Privacy Policy - Scootle

What is Personal Information?

"Personal Information" is information or an opinion, whether true or not, and whether recorded in a material form or not, about an identified individual or an individual who is reasonably identifiable.

What Personal Information does ESA collect?

The type of Personal Information ESA collects depends on our interaction with you but may include:

• contact information, such as your name and email address;
• school name, teaching year levels, teaching learning areas;
• location information such as your postcode and country;
• information from your social media accounts and profiles;
• information required to register a Scootle account including if you sign up via Single Sign On; and
• your username and password for the Scootle website.

How does ESA collect your Personal Information?

ESA may collect your Personal Information in certain circumstances, including when you:

• register on the Scootle website;
• browse, make an enquiry or otherwise interact with the Scootle website;
• provide feedback to us;
• visit a premises from which we operate;
• otherwise contact us by telephone, email, social media, post or in person; or
• where we are otherwise required or authorised by law to do so.

Sometimes ESA collects your Personal Information from a third party. For example, ESA may collect your Personal Information from a relevant jurisdiction in order to enable Single Sign On.

Third-party Personal Information provided to us

If you provide Personal Information to us about someone else you must ensure that you are entitled to disclose that Personal Information to us and that, without us taking any further steps, we may collect, use and disclose that Personal Information as described in this Privacy Policy. In particular, you must ensure that the individual concerned is aware of and acknowledges this Privacy Policy and our collection statement.

Remaining anonymous or using a pseudonym: are you required to provide Personal Information?

Where it is not impractical or unlawful, you may interact with ESA using a pseudonym or without identifying yourself. As a general principle, you provide ESA with your Personal Information voluntarily and there are generally no detrimental effects for you if you choose not to consent or not to provide Personal Information. However, there are circumstances in which ESA cannot take action without certain Personal Information. For example, Personal Information may be required to provide you with access to specific web offerings, newsletters or Single Sign On. In these cases, it will not be possible for ESA to provide you with what you request without the relevant Personal Information and ESA will notify you accordingly.

Information collected via our Website

Personal Information may be collected by us and by our third-party service providers who assist us in operating our website at scootle.edu.au (the Website).

We may use various technological methods from time to time to track the visiting patterns of individuals accessing our Website, including but not limited to the methods set out in this paragraph 6.

Click Stream Data

When you read, browse or download information from our Website, we or our internet service provider may also collect information such as the date, time and duration of a visit, the pages accessed, the IP address of your computer, and any information downloaded. This information may be used for purposes including statistical reporting and website administration, maintenance and improvement purposes.

Cookies

Our Website may use 'cookies' from time to time. Cookies are small text files that are transferred to a user's computer hard drive by a website for the purpose of storing information about a user's identity, browser type or website visiting patterns. Cookies may be used on our Website to monitor web traffic, for example the time of visit, pages visited and some system information about the type of computer being used. We use this information to enhance the content and services offered on our Website.

Cookies are sometimes also used to collect information about what pages you visit and the type of software you are using. If you access our Website or click-through to our Website from a link in an email we send you, a cookie may be downloaded onto your computer's hard drive.

Cookies may also be used for other purposes on our Website.

Google Analytics

We use Google Analytics to help analyse how you use our Website. Google Analytics generates statistical and other information about website use by means of cookies, which are stored on users' computers. The information generated is used to create reports about the use of our Website. Google stores this information.

If you do not want your Website visit data reported by Google Analytics, you can install the Google Analytics opt-out browser add-on. For more details on installing and uninstalling the add-on, please visit the Google Analytics opt-out page at https://tools.google.com/dlpage/gaoptout.

Social Media Platforms

Some of the content on our Website may include tools, applications, images or other functionality (tools) made available by third parties, such as third-party social media platforms. These tools allow those third parties to follow the actions of their users after they are directed to a website (like our website) when clicking on links such as advertising posted by third-party platforms. This data remains anonymous to us, but may be identifiable to, and may be saved and processed by, those third parties. Those third parties may connect your data with your account on their platforms and use and disclose it for their own purposes, including advertising. For more information, please visit the Privacy Policies of the respective social media and other digital platforms that you use. You can generally revoke permissions for the use of your personal information through your account on those platforms.

Use of your Personal Information

We use the Personal Information we collect about you for Scootle's functions and activities, in order to operate Scootle efficiently and to market our products and services.

We may collect, hold and use your Personal Information:

• to identify and communicate with you;
• to facilitate and support the functions and activities of our internal business units and related entities;
• to provide services or things you may have requested, for example access to content on the Scootle website, provide access to Single Sign On or for the purpose of you entering a competition;
• for compliance with ESA's legal obligations (such as record keeping obligations);
• to analyse and improve ESA's services and communications to you;
• to protect the security of and manage access to ESA's premises, IT and communication systems, online platforms, websites and other systems;
• to prevent and detect security threats, fraud or other criminal or malicious activities;
• for insurance purposes;
• for monitoring and assessing compliance with ESA's policies and standards;
• to identify persons authorised to trade on behalf of ESA's clients, customers, suppliers and/or service providers;
• to comply with ESA's legal and regulatory obligations and requests anywhere in the world, including reporting to and/or being audited by national and international regulatory bodies;
• to comply with court orders and exercise and/or defend ESA's legal rights;
• to communicate with you through the channels you have approved to keep you up to date (including newsletters and emails);
• to provide you with information about customer surveys, marketing campaigns, market analysis, contests or other promotional activities or events;
• to collect information about your preferences to personalise and foster the quality of ESA's communication and interaction with you (for example by way of newsletter tracking or website analytics); and
• for any purpose related and/or ancillary to any of the above or any other purpose for which your Personal Information was provided to ESA.

We may aggregate Personal Information for reporting, statistical and analysis purposes, and for business, product and service improvement purposes. This allows us to better inform ourselves and anticipate our customers' preferences and requirements, and to monitor and improve the effectiveness of our business, products and services. We may also de-identify information for inclusion in such aggregated databases or reports.

We reserve the right at all times to monitor, review, retain, and/or disclose any information as necessary to satisfy any applicable law, but we have no obligation to monitor the use of the Website or to retain the content of any user session.

You consent to us using your Personal Information in the above ways and as set out in this Privacy Policy.

We may otherwise collect, use or disclose your Personal Information where the collection, use or disclosure is:

(a) in accordance with this Privacy Policy or any agreement you enter into with us; or

(b) required or authorised by law, including without limitation the Australian Privacy Principles under the Privacy Act 1988 (Cth).

Disclosure of your Personal Information

We may disclose, or provide access to, your Personal Information to third parties in connection with the purposes described in paragraph 8. Depending on the circumstances and the nature of your engagement with us, we may disclose your Personal Information to our related entities, to third parties that provide products and services to us or through us, or to other third parties.

We may also disclose your Personal Information to:

• your nominated representatives;
• ESA's related entities, internal divisions, business units or departments;
• other organisations who assist us in providing products and services to you;
• professional service providers and advisors who perform functions on our behalf, such as lawyers;
• to the Australian education authorities for data matching and Single Sign on;
• representatives, agents or contractors who are appointed by us in the ordinary operation of our business to assist us in providing goods or services or administering our business (such as for data storage or processing, printing, mailing, marketing, planning and product or service development); and
• Government, regulatory authorities and other organisations as required or authorised by law

We may also disclose your Personal Information to our Website host in certain limited circumstances, for example when our Website experiences a technical problem or to ensure that it operates in an effective and secure manner.

1. 8.1 Publication of your Personal Information

   ESA will only publish Personal Information on the Scootle website if it has been collected for this purpose, with your knowledge, or if you have otherwise consented to the disclosure. When giving consent you should be aware that Personal Information published on the Scootle website may be accessible to web users from all over the world.

   Please note that if you post or comment on a social media platform, for example the Scootle Facebook page, the relevant social media platform Privacy Policy will apply to your Personal Information.

2. 8.2 Interstate disclosures

   Some of your Personal Information may be disclosed, transferred, stored, processed or used overseas by us, or by third-party service providers. This may happen if:

   • our offices or related entities are overseas;
   • we outsource certain activities overseas;
   • transactions, information, services or products have an overseas connection; or
   • our computer systems, including IT servers, are located overseas.

   You consent to the collection, use, storage, and processing of your Personal Information outside of Australia as set out in this Privacy Policy.

Other uses and disclosures

We may collect, use and disclose your Personal Information for other purposes not listed in this Privacy Policy. If we do so, we will make it known to you at the time we collect or use your Personal Information.

Marketing

You consent to us using your Personal Information for sending you information, including promotional material and surveys about us or our products and services, as well as the products and services of our related entities , now and in the future. You also consent to us sending you such information by means of direct mail, email, SMS and MMS messages.

If you do not want to receive marketing information from us, you can unsubscribe in any of the following ways:

(a) clicking on the 'Unsubscribe' or subscription preferences link in a direct marketing email that you have received from us; or

(b) contacting us using the contact details specified in paragraph 14.

Accessing, correcting and deleting Personal Information

ESA endeavours to ensure that the Personal Information that it holds is accurate, up-to-date, complete and relevant. If you want to know what, if any, Personal Information ESA holds about you, or wish to correct any Personal Information ESA may hold about you, you may access this information by contacting ESA using the contact information specified in paragraph 14.

ESA may allow access to, make your requested changes to or delete your Personal Information unless otherwise required or permitted by law. ESA will notify you of the basis for any denial of access to your Personal Information.

When Personal Information is no longer required, ESA takes reasonable steps to de-identify, securely destroy or delete such Personal Information

Security of your Personal Information

ESA takes reasonable steps to protect the Personal Information that it holds against misuse, interference, loss, unauthorised access, modification or disclosure by utilising up-to-date electronic and physical security controls that comply with relevant industry standards and guidelines.

If you do not wish to use the internet to transmit personal information you can mail or telephone ESA using the contact information specified in paragraph 14.

Please note that if you use a link to a non-Scootle web page, a different privacy and security statement will apply.

You should also note that if you link to a non-Scootle page, a different privacy and security statement is likely to apply

How we deal with complaints about Privacy

If you feel that we have not respected your privacy or that we have conducted ourselves inconsistently with this Privacy Policy, please contact our Privacy Officer in any of the ways specified in paragraph 14 and advise us as soon as possible. We will investigate your queries and privacy complaints within a reasonable period of time depending on the complexity of the complaint.

It would assist us to respond to your complaint promptly if it is made in writing. Please detail information relevant to your complaint.

We will notify you of the outcome of our investigation.

What to do if you have a question, problem or complaint, or want to contact us about our use of your Personal Information or this Privacy Policy

If you have any questions, comments, concerns or complaints about our Privacy Policy or practices, you can contact us by:

• Telephone: +61 3 9207 9600;
• Post: Post Office Box 177, Carlton South, Victoria, Australia 3053; or
• Email: [email protected]

Changes to this Privacy Policy

ESA may make changes to this Privacy Policy from time to time to take account of new laws and technology or changes to ESA's operation and practices. ESA recommends that you regularly check this Privacy Policy. Any changes will take effect as soon as they are posted on this website. You may obtain a paper copy of this Privacy Policy by contacting ESA via the contact details provided above.