Privacy Policy

1. Who we are

This policy is issued by Jason Davey, trading as Multi-Modal Design (ABN [●]), based in Sydney, Australia (“MMD”, “we”, “us”). It applies to the public website at multimodaldesign.com.au and its subdomains; the CapX application (the assessment, “Ana” conversations, results, team and studio surfaces, and the emails those send); and our direct dealings with you in connection with those services — together, “the Services”.

2. Our commitment to the Australian Privacy Principles

MMD is likely a “small business operator” under the Privacy Act 1988 (Cth) and may not be legally bound by the Australian Privacy Principles (APPs). We have chosen to be bound by them anyway. By publishing this policy we commit to handling personal information in accordance with the APPs and the Notifiable Data Breaches (NDB) scheme, and we accept the obligations that come with that commitment.

We do this because a capability assessment only works if you are honest in it, and you can only be honest with a service you trust. We would rather earn that than claim it.

3. What we collect

We collect only what the Services need to work. What follows is written from how the product is actually built, not from a template.

3.1 When you check your signals (the public assessment)

3.2 When you create an account, join a studio, or are invited by your organisation

3.3 When you are a manager, studio partner, or team coordinator

3.4 When you apply to a founding cohort

Your application conversation, the details you give in it, and the draft scores it produces are kept so we can assess your application and, if you join, carry them into your cohort record.

3.5 Automatically, when you use the Services

We do not use advertising cookies, third-party tracking pixels, or any form of cross-site tracking.

3.6 What we deliberately do not collect

We do not ask for, and ask you not to volunteer, sensitive information as defined in the Privacy Act — health information, racial or ethnic origin, political or religious beliefs, sexual orientation, criminal record, and so on. Assessment conversations are free text, so you could type such things; if you do, they are stored as part of your conversation and covered by this policy, but we do not extract, score, or index them, and we will remove them on request (section 9).

We do not knowingly collect information from anyone under 18. The Services are for working professionals.

4. How we use your information

1. Produce your reading. Your conversation is analysed to produce your capability scores, confidence levels, evidence and narrative. Part of that analysis is rule-based and runs on our own servers; part is performed by a large-language-model provider (section 7).
2. Run the Services — sign you in, keep your reading attached to you, and send the transactional emails the product depends on (your result link, an invitation, a reminder that a conversation is unfinished, a re-assessment check-in, or a note about your application).
3. Show the right people the right things — you, and if you are in an organisation's space, that organisation's coordinators (section 6).
4. Improve the product — using analytics events and, where you have opted in, anonymised assessment data (section 5).
5. Meet our legal obligations and respond to lawful requests.

We do not use your information to:

• sell, rent, or trade it to anyone;
• serve advertising, ours or anyone else's;
• build a profile of you for any purpose other than showing you your own reading;
• make automated decisions about your employment, pay, promotion, or access to anything. CapX produces a map of where your capability currently sits, in your own words, for your own use and your team's development. It is not a verdict and it is not designed to be used as one. If an organisation you belong to attempts to use a CapX reading as the sole basis for an adverse employment decision, that is a misuse of the product and outside what we license it for.

We will only use your information for a purpose you would not reasonably expect if you have consented, or the law requires or permits it.

5. The cross-industry capability dataset (opt-in only)

We are building an anonymised, cross-industry dataset of capability readings so the method can be validated and the readings it produces can be compared against a real population rather than a theory.

Your data joins this dataset only if you tick the box that says so. The default is no. When you do opt in:

• your name, email address, and any free text that could identify you are removed;
• your organisation is reduced to an industry category, never a company name;
• the retained record is your scores, confidence levels, role context, industry, and the timing of your assessment;
• the dataset is used for research, method validation, and aggregate benchmarks. No individual is identifiable in anything published from it.

You can withdraw at any time by emailing us (section 12). We will remove your record from future analysis; anything already published in aggregate cannot be recalled, but cannot identify you either.

6. Who can see your data inside the product

This section exists because it is the question people most want answered and most policies avoid.

• You can see your own conversations, readings, narrative, and history.
• Your organisation's coordinators — the manager or studio partner who set up your organisation's space and invited you — can see the assessments of members of that space. That includes the scores and the conversation transcript that produced them, so they can understand the reading, not just the number. Data is isolated per organisation at the database level (row-level security); a coordinator of one organisation cannot see another organisation's members under any circumstances.
• Nobody outside your organisation can see your data unless you share a report link yourself. Report links carry an unguessable token; anyone you give the link to can view that report until the link is revoked.
• MMD (in practice, the founder, and any contractor bound by confidentiality who is helping run the service) can access data to operate, support, and debug the Services, to respond to your requests, and to conduct the research described in section 5. We do not browse individual conversations for curiosity.

If you check your signals through the public link and are not in an organisation's space, no coordinator exists and only you and MMD can see your reading — unless you later accept an invitation from an organisation, in which case your reading can be attached to that organisation's space. We will tell you that at the point you accept.

