- explain what personal information we collect;
- only collect personal information that we need in order to operate our Site, provide our Services and properly undertake our business;
- be open and honest about how we might use personal information;
- confirm if we need to disclose personal information to anyone else (including anyone overseas) and if so, in what circumstances this might occur;
- keep personal information secure;
- explain how to exercise choices and manage personal information;
- promptly respond to any request not to receive direct marketing material from us;
- make sure personal information is kept accurate and up to date and to properly dispose of any personal information which is no longer required by us; and
- ensure that, where appropriate, individuals can access and correct their personal information.
This policy is intended to explain clearly and in plain language some of the key processes and procedures that we have implemented to manage personal information, to protect the privacy of individuals and to comply with applicable data protection and privacy laws. It has been prepared with reference to the requirements of the General Data Protection Regulation ("GDPR") of the European Union.
References to "our", "us" and "we" in this policy are references to Studiosity. “End-User” means a person who uses the Studiosity service (“Service”).
This policy explains how we collect personal information, what we do with it and what controls you have in relation to your personal information but if you require further information, you are welcome to contact us.
We will only collect information that is necessary and relevant to the proper undertaking of our business. Where you are a student, we collect information from your academic institution in order that we can authenticate your access to the Service as well as information you give us when you sign-in to use the Service and information from your use of the Service.
The types of personal information we collect may include name, email address (including institution email and a personal email if provided), mobile phone number, year of study, date of birth, postcode, student status, entity/institution name, type of entity/institution, details of sporting and other extra-curricular commitments (if required to assist with scheduling) and details arising from the use of the Service, (such as transcripts of chat dialogues with subject specialists) and information and papers submitted for review and feedback.
We may also collect additional information from End-Users including feedback in order to improve our services and performance.
Certain information is collected automatically from the use of the Site or Service. This may include information about the device being used to access the Site or Service, the country of the End-User from a check against the Internet Protocol (IP) address, and technical information such as the browser type and when, how often and for how long the Site or Service is used.
We also use a mix of tools such as cookies, id's, web beacons and similar technology (collectively described in this policy as 'cookies') to collect information about the access to and use of the Site and Service. These typically involve a unique reference code that relates to, or is accessed from, an End-User's device. For more information see the 'Cookies' section.
The level of information we collect will depend on the exact nature of the services that we are providing and what information is reasonably required to provide those services.
There are various reasons why we might need to collect, hold, use or disclose personal information and this will depend upon the specific service that we are providing.
Usually, the main reasons that we will need to collect End-Users’ personal information will be to authenticate access and provide our Services. Our main Services relate to the provision of individualised, one-to-one tuition to students in circumstances where these students are the end users ("End Users") of our commercial clients, (being tertiary institutions). Our tuition services will include assisting students with homework/study, assignment research, study skills, revision and exam preparation by providing students with a forum with our subject specialists for discussion, feedback and responses in respect of study queries and other aspects of their study. Our services are primarily delivered through the Internet.
We may also use personal information for other reasons, including:
- to assist us to run our business, including:
- setting up our services, understanding the year level of students, understanding the progress of, and services required by students, staff scheduling, staff training, accounting, risk management, record keeping, archiving and systems development,
- to analyse and improve our services and performance developing new services and products (if applicable), undertaking planning, research and statistical analysis (for example, to ascertain the aggregate number of users in a geographical area);
- to provide customer and technical support;
- to communicate with clients and End-Users by way of service updates or notifications relating to End-User accounts or responding to a specific query raised with us;
- to send marketing communications, where permitted by law;
- to prevent fraud and other criminal activities; and
- to comply with our legal obligations.
There is no obligation to provide personal information for use by us but if you do not provide us with the personal information that we require, we may not be able to provide the information or services that you require.How do we collect personal information?
The means by which we collect personal information will depend on the nature of the service being provided.
