Klaw Brands Pty Ltd (ACN 611 042 267, ABN 90 611 042 267) trading as Paragon Talent Suite ("we", "us", "our") operates the Paragon Talent Suite applicant tracking system (the "Platform") at paragonts.com.
We are committed to protecting the privacy of all individuals whose personal information we handle. This Privacy Policy explains how we collect, use, store, disclose and manage personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).
Our Privacy Officer can be contacted at privacy@paragonts.com. Klaw Brands Pty Ltd is registered in New South Wales, Australia.
When a Candidate applies for a job, registers via a contact form, or accesses the Candidate Portal, we collect personal information on behalf of the relevant Agency, including:
Important: the Agency (not Paragon Talent Suite) is the data controller for Candidate Data. We process Candidate Data as a data processor on behalf of Agencies. Candidates should direct privacy-related requests to the Agency that collected their information.
When a referee submits a reference via the Platform, we collect their name, email address, phone number, job title and employer; their relationship to and employment-history details relating to the Candidate; and their responses to reference questionnaire questions.
When you visit our website we may collect your IP address, browser and device type, the pages you visit and referral source, and information via cookies and similar technologies (see section 10). We use Google Analytics (GA4) for website analytics.
We collect personal information directly from you when you register, complete forms, submit applications or contact us; from Agencies when they upload or enter Candidate Data; from Candidates when they update their Candidate Portal profile; from referees when they submit a reference via a unique token link; and automatically through your use of the Platform (session data, usage analytics, logs).
We collect and use personal information to provide and operate the Platform; to process job applications on the Agency's instruction; to send transactional emails (confirmations, status updates, portal invites, reference requests); to provide AI Features the Agency chooses to use; for reference checking; for offer-letter signing; for billing and tax records; for security, fraud prevention and compliance; for product analytics and improvement using de-identified or aggregated data; and for business development, where permitted. Where we rely on consent, you may withdraw it at any time.
Our core application database, file storage and sovereign AI inference environment are hosted in Australia. Some limited ancillary processing, including email delivery and payment processing, may involve overseas service providers, as disclosed in the Sub-Processor Schedule below. We distinguish the following layers rather than make a single absolute claim:
We implement the following measures, which are operational in production:
Despite these measures, no system is completely secure, and we cannot guarantee the absolute security of information transmitted over the internet.
The Platform includes AI Features such as job description generation, CV extraction, call transcription and email drafting. This section explains how personal information is handled by those features. The AI provisions of our Terms of Service apply in addition to this section.
We do not use Agency Data, Candidate Data, CVs, job data, screening notes, call recordings, transcripts, reference responses or AI outputs to train, fine-tune or improve general-purpose AI models, and we do not instruct or authorise our AI providers to do so, unless the Agency has expressly opted in under a separate written agreement. Our current sovereign provider, SCX.ai, does not train on customer inference data under its terms as at the date of this policy. BYOK providers operate under their own terms.
AI outputs are assistive only and must not be used as the sole basis for shortlisting, rejection, hiring or other material recruitment decisions. Agencies are responsible for human review and for lawful, non-discriminatory recruitment.
To maintain availability we may, at our sole discretion and at any time without prior notice, substitute or supplement our sovereign AI provider with any other Australian-hosted provider; data in Sovereign AI Mode remains in Australia. We will not silently route Sovereign AI Mode data to an overseas provider. If a sovereign provider is unavailable and no Australian-hosted alternative can maintain an affected AI feature, that feature is suspended by default, and we will not process the data through a non-Australian provider unless the Agency gives explicit, revocable opt-in to temporary non-sovereign processing.
Where an Agency uses call transcription, audio recordings are processed into text and summaries. The Agency is responsible for providing all required notices and obtaining all required consents before recording, uploading or transcribing any call, and recording laws differ between Australian states and territories. Audio and transcripts are processed to provide the feature, are retained for the duration of the Agency's subscription unless deleted earlier, and raw audio is not retained beyond what is needed to produce and store the transcript except where the Agency chooses to store the recording.
Text-to-speech and synthetic voice features are not currently enabled. If introduced, they will be disclosed here, and the Platform does not create voice clones, biometric voiceprints or speaker-identification profiles unless expressly agreed in writing.
We share personal information with third-party sub-processors only to the extent necessary to operate the Platform. This schedule is kept operationally current.
| Function (provider) | Data shared | Region | Training use |
|---|---|---|---|
| Database, auth & file storage | All Platform data | Sydney, AU | n/a |
| Platform hosting / compute | Server requests, logs | Sydney, AU | n/a |
| Sovereign AI inference (default) — SCX.ai | CV text, job data, notes | Sydney, AU | No training |
| Transactional email | Name, email, auth links | Sydney, AU (US fallback) | n/a |
| Offer-letter signing | Offer details, signer name & email, signature records | Cloud (non-AU) default | n/a |
| Payment processing | Billing name, email, card details | US-based | n/a |
| Website analytics | IP address, usage data | US-based | n/a |
This schedule reflects our sub-processors as at the last-updated date of this policy. Sub-processors may change, and we will update this schedule accordingly. We can provide the current named provider for any layer on request.
Some sub-processors (the document-signing provider's default host, our payment processor and, if enabled, our analytics provider) are based outside Australia. Our transactional email provider is Australian-resident; a US-based email provider is retained only as a failover and is not used in normal operation. Where we transfer personal information overseas, we take reasonable steps under APP 8 to ensure the recipient handles it consistently with the Australian Privacy Principles.
We may also disclose personal information where required by law or regulatory authority; to protect rights, property or safety; or in connection with a merger or sale of assets, subject to equivalent privacy protections. We do not sell personal information.
You may request access to, and correction of, the personal information we hold about you by contacting our Privacy Officer at privacy@paragonts.com. We respond within 30 days. Candidates may update their information via the Candidate Portal at any time, and requests to delete Candidate Data should be directed to the relevant Agency as data controller. If you are not satisfied with our response to a complaint, you may contact the Office of the Australian Information Commissioner (OAIC) at oaic.gov.au.
Our website and Platform use strictly necessary cookies (session authentication, CSRF protection), functional cookies (preferences) and Google Analytics (GA4) with anonymised IP addresses. Analytics cookies are off until you accept them via our cookie banner. You can control cookies through your browser settings; disabling strictly necessary cookies affects Platform functionality. For Google Analytics opt-out, see tools.google.com/dlpage/gaoptout.
| Data type | Retention period | Basis |
|---|---|---|
| Agency account & team data | Subscription + 30 days | Contract; export window |
| Candidate applications & profiles | Duration of subscription | Agency instruction |
| CV files | Duration of subscription | Agency instruction |
| Call recordings & transcripts | Duration of subscription (audio only as long as needed for transcript unless stored) | Agency instruction |
| Reference submissions | Duration of subscription | Agency instruction |
| Offer letter records | Subscription + 7 years | Legal obligation (contract records) |
| Billing records | 7 years | Legal obligation (ATO) |
| System & security logs | 90 days | Security monitoring |
The Platform is not directed at individuals under 18, and we do not knowingly collect their personal information. If you believe a minor has provided information without parental consent, contact our Privacy Officer.
We may update this policy to reflect changes in our practices or legal requirements. We will notify users of material changes by email and by posting the updated policy at paragonts.com/privacy with a new "last updated" date.