7. Who we share your information with, and where it goes

We do not share personal information with anyone except the service providers that run the product for us, each of which acts on our instructions and is bound by its own contractual and certified obligations.

Overseas disclosure (APP 8). Because these providers process data outside Australia, your personal information is stored in Japan and processed in the United States. By using the Services you acknowledge this. We have chosen providers that hold recognised security certifications (section 8), we limit each to the data it needs, and we remain accountable to you under this policy for how they handle it. We do not disclose personal information to any other overseas recipient.

We may also disclose personal information if required by law, court order, or a regulator with jurisdiction over us, and will tell you unless legally prevented. If MMD is ever sold or merges with another business, personal information may be transferred to the new operator, who will be bound by this policy or one at least as protective, and you will be notified.

8. Security — what we have, and what we don't

We hold your assessment conversations, which can be candid. Here is an honest account of how they are protected.

What is in place

• All data is encrypted in transit (TLS) and at rest by our providers.
• Every organisation's data is isolated by database row-level security: access is enforced by the database itself, not just by the application.
• The application's privileged database credentials are held server-side only and are never exposed to the browser.
• Anonymous assessment sessions are accessed only through single-use, unguessable tokens.
• Our infrastructure providers — Supabase, Vercel, Anthropic, Mixpanel, and Resend — each maintain independently audited security programs (SOC 2 Type II and, for several, ISO 27001). We rely on those controls for the layers they operate.
• Access to production data by MMD is limited to the founder and any contractor under written confidentiality, and only for the purposes in section 6.

What is not in place, and we won't pretend otherwise

• MMD itself does not hold a SOC 2, ISO 27001, IRAP, or Essential Eight assessment. We are a founder-run business at an early stage; obtaining our own certification is a planned step as the business grows, not something we claim now.
• We have not yet commissioned an independent penetration test of the application.

If your organisation requires vendor security documentation, we will answer a security questionnaire honestly and share our providers' certifications on request.

If something goes wrong. We have adopted the NDB scheme voluntarily. If we become aware of a data breach that is likely to result in serious harm to you, we will notify you and the Office of the Australian Information Commissioner (OAIC) as soon as practicable, and tell you what happened, what data was involved, and what we recommend you do.

9. Your rights: access, correction, deletion, and portability

You can ask us, at any time, to:

• Access the personal information we hold about you, including a copy of your assessment conversations and readings;
• Correct anything that is inaccurate or out of date;
• Delete your account and all personal information attached to it. We will delete your profile, conversations, scores, narrative, and analytics identity within 30 days, and confirm when done. Anonymised dataset records (section 5) are not personal information once anonymised, but we will remove your record from future analysis if you ask. Backups held by our database provider expire on the provider's standard cycle;
• Export your readings in a portable format;
• Withdraw consent you have previously given (for example, to the dataset, or to marketing emails).

To exercise any of these, email us at the address in section 12. We will respond within 30 days and will not charge you. We may need to verify your identity first — usually by asking you to write from the email address on your account. If you are a member of an organisation's space, deleting your data removes it from that organisation's view too.

10. How long we keep your information

• Active accounts and readings: for as long as you have an account or an open reading, so you can return to it and see your progress over time. Re-assessment is central to the product, which is why we do not auto-expire readings.
• Public signal checks with no account: we keep the reading so your result link keeps working. Email us if you'd like it removed.
• Leads and applications: until the enquiry is resolved and for a reasonable period afterwards, then deleted or de-identified.
• Org-chart uploads: only as long as needed to create member records and resolve import errors, then removed.
• Analytics events: per Mixpanel's retention settings for our project, currently [●] months.
• Transactional email records: per Resend's standard retention.
• Anonymised dataset records: indefinitely, because they are no longer personal information.

When we no longer need personal information, we delete or de-identify it.

11. Emails we send

The product sends transactional emails: your result link, invitations from an organisation, a reminder if you left a conversation unfinished, a re-assessment check-in when one is due, and updates on a cohort application. These are part of the service and you receive them because you started something that needs a reply.

We will only send you marketing or newsletter email if you have opted in, and every such email carries an unsubscribe link that works.

12. Contact, questions and complaints

Privacy contact: privacy@multimodaldesign.com.au
Post: Multi-Modal Design, Sydney NSW, Australia

If you believe we have mishandled your personal information, email us first. We will acknowledge your complaint within 7 days, investigate, and respond within 30 days. If you are not satisfied with our response, you can complain to the Office of the Australian Information Commissioner (OAIC) at oaic.gov.au or on 1300 363 992.

If you are outside Australia, you may also have rights under your local law (for example the UK or EU GDPR). We will honour equivalent requests from anyone, regardless of where you live.

13. Changes to this policy

When we change this policy we will update the version number and effective date at the top, keep prior versions available on request, and — for any change that materially affects how we use your data — email account holders before it takes effect. The policy in force is always the one published at multimodaldesign.com.au/privacy.