We may collect personal information:
- directly from the End-Users including when accessing the Service via a third-party institution's software platform;
- as a result of direct access and interaction with the Site or Service (including audio recordings and transcripts of calls with End Users);
- from our educational institution clients who make the Service available to their individual clients or students (i.e. the End User) and who may, with agreement, of End User's, share personal information to us in order that we can authenticate access to the Service, for use in our business and to provide our services; or
- from publicly available sources, for example, the electoral role, the telephone directory ;or
- from other websites or services including where you choose to synch or upload information and content of third party websites and services through our software APIs and tools, (such as in the course of authentication when you login in through a Facebook or other account). Where you connect a third party account with the Site or Service we may receive information about you provided by the third party service you are using.
We will collect personal information directly from the relevant individual wherever possible.
Where we are collecting personal information, we will remind you of this policy at the time of collecting that personal information and as part of our communications with you.Cookies
A cookie is a small file or other unique code ("UDID") that is either sent to your browser from a web server to be stored on your computer, device and browser or is associated with or assigned to your device and enables the computer or device to be remembered when interacting with the Site and Service or when you return.
- Some Cookies are essential to the Site and Service in order to enable our log-in process and let you to move around it and to use its features. Without these Cookies, we may not be able to provide certain services or features, and the Site or Service will not perform as smoothly for you as we would like.
- We may use analytics Cookies, to collect information about your use of the Site and Service and enable us to improve the way each works.
- Analytics Cookies collect information about how you use the Site or Service, for instance, which pages you go to most. The information allows us to see the overall patterns of usage and help us record any difficulties you have with the Site or Service.
- We use Analytics providers to understand what features are popular. The information generated by the cookie about your use of the Site and Service may be transmitted to and stored by these providers on servers in the United States. This information is used for the purpose of measuring your activity on our Site and Service including the effectiveness of our communications, compiling statistical reports on activity for us and providing other services relating to activity and internet usage. You can prevent the collection of the data generated by cookies or similar tracking tools used by our Analytic providers, as well as the processing of this data, by opting out of or blocking these tools which may involve downloading and installing a browser plug-in. Further details on how to opt-out of analytic tracking is available below from the following links:
- Our Site and Service has implemented Social plugins enabling visitors and End-Users to share content of interest on with friends and connections.
- Our Site and Service contains social plugins to external social networking sites such as facebook.com ("Facebook"), twitter.com ("Twitter"), instagram.com ("Instagram"), pinterest.com ("Pinterest"), youtube.com ("Youtube") and linkedin.com ("Linkedin"). If you are a member of one of these social networking sites and you are logged-in while you are visiting our Site or Service, the relevant social network may assign information to your personal user account. By interaction with one of those plug-ins, e.g. by clicking the 'like' or equivalent interaction button, this information will be sent via your browser directly to the relevant social networking site where it will be stored on your personal user account. The information that you visited our Site or Service may be sent to the social network provider regardless of whether you click on one of the plug-ins. Please read the privacy and cookie policies of your social networking provider for further information about their collection and use of data and your rights and options to further protect your privacy.
- Our Site also uses the Google AdWords Remarketing service, which advertises across the Internet to previous visitors to our Website. Google AdWords Remarketing displays relevant advertising content based on which sections of The Website you have visited. Google AdWords Remarketing allows us to tailor our advertising and marketing content so it is relevant and suits your needs.
Information derived from these Cookies may be combined with other information you provide when signing up to use any element of our services including, but not limited to, joining an email list or signing up to the Site service. We do this only for the purpose of analysing data in order to improve the Site services.
Most computer and some mobile web browsers automatically accept cookies but, if you prefer, you can change your browser to prevent that or to notify you each time a cookie is set. You can also learn more about cookies by visiting www.allaboutcookies.org which includes additional useful information on cookies and how to block cookies using different types of browser. Please note however, that by blocking or deleting cookies you may not be able to take full advantage of the Site or Service (as the case may be).
If you do not wish to be a part of our Google AdWords Remarketing, you can opt out by visiting Google Ads Preference Manager by clicking here; then go to the “opt-out settings” where you can opt out of all interest-based ads on Google and across the web. You can also opt out of processing of analytics data by Google, by downloading and installing the browser plug-in available from Google - http://tools.google.com/dlpage/gaoptout.
