraw your consent where we rely on consent; and receive certain information in a portable format. For individuals in the United Kingdom and the European Economic Area, these rights arise under the UK GDPR and EU GDPR; for individuals in Australia, the Australian Privacy Principles give you rights to access and correct your personal information.
10.2 To exercise any of these rights, please contact us at privacy@compozer.com. We will respond within the timeframe required by applicable law. We may need to verify your identity before we act on your request.
10.3 If you are not satisfied with how we handle your personal information or a privacy request, you can lodge a complaint with a supervisory authority. In Australia, that is the Office of the Australian Information Commissioner (oaic.gov.au). In the United Kingdom, it is the Information Commissioner's Office (ico.org.uk). In the European Economic Area, it is the data protection authority in your country. We ask that you contact us first so that we can try to resolve your concern.
11. Cookies
11.1 We use cookies and similar technologies on the Website and in the Service. Our Cookies Policy at compozer.com/trust/cookies explains what cookies we use, why we use them, and how you can control them.
12. Children's privacy
12.1 The Website and Service are intended for business and professional use and are not directed to children. We do not knowingly collect personal information from children. If you believe a child has provided us with personal information, please contact us and we will take reasonable steps to delete it.
13. Changes to this policy
13.1 We may update this Privacy Policy from time to time by publishing an updated version on the Website and changing the 'last updated' date above. Where a change is significant, we will take reasonable steps to notify you. We encourage you to review this policy periodically.
14. How to contact us
14.1 If you have any questions about this Privacy Policy or how we handle your personal information, or if you would like to access or correct your personal information or make a complaint, please contact us at privacy@compozer.com.