Smart Sparrow Pty Ltd ACN 148 030 451 (“Smart Sparrow”, “us” or “we”), the operator of www.smartsparrow.com (as well as associated products, software and services, collectively referred to as the “Services”) respect the importance of privacy protection. Accordingly, Smart Sparrow complies with the Privacy Act 1988 (Cth) (“the Act”).
Data Hosting Service Provider means Amazon Web Services, Inc. (and its related companies) and any other person or entity Smart Sparrow may engage from time to time to provide similar or equivalent services; and
Personal Information means any information or data that you provide us in any form from time to time which relates to a living individual who can be identified from, or whose identity is apparent or can reasonably be ascertained from, that information or data alone or in conjunction with other information already held by the recipient, controller, or processor of such information or data and includes any expression of opinion about the individual and any indication of the intentions of the recipient or any other person in respect of that individual.
Smart Sparrow’s contact details
Smart Sparrow is the controller of any Personal Information collected through your use of the Services.
Smart Sparrow’s business address is Level 5, 116-120 Kippax St, Sydney, NSW 2000 AUSTRALIA.
You can contact Smart Sparrow by:
- Australia phone: +61 (0)2 8096 8096
- United States phone: +1 (855) 777 9556
- Email: firstname.lastname@example.org
What types of Personal Information do we collect?
Personal Information we collect from you will depend on how you use the Services, whether you are a registered user or just a visitor to the Services. If you wish to become a registered user of the Services, we require at minimum your name, email, and a password which is collected to establish and secure your user account. To provide a better Service experience, we may also request your area of educational domain, school or faculty, the number of instructors you plan to work with, and the number of students you intend to teach. Other personal Information we may collect from you includes your postal address, telephone number/s, the institution/company you work for, and your country of residence. If you wish to become a registered student on the Services, we will also collect or manage your username, student number (if applicable), and password (which may be provided to us by your educator or institution). If you are under 16 years old, you should not register to use the Services, although you may be registered or enrolled to learning experiences developed on the Services by your educator, teacher, or other responsible user.
What Personal Information is collected regarding students on the Services?
When a registered user enrolls students to a learning experience created using the Services, Smart Sparrow generally requires — at minimum — the students’ names and email addresses in order to send out invites and/or authenticate the students. Student Personal Information is also managed in line with this policy.
How do we collect Personal Information?
We collect your Personal Information from information you provide directly to us when you contact us, register to use the Services, pay for a product or service provided by the Services, participate in surveys or questionnaires, and from information you upload to the Services from time to time.
How do we use Personal Information?
Generally, we will only use and disclose your Personal Information for the following purposes:
- to register you to use the Services;
- to provide you with information you request about us or the Services we offer;
- to manage the Services (including your account) and provide you with support (as required);
- to provide you with access to and for you to use Smart Sparrow’s Services from time to time;
- to process and obtain payment for any products you order through the Services;
- to understand your needs and Services usage to help us improve the Services, our marketing or the way we do business;
- to analyze student learning behavior and trends;
- to analyze teaching behavior and trends;
- if necessary, to verify your identity or age (e.g. over 18);
- to comply with any applicable law, court order, regulation, or other legal requirement; and
- to contact you for direct marketing and promotional purposes including providing you with information about products, services, events, and special offers offered by us and third parties, unless you tell us that you do not wish to receive this type of information.
Automated decision making and profiling
Based on your Personal Information, or information gathered via your use of the Services, we may apply algorithms, automated decision making, or scripted logic to provide a better Service experience, offer you new or complimentary services, or tailor our communications with you.
From time to time we may also ask you to participate in surveys or questionnaires. These help us to improve our levels of service and to maximize the opportunities and benefits you can enjoy.
We may send you electronic messages updating you about products, services, events, offers, and special offers. We will only send you such electronic messages if you have consented to receive them or it can be inferred from your existing business or other relationship with us that there is a reasonable expectation of receiving those electronic messages. All electronic messages will identify us, and you can opt-out by unsubscribing to any of the emails we send.
What happens if you don’t provide us with the Personal Information we require?
If you don’t provide us with certain information, we may be unable to provide you the information, products, or services you wish to buy or receive.
