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Pivot Professional Learning Privacy Policy

Last updated: 17 January 2022

In the course of carrying out our activities, Pivot Professional Learning Pty Ltd (ACN 601 883 372) (we, us or our), and our subsidiaries and related bodies corporate, will collect, store, use and disclose personal information. We are committed to the protection of your personal information and to compliance with applicable privacy laws.

Your privacy is important to us. This policy sets out how we protect your personal information.

Personal information

Summary: Any information that can lead to someone identifying you or inferring that the information is about you is personal information.

Personal information and/or personal data (the terms commonly used in applicable privacy laws), is information or an opinion about an identified or reasonably identifiable individual, whether or not the information or opinion is true and whether or not the information is recorded in a material form.

Types of personal information we collect and hold

Summary: We collect different types of personal and sensitive information which will depend on your interaction with us, the below sets out the types of information we might collect. We’ll ask for your permission before we collect your information if required by law. If you’re under 15 or if we think it’s best, we’ll need your parent or guardian to give us permission to collect your information.

We collect and hold personal information about individuals for the provision of our products and services (including our website(s), other platforms and tools as applicable) (our products and services) and purposes connected to those products and services.

Consistent with the provision of our products and services, the types of personal information we may collect and hold include the following.

  1. Identity and contact details – including individuals’ first and last name, email address, job title, school, class, year group, student ID, age, and other identifying and contact information.

  2. Payment information – including any personal information associated with any payment information provided.

  3. Other information – text of written and oral communications gathered in the course of our interaction with you, including other information from your interactions with us online, such as any feedback you provide us, when you communicate with our customer support or as part of delivering additional services in schools such as coaching or training, cookie information, IP address, URL’s, search histories and other associated information.

  4. Sensitive information – including any physical or mental health conditions or information, other health information, racial or ethnic origin, religious beliefs or sexual orientation. You consent to us collecting sensitive information which you provide to us voluntarily. If we need to collect any sensitive information for a specific purpose, we will ask for your consent. To the extent we collect sensitive information from a child under 15 or from a child older than 15, who in our reasonable opinion does not have the capacity to provide informed consent, we require the child’s school to seek the consent of their parent or guardian on their behalf.

If you don’t provide us with personal or sensitive information, we are unlikely to be able to provide you with our products and services.

How we collect and hold personal information

Summary: This section explains how we collect the information from you.

We may collect personal information directly from you, whether you are a student, a parent, legal guardian and/or teacher (or other education representative), or where you have given a third party permission to disclose your personal information to us (or where that third party is permitted by law to disclose such information).

We may collect personal information while providing our products and services to you, from our website, mobile applications and other online platforms, including where you participate in surveys or feedback processes, communicate with us and our customer support teams, or we engage with you outside of our platform (for example, if we provide you with coaching or training services).

Purposes for which we hold, use and disclose personal information

Summary: 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. For example, we can disclose your personal information if we’re worried about your health or safety.

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:

  1. to conduct our business, which includes providing our products and services;

  2. where you have consented, if such consent is required by law, to:

    1. communicate information about our products and services or third party products and services that may be of interest to you; and

    2. provide you with information or advertising relating to our products or services (including serving and targeting advertisements) or marketing communications we believe may be of interest to you, including for example our research updates
      relating to teacher professional development;

  3. to respond to your queries, comments, or support requests;

  4. to improve and optimise our products and services;

  5. for our internal administrative, planning, marketing and product development purposes;

  6. for research purposes including to identify teachers with specific traits or results, whom we may then approach as a potential candidate for qualitative research;

  7. to comply with our legal obligations;

  8. where an individual triggers a distress protocol within our platforms (and such disclosure may involve allowing another individual to monitor their wellbeing);

  9. where a situation requires us to do so in order to lessen or prevent a threat to the life, health or safety of any individual; and/or

  10. 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
    (this information may be disclosed to a potential purchaser under an agreement to maintain confidentiality and we would seek to only disclose information in good faith and where required by any of the above circumstances).

If you are a student, we may disclose your personal information to your parent or guardian, school or teacher. If you are a teacher, we may disclose your personal information to your employer. We may also disclose personal information to our third party partners and organisations, third party technology and marketing partners and other third party service providers, including for example, our customer relationship management provider for purposes in connection with the provision of our products and services

Security of your personal information

Summary: Because we care about protecting your personal information, we have implemented a number of industry standard security measures to keep it safe.

We are committed to ensuring that the personal information you provide to us is secure. We have put in place suitable physical, electronic and managerial procedures to safeguard and secure information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.

For example, all personal information is archived on regularly backed-up, secure data centres located in Australia. All data is password-protected and encrypted where appropriate.

Access and corrections

Summary: You have the right to access and correct your own personal information. If you’re a student, your school can also request to access and correct your personal information but we’ll do our best to make sure they are who they say they are before giving them your information. If you, your parent or guardian wants to access or correct your information, the request will first need to be made through your school, which will then be forwarded on to us.

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 a student. 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.

To the extent you are a student or parent/guardian, any request to access, review, correct or delete personal information will first need to be made through your/or your child’s school. The school must then forward the request to us. We take this approach in the interest of children’s privacy and security, as only the school is in a position to verify your identity and confirm you are authorised to make the request.

We will respond to all requests and attempt to provide you with the requested data within 30 days of receipt of your request. If you are a student or parent/guardian and have made a request through a school, we will provide the requested information directly to you unless you have specified otherwise.

Please direct all requests to privacy@pivotpl.com.

Complaints about privacy

Summary: Feel free to contact us if you have a privacy complaint. We’ll do our best to resolve your complaint.

If you have any complaints about our privacy practices, please feel free to send in details of your complaints to privacy@pivotpl.com. 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.

Changes to this Privacy Policy

Summary: We’ll let you know if we make major changes to this policy.

We will review and update this privacy policy from time to time as needed without notice. Therefore, you should review the terms of this policy periodically to make sure that you are aware of how we collect, hold, store and use personal information. However, if we make material changes we will notify you using a method determined by us. The date this policy was last updated will be set out at the start of the policy.

Contacting us

Summary: Any questions? Get in touch! We’re always happy to answer any questions you may have.

If you have any questions about this policy and would like further information, please contact us at privacy@pivotpl.com.

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