Data privacy policy

EDAPT EDUCATION PRIVACY POLICY

Effective: March 2021

We are committed to protecting your privacy and respecting and upholding your rights in accordance with the Australian Privacy Principles (“APPs”) contained in the Privacy Act 1988 (Cth).
The APPs govern the way in which we collect, use, disclose, store, secure and dispose of your personal information.

This Privacy Policy explains how Edapt Education deals with your personal information and how to contact us if you have any queries about our management of your personal information.
We may change this Privacy Policy from time to time. If we make any changes, we will notify you by revising the “Effective” date at the top of this Policy and, where appropriate, we may provide you with additional notice such as sending an email notification.

If you disagree with any changes to this Privacy Policy, you will need to stop using Edapt Education’s products and services, and deactivate your account(s).

DEFINITIONS

Personal Information: Personal information is any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. Personal information in this instance refers to any students, staff or other individuals associated with your organisation.

Sensitive Information: is personal information that includes information or an opinion about an individual’s racial or ethnic origin, political opinions or associations, religious or philosophical belief, trade union membership or associations, sexual orientation or practices, criminal record, health or genetic information, or some aspects of biometric information. Generally, sensitive information has a higher level of privacy protection than other personal information.

Platform: online web portal that hosts our web-based solutions and dashboards.

Services: offerings to support the use of our Platform, including but not limited to, support, training, emails, blogs, and newsletters.

Cookies: small files that can be stored on and accessed from a user’s device when the user accesses a Platform. They enable authorised web servers to recognise you across different Platforms, services, devices and browsing sessions.

Web beacons: often used in combination with cookies, typically used to monitor the activity of users on a website for the purpose of web analytics and engagement metrics. Web beacons allow us to count users who have visited certain pages on our website and to generate statistics about how our site is used.

  1. What type of personal information do we collect and hold?

We will collect personal information directly from you or on your behalf. This information may include your name, email address, school name, school postal address, date of birth, and student
gender.

Collection is only to the extent necessary to provide our services requested or ordered by you and to carry out our administrative functions, included in our Terms of Use, or as required by the APPs. We may collect personal information that you have provided to third parties (for example, a Student Information System) and in respect of which you have expressly consented for such personal information to be shared with us.

We will not collect sensitive information (as defined under the APPs) from you. We ask that you do not send us, or do not disclose, any sensitive information (such as information related to racial or ethnic origin, religion or other beliefs, health, or criminal background) on or through the Platform or otherwise. If, contrary to this request, you do provide any sensitive information through the Platform, in doing so you consent to us collecting and handling that information in accordance with this Privacy Policy.

We require individuals to provide accurate, up to date and complete personal information at the time it is collected.

If you use a pseudonym when dealing with us or you do not provide identifiable information to us, we may not be able to provide you with any or all of our services as requested. If you wish to remain anonymous when you use our Platform, do not sign into it or provide any information that might identify you.

  2. How do we collect personal information?

Personal information may be collected by Edapt Education in a number of ways, including:

  • Accessing our Platform or Services when setting up, or logging into, a system account;
  • Downloading documents and/or resources from our Platform; or
  • Requesting a (i) Platform demonstration, or (ii) Platform trial through our website.

We use cookies, web beacons and similar technologies (collectively “Cookies”) on our Platform. By accessing or using our Platform, you agree that we can store and access Cookies in accordance with this Privacy Policy.

We may use Cookies to enable users to access and use our Platform and Services, including to:

  • identify users of our Platform and Services; process user requests
  • improve user experience;
  • remember user preferences on our website;
  • monitor the use of our website and for analysis of our user base;
  • facilitate communication with users;
  • control access to certain content on our website; and
  • protect our website.

The data collected through Cookies will not be kept for longer than is necessary to fulfil the purposes mentioned above.

We will handle any personal information collected by Cookies in the same way that we handle all other personal information.

You can delete and refuse to accept browser Cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of the Platform. Unless you have adjusted your browser setting so that it will refuse Cookies, our system will issue Cookies when you direct your browser to our Platform.

  3. How do we store and secure personal information?

We may hold your personal information in either electronic or hard copy. We take reasonable steps to protect your personal information from misuse, interference and loss, as well as unauthorised access, modification or disclosure and we use a number of physical, administrative, personnel and technical measures to protect your personal information.

Edapt Education takes reasonable steps to ensure the personal information we store is accurate, complete and up-to-date. We may periodically contact you for this purpose.