Other direct analytic opt-out tools provided by our suppliers include that provided by Kissmetrics - https://www.kissmetrics.com/privacy/#controls
You can also find more information about analytics, advertising and retargeting by visiting www.youronlinechoices.com and where you can manage your choices to turn off tracking from providers signed up to this programme.How do we use personal information?
We may use personal information for the purposes for which it was collected or for a related purpose such as:
- to set up and activate End User accounts with Studiosity;
- to consider a request for a service or product;
- to enable us to provide a service or product;
- to coordinate the setup and activation of the Services;
- to facilitate, process and respond to the educational or study queries of students;
- to facilitate online chat and assistance to students;
- to carry out or respond to other queries or requests of students;
- to respond to enquiries or requests;
- to facilitate and process payments for our Services;
- to perform administrative and operational tasks (including risk management systems development and testing, staff scheduling, staff training and collecting debts);
- to seek feedback in relation to client satisfaction;
- to monitor or improve the quality and standard of services that we provide;
- to consider any concerns or complaints made against us;
- to ensure the safety of you or your customers (for example, if we believe the personal safety of a student or any other person is at risk and it is a reasonable action to take to protect that student or person from possible injury);
- to assist us in providing and improving our Services, to analyse general usage of our Services and industry trends and develop, improve and market our Services and products; and
- for regulatory reporting and compliance with our legal obligations;
- we may use anonymised student quotes about Studiosity (or case studies) to explain our service to prospective partners;
We deal with third party service providers who may assist us with a variety of functions including with marketing, research, mail and delivery, security, insurance, professional advisory (including legal, accounting and auditing advice), banking, payment processing, credit reporting or technology services. Where we engage third party service providers to perform services for us, those third parties may be required to handle personal information. Under these circumstances, those third parties must only use the personal information where necessary to perform their functions and subject to security measures.
We will limit personal information provided to independent third parties to that information required for those third parties to properly perform their functions. Further, our contracts with these third parties will always require the third parties to comply with the applicable data protection and privacy law.
We may disclose personal information to various regulatory bodies, law enforcement officials and agencies, to protect against fraud, criminal activity and related security purposes.
Studiosity will also share information regarding the usage of its Services by its End Users with its commercial clients by way of a monthly report. Where commercial clients (such as universities, schools etc.) have purchased a licence to use our Services, those commercial clients will have access to, and knowledge of the usage patterns of their students. Such usage patterns will include the content of student learning sessions and any comments left in post-session surveys. We may also share transcripts and audio recordings with our commercial clients for the purpose of quality control of our services.
Other than the above, we will not disclose personal information without consent unless disclosure is either necessary to prevent a threat to life or health, authorised or required by law, reasonably necessary to enforce the law or necessary to investigate a suspected unlawful activity.Do we use personal information for marketing purposes?
As part of the services that we provide, we may:
- use personal information that we have collected to identify a Studiosity product or service that may benefit a particular person or group of people;
- contact individuals from time to time, provided they have consented to be contacted for these purposes, to let them know about a Studiosity product or service that we believe might be of interest to them.
Individuals can opt-out, unsubscribe or make a request not to receive marketing communications from us at the point of collection or at any other time, by writing to us by email at email@example.com.
Additionally, each marketing communication, including all emails and SMS, will include an opt-out or "unsubscribe" option which will immediately indicate to us that the person opting-out or unsubscribing no longer wishes to receive materials of this kind. If a request is made not to receive marketing communications from us, we will stop sending these materials.
We do not use personal information for public relations purposes without prior consent.How do we store and protect personal information?
We have implemented appropriate processes and techniques (including physical security such as locks and security systems and computer and network security, including firewalls and passwords) to protect personal information from loss, misuse and interference and from unauthorised access, modification or disclosure. In addition, access to personal information is limited to those who specifically need it to conduct their responsibilities.
We and our third party service providers take all necessary steps to destroy or permanently de-identify personal information where it is no longer required and to protect personal information from loss, misuse and interference and from unauthorised access, modification or disclosure.
