Smart Sparrow Pty Ltd ACN 148 030 451 (“Smart Sparrow”, “us” or “we”), the operator of www.smartsparrow.com (the “Website”) and provider of associated products, software and services (collectively referred to as the “Services”) respects 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
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.
What types of Personal Information do we collect?
Personal Information we collect from you will depend on how you use the Services, and whether you are a registered user or just a visitor to the Website. Personal Information we may collect from you includes your name, email address, postal address, telephone number/s, the institution/company you work for, your country of residence and information necessary for us to provide the Services to you. 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. If you wish to become a registered user of the Website, we will also collect or manage your username, student number (if applicable) and password. 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.
How do we collect your 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 any Services, participate in surveys or questionnaires and from information you upload via the Website from time to time.
How do we use your 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 the Website and Services and for you to use Smart Sparrow’s Services from time to time;
- to process and obtain payment for any Services;
- to understand your needs and Services usage to help us improve the Services, our marketing or the way we do business;
- to analyse student learning behaviour and trends;
- to analyse teaching behaviour and trends;
- if necessary, to verify your identity or age (i.e. 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.
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, unauthorised 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 authorised 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
We engage secured third party payment service providers identified on the Website from time to time to process payments for Services offered through the Website. Payments may be made by credit or debit card as permitted by the Website from time to time. We will not keep a record of your credit or debit number for payments for Services made via the secured third party payment service providers used by the Website.
Using 3rd parties to process your information or provide services
We may use third party service providers to manage information that you provