1. INTRODUCTION
This document sets out the privacy policy of Cyber Safety Project Pty Ltd ACN 623 529 680 (referred to in this privacy policy as ‘we’, ‘us’, or ‘our’).
This privacy policy applies whenever we collect your personal information (or personal data). This includes between you, the visitor to this platform (whether directly as our customer or as personnel of our customer), and us, the owner and provider of this platform and also where we are directed by a third party to process your personal information. This privacy policy applies to our use of any and all data collected by us or provided by you in relation to your use of the website and the provision of our services to you.
We take our privacy obligations seriously and we’ve created this privacy policy to explain how we collect and treat your personal information. Personal information is that information which is identifiable as being about you.
2. LAWS AND STANDARDS WE COMPLY WITH
We comply with:
- the Australian Privacy Principles established by the Privacy Act 1988 (Cth); and
(to the extent the European Union’s General Data Protection Regulation 2016/679 (‘GDPR‘) applies to us and our use of your information, the GDPR.
3. TYPES OF PERSONAL INFORMATION WE COLLECT AND HOLD
The personal information we collect may include the following:
- name;
- email address;
- educational institution
- information in connection with client surveys, questionnaires and promotions;
- your device identity and type, I.P. address, page view statistics, and standard web log information.
4. SUBPROCESSORS
Subprocessors are third-party entities engaged by Cyber Safety Project to assist in providing our services. Subprocessors we use are not authorised to access or process your personal data. You authorise us to use subprocessors as laid out in our Terms and Conditions.
The Cyber safety Project uses the following subprocessors:
- Login with Google (Google Inc – https://google.com), used for single sign on, Subprocessor data may be processed or stored internationally. Google may process your email address.
- Login with Microsoft (Microsoft Inc – https://microsoft.com), single signon. Subprocessor data may be processed or stored internationally. Microsoft may process your email address.
5. HOW WE COLLECT, HOLD AND STORE PERSONAL INFORMATION
We endeavour to ensure that information we collect is complete, accurate, accessible and not subject to unauthorised access.
We may collect personal information either directly from you, or from third parties, including where you:
- contact us through our website;
- communicate with us via email, telephone, SMS, social applications (such as LinkedIn, Meta or ‘X’) or otherwise;
- interact with our website, social applications, services, content and advertising
We may hold user data for a period of up to 18 months after a users last activity/login on the platform. We remove inactive user’s Educator Hub platform data on an annual cycle.
We store user personal information within secure data centres located in Australia. Our Educator Hub is hosted and run on AWS infrastructure in Sydney, Australia. All data is password-protected and encrypted where appropriate.
6. PURPOSE FOR COLLECTING PERSONAL INFORMATION
We collect, use and disclose your personal information for a wide variety of reasons but only to the extent that we need to in order to operate our platforms and provide you with services, or where required or permitted by law.
We will not use or disclose personal information for any secondary purpose, unless that secondary purpose is related to the primary purpose for which we have collected that information, and you would reasonably expect the disclosure in the circumstances, or unless you consent to that use or disclosure.
The purposes for which we collect, hold, use and disclose information may include:
- to conduct our business, which includes providing our products and services;
- where you have consented, if such consent is required by law, to:
- communicate information about our products and services or third-party products and services that may be of interest to you; and
- marketing communications we believe may be of interest to you, including for example our research updates relating to teacher professional development and other learning services;
- to respond to your queries, comments, or support requests;
- to seek feedback, improve and optimise our products and services;
- for our internal administrative, planning, marketing and product development purposes;
- to comply with our legal obligations;
- if there is a change of control in our business or a sale or transfer of business assets, we reserve the right to transfer to the extent permissible at law our user databases, together with any personal information and non-personal information contained in those databases.
7. COOKIES AND TRACKING TECHNOLOGIES
We may collect and store cookies for the following purposes;
- Login tokens to authorise you as a user
- Course and lesson progression information
- User notifications
- Tracking page and site views, and the way you interact with the platform.
8. ACCESS AND CORRECTIONS
You have the right to access and correct your own personal information.
If you believe personal information that we hold about you is not up to date or accurate, you may ask us to correct it. You may also request details of information that we hold about you (in accordance with the provisions of the Privacy Act 1988 (Cth)).
Educational institutions may also request to access, review, correct or delete data we have collected from users. We take reasonable steps to confirm that a requesting party has authority to access, review, or correct data and to verify the requesting party’s identity before granting access to any requested personal information.
We will respond to all requests and attempt to provide you with the requested data, free of charge, within 60 days of receipt of your request. Please direct all requests to [email protected]
9. KEEPING YOUR DATA SECURE
We are committed to ensuring that the personal information you provide to us is secure. We have implemented physical, electronic and managerial procedures to safeguard and secure information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.
We have active protections in place to limit and log unauthorised usage, and may block users/IP’s who abuse the platform.
10. INTERNATIONAL DATA TRANSFERS
The Educator Hub does not store or transmit any personal information to servers/sites located outside of Australia. The Educator Hub may receive personal information from services such as Microsoft and Google for the Single Sign-On (SSO) feature which may be located internationally. However, all personal information received will be processed by the Educator Hub in Australia, in accordance with Australian Laws.
11. COMPLAINTS ABOUT PRIVACY
If you have any complaints about our privacy practices, please feel free to send in details of your complaints to [email protected]. We take complaints very seriously and will respond promptly. If you do not consider our response satisfactory, you may contact the Australian Privacy Commissioner at its website www.oaic.gov.au or by telephone on 1300 363 992.