While care is taken to protect personal information, unfortunately no data transmission over the Internet is guaranteed as 100% secure and no computer system is completely without risk of penetration by unauthorised persons, or other unauthorised access. Accordingly, we cannot ensure or warrant the security of any information sent to us or received from us online. This is particularly true for information sent to us via email as we have no way of protecting that information until it reaches us. Once we receive personal information, we are required to protect it in accordance with applicable law.Maintaining personal information
We take reasonable steps to ensure that:
- the personal information that we collect is accurate, complete and up-to-date at the time of collection;
- when we use personal information, it is accurate, up-to-date, complete and accurate at the time of use; and
- if we disclose personal information, it is accurate, up-to-date, complete and accurate at the time of disclosure.
Studiosity is headquartered in Australia and uses data processing and hosting facilities located on servers outside of Europe. Personal information may also be transferred to and/or processed in other countries outside of Europe for the purposes described in this policy where our service providers maintain operations. Where personal information is transferred in relation to providing the Site or Services we will take steps to implement appropriate legal mechanisms relevant to the transfer.How can personal information be accessed?
We will seek to be able to provide access to personal information upon receipt of a written request. Such a request can be emailed to firstname.lastname@example.org or can be sent by post to Studiosity, Level 1, 11 Chandos Street, St Leonards NSW 2065 Australia, together with confirmation of the person's identity.
Where a request is made for access to personal information, we will respond within the statutory permitted timeframe after the request is made.How can you seek to correct personal information?
We do what we can to ensure that the personal information we hold is accurate, complete, up-to-date, relevant and not misleading. To assist us to do this, please ensure that you provide us with correct information at the time you provide it to us and immediately inform us if any details change at any time. If we are concerned that any personal information is inaccurate, incomplete, out-of-date, irrelevant or misleading, or if a request is made that we correct any personal information, then we will take all reasonable steps to correct the information to ensure that it is accurate, complete, up-to-date, relevant and not misleading in the context of the purpose for which it is held.
If we correct any personal information and that information has previously been disclosed to another entity then, upon receipt of a request to do so, we will take reasonable steps to notify that other entity of the correction unless such notification is impracticable or unlawful.What if you want to make a complaint about some aspect of our privacy procedures?
We are committed to maintaining and protecting the privacy of individuals but it is possible that in limited circumstances, mistakes might be made. If you are concerned with the way that personal information has been handled then you are entitled to make a complaint. If you would like to lodge a complaint, please contact us through our Privacy Compliance Officer, whose details are set out below.
Privacy Compliance Officer
Level 1, 11 Chandos Street,
St Leonards NSW 2065
Telephone: +61 2 9906 2700
If personal information has not been handled in an appropriate way, we will do our best to remedy your concerns as quickly as possible, including by acknowledging receipt of your complaint within 48 hours and trying to resolve the complaint. Where this is not possible, we will contact you within this period to let you know an anticipated time frame within which your complaint will be resolved.
If your complaint is not satisfactorily resolved, you may approach your local data protection authority, approach an external dispute resolution service or apply to the Office of the Australian Information Commissioner ("OAIC")( https://www.oaic.gov.au/ ) to have the complaint heard and determined.How can you seek to remove personal information?
We store data for as long as it is necessary to provide our services and products to you. Your account information will be kept until we no longer need the data to provide our services and products. You can request removal of your personal information at any time by contacting our Privacy Compliance Officer at the details listed above.Protecting identity
Wherever it is practicable, we will always provide an individual with the option not to identify themselves when dealing with us. Alternatively, an individual may elect to use a pseudonym to protect their identity.Links to other websites
Studiosity websites may contain links to websites that are owned or operated by other parties. You should make your own enquiries as to the privacy and cookie policies of these parties. We are not responsible for information on, or the privacy practices of, such websites.Changes to this policy
Please find below our contact details. Please do not hesitate to contact us in relation to any privacy-related concerns and we will use our best endeavours to address any such concerns thoroughly and in a timely manner.
If it is practical to do so, you can contact us without identifying yourself. However, if you choose not to identify yourself, it may be more difficult for us to assist you with your enquiry. This will depend on the nature of your enquiry.
Level 1, 11 Chandos Street,
St Leonards NSW 2065
Telephone: +61 2 9906 2700