What types of information do we collect and why?

1. Collection from you: we collect and store information you provide directly to us (either in person, by email, by phone, or by any other direct means) in order to deliver our products and services. This includes:
   • Registration information. As a customer, prospective customer, or user of our services, we may collect information such as your name, student names, contact information including your phone number, teacher and student email addresses, school name, class year, country or state of your school.
   • We do not however collect any unnecessary personal information from Registrants (for instance, information about religious beliefs or date of birth).
   • In the case of school/educational institution customers, we seek consent from the School Customer to be provided with registrant information for and on behalf of that student or teacher.
2. Automatic: we use cookies (small text files stored on your devices that provide us with information such as your internet protocol (IP) address, server information, internet service provider, and information on how you interact with our website) and other services that allow us to understand how you use our online media. We use Google Analytics which tracks and measures user interaction and provides data to help improve our products and services. If you opt-out of third party tracking technologies or elect to prevent the use of cookies, this may result in the loss of functionality, restrict your use of the platform or delay or affect the way in which the platform operates.
3. Device: if you use our services or interact with us through a mobile device, we receive technical information about your device, numbers that identify the device and your location information. This information is associated with you.
4. Communications: when you communicate with us, we collect information such as your contact details (such as email address or phone number). We also engage third party services that provide us with information about how you interact with some communications we distribute. You can elect to not receive communications from us by contacting our Privacy Officer.
5. Information you provide about someone else If you provide us with personal information about someone else, you must ensure that you are authorised to disclose that information to us and that, without us taking any further steps required by applicable privacy laws, we may collect, store, use and disclose such information for the purposes described in this policy. Where we request you to do so, you must assist us with any requests by the individual to access or update the personal information you have collected from them and provided to us. If you are someone who does not have a relationship with us but believe that one of our customers has entered your personal information into our servers, you will need to contact that customer for any questions you have about your personal information (including where you want to access, correct, amend, or request that we delete, your personal information). You have the option of not identifying yourself or interacting with us using a pseudonym. However, this may not be practicable when engaging our services or purchasing our products. You can choose not to provide your personal information, but it may mean that we are unable to provide you with our products and services.

How do we use your information?

• set-up and configure accounts;
• identify our users;
• improve our service offerings;
• record and maintain user details;
• provide information on services available to users;
• provide client and user support;
• deliver marketing materials to you regarding new services and offers we believe may be of interest to you;
• comply with legal obligations;
• resolve disputes;
• respond to your enquiries and concerns and resolve disputes;
• contact you regarding your use of our services; and
• and any secondary purposes related to the above.

1. Disclosure of personal information to third parties We may disclose your information to third parties who assist us in providing, managing and administering our products and services. We will also disclose your personal information where such disclosure is required by law. We will not sell or license your information to third parties or otherwise disclose your personal information unless we believe on reasonable grounds that you have provided your authorisation. In certain circumstances we may be required to disclose your personal information without your consent in order to comply with any court orders, subpoenas or other legal process or investigation including by tax authorities, if such disclosure is required by law. Where possible and appropriate, we will notify you if we are required by law to disclose your personal information.

How do we store and secure the information we collect?

1. Security and management of personal informationWe will take reasonable steps to protect the personal information we hold from misuse, loss, and unauthorised and accidental access, modification, disclosure, destruction, or other action which prevents or otherwise hinders our access to your personal information on a temporary or permanent basis. We do this by:
   • Putting in place physical, electronic and procedural safeguards in line with industry standards;
   • Requiring any third party providers to have acceptable security measures to keep personal information secure;
   • Limiting access to the information we collect about you;
   • Imposing confidentiality requirements on our employees;
   • Only providing access to personal information once proper identification has been given.
   While we take all steps reasonable in the circumstances to protect your information, in the unlikely event of a data breach we will notify you in accordance with our obligations under the Privacy Act. Where there is a risk of serious harm arising from the breach, we will notify you and any relevant authorities. We will only keep your personal information for as long as we require it for the purpose for which it was collected. However, we may also be required to keep some of your personal information for specified periods of time, for example under certain laws relating to companies, money laundering and financial reporting legislation. If we no longer require your personal information, and are not legally required to retain it, we will take reasonable steps to destroy or de-identify the personal information.

How to access and control your information?

1. Accessing the information we hold about you Under the APPs you may be able to obtain a copy of the personal information that we hold about you. To make a request to access this information please contact us in writing. We will require you to verify your identify and specify what information you wish to access. If eligible, we will grant you access to the information within 30 days. We may charge a fee to cover the costs of verifying your application, and retrieving, reviewing and copying any material requested.
2. Updating your personal information   We endeavour to ensure that the personal information we hold about you is accurate, complete and up-to-date. Please contact us at the details above if you believe that the information we hold about you requires correction or is out of date. We endeavour to process any request within 30 days and will provide written reasons if your request is rejected, as well as providing details for making a complaint about the refusal if necessary.

Complaints