Edapt Educations hosts data within the Amazon Web Services facility based in Sydney, Australia. This centre is independently accredited as compliant with Australian Cyber Security Centre (ACSC) standards and IT security controls that reflect industry and global best practice. However, no system or facility is 100% secure due to continuous increases in the complexity, pace and scale of the cyber threat landscape. Therefore, the transmission of personal information over the internet does carry some risk of being breached, misused and accessed incorrectly. We recommend you always check whether or not Edapt Education’s Platform is encrypted using industry standard SSL before choosing to transfer your data (indicated with the URL prefix https://edapt.education; and/or the padlock icon showing at the start of the URL bar on your web browser).

When we no longer need your personal information for any of the purposes set out in this Privacy Policy, or as otherwise required by the APPs, we will take such steps as are reasonable in the
circumstances to destroy your personal information or to de-identify it.

If we learn a cyber security or data breach incident has occurred in our systems, Edapt Education have a documented Incident Response Management Plan in place, of which all our staff and contractors are well versed in its implementation. As part of this response plan, if our internally-led investigation into the cause of the incident identifies you as being impacted, Edapt Education will make direct contact with you via email so you may take your own protective and/or responsive steps.

  4. For what purpose do we collect, hold, use and disclosure personal information?

We use, process and disclose your personal information for the purposes for which the information is collected, or for a directly related purpose, including (but not limited to):

  • providing our Platform and Services to you;
  • administering, protecting, improving or optimising our Platform and Services (including performing data analytics, conducting research and for advertising and marketing purposes);
  • creating industry reports from de-identified data;
  • verifying your age;
  • informing you about our Platform, products, services, rewards, surveys, contests, or other promotional activities or events sponsored or managed by us or our business partners;
  • responding to any inquiries or comments that you submit to us;
  • verifying your identity;
  • any other purpose you have consented to; and
  • any use which is required or authorised by a relevant Privacy Law.

Where we:

  • have your express consent (which you may withdraw at any time by contacting us in writing at SUPPORT@EDAPT.EDUCATION);
  •  have a legal basis; or
  • are otherwise permitted by relevant Privacy Laws,

we may use and process your personal information to send you information about products and services we believe are suited to you and your interests. At any time, you may opt out of receiving direct marketing communications from us. Unless you opt out, your consent to receive direct marketing communications from us and to the handling of your personal information as detailed above will continue. You can opt out by following the unsubscribe instructions included in the relevant marketing communication, or by contacting us in writing at SUPPORT@EDAPT.EDUCATION.

We may utilise personal information to develop, test and improve the Services or develop new products or offerings. Furthermore, we may use such information for data analysis, conducting broad based research or for any ancillary purpose. Our preference will be to de-identify this information first, and then use it for this purpose.

  5. Who do we disclose personal information to?

We may disclose your personal information to:

  • third-parties we ordinarily engage from time to time to perform functions on our behalf in order to deliver the Services
  • any person or entity to whom you have expressly consented to us disclosing your personal information to;
  • our external business advisors, auditors, lawyers, insurers and financiers;
  • any relevant payment processing service provider; and
  • any person or entity to whom we are required or authorised to disclose your personal information to in accordance with the relevant Privacy Laws.

We may disclose your personal information to a third party located in or outside of Australia in order to provide our services to you and enable the Retailer to deliver products to you.

When entering into a transaction with us you expressly and freely consent to your personal information being disclosed or transferred to such third parties. We will take steps reasonably necessary to ensure your personal information is treated securely and in accordance with this Privacy Policy. We use reasonable endeavours to ensure that each third party receiving your personal information is bound by the relevant Privacy Laws.

  6. Can I access and correct my personal information?

If you believe that we hold personal information about you that is not accurate, complete or up-todate then you may request that your personal information be amended (SUPPORT@EDAPT.EDUCATION). We will respond to your request to correct your personal information within a reasonable timeframe. We may charge a reasonable fee that is not excessive to cover the charges of retrieving your personal information from our customer account database. We will not charge you for making the request.

On some exceptions provided by the relevant APPs, your request to access to your personal information in our customer account database, or seek correction of it, may be declined. Should we decline you access to your personal information, we will provide a written explanation setting out our reasons for doing so.

  7. How do I make a compliant about privacy?

If you require further information regarding our Privacy Policy or wish to make a privacy complaint, please contact us in writing at SUPPORT@EDAPT.EDUCATION.

We will cooperate with appropriate regulatory authorities, including federal or state data protection authorities, to resolve any complaints regarding the handling of personal information that cannot be resolved between us and the individual.

 

 

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