Personal Information security
We will take commercially reasonable and appropriate steps to ensure your Personal Information is protected from risks such as loss, unauthorized access or use, destruction, modification, or disclosure. Aside from the disclosure or transfer of your Personal Information to our Data Hosting Service Provider, we only permit our authorized personnel to access your Personal Information.
The Internet is not a secure method of transmitting information. Accordingly, we cannot accept responsibility for the security of information you send to or receive from us over the Internet or for any unauthorized access, use, or modification of that information.
Payment card information
To facilitate payment for the Services, we may require Personal Information including credit card number and expiry date, debit card number and expiry date, verification numbers, and billing information. We engage secured third party payment service providers identified on the Services from time to time to process payments for products offered through the Services. Payments may be made by credit or debit card as permitted by the Services from time to time. We will not keep a record of your credit or debit number for payments for products or services made via the secured third party payment service providers used by the Services.
Using 3rd parties to process your information or provide services
Aside from the disclosure or transfer of your Personal Information to our Data Hosting Service Provider (see “Where your information is stored” below), we use the following third-party services to effectively deliver you the Services:
When we use third party service providers we seek to keep the amount of Personal Information they hold to a minimum and use reasonable efforts to make sure they are as careful with your information as we are.
Where your information is stored
Subject to the below, Personal Information we collect from you is stored securely on servers in Australia and the United States. We also engage a third party Data Hosting Service Provider to store and provide data hosting services in relation to your information. We will disclose Personal Information to our Data Hosting Service Provider to the extent necessary for it to provide the storage and data hosting services required for you to use the Services and the products and services offered via the Services. Servers in which your information (including Personal Information) is stored by our Data Hosting Service Provider are currently located in Australia and the United States, although additional or other locations may be used by our Data Hosting Service Provider in the future. If our Data Hosting Service Provider stores your Personal Information outside Australia, the Act requires us to ensure that our Data Hosting Service Provider complies with applicable Australian privacy laws unless you agree otherwise.
How do we use information that is not Personal Information?
From time to time we may sell or disclose information you provide us that is not Personal Information or does not disclose your identity to any person for any purpose at our sole discretion, including to people or companies located outside of Australia. For example, we may sell, disclose, or use information you provide us that is not Personal Information to determine what advertising, promotional materials, products, or services are likely to be of most interest to you or other Services visitors and to assist third parties to monitor general consumer trends in various areas. We may also modify your Personal Information (through encryption or other de-identifying techniques) so that it is in a form from which you cannot be identified and sell or disclose such modified information to any person for any purpose, including to people or companies located outside of Australia.
Your rights of access and correction
You have the right to access Personal Information which we have collected from you within the requirements of the Act and other legislation as relevant.
If you wish to access your Personal Information, or believe that any of the Personal Information we hold about you is inaccurate, incomplete, or out-of-date, please contact us by emailing us at email@example.com. We will take reasonable steps to correct any inaccurate, incomplete, or out-of-date Personal Information if you request us to do so, where required by law.
We may withhold or refuse you access to your Personal Information if we are legally authorized to do so or where its disclosure to you is restricted by law, is the subject of legal action, or may compromise the privacy of another person.
We may charge you a reasonable fee to access your information as permitted by applicable law.
Your right to withdraw consent
You can withdraw your consent for our use of your Personal Information at any time by emailing firstname.lastname@example.org. Please note that, as a consequence of this withdrawal, we may be unable to continue providing you the Service.
How can you stop receiving marketing information?
Where marketing information is forwarded to you via electronic messages, there will be a functional ‘unsubscribe’ mechanism contained in the message.
If you no longer wish to be contacted by us or receive such marketing information, you can advise us:
- by emailing us at email@example.com; or
- by clicking the ‘unsubscribe’ mechanism (where marketing information is sent electronically).
We will keep a record of your request to ensure you do not receive that information in the future.
You cannot refuse to receive information which we are required to provide you by law.
We suggest that you visit our website regularly to keep up to date with any changes.
Smart Sparrow’s Data Protection Officer
Brian Weck, Smart Sparrow’s CTO, is responsible for delivery of the Services and the protection of your Personal Information.
You can contact our CTO by:
- Australia phone: +61 (0)2 8096 8096
- Email: firstname.lastname@example.org
Further queries or complaints
Complaints may also be made directly to the office of the Australian Information Commissioner though its website located at www.oaic.gov.au/privacy/privacy-complaints.
Page last updated: 25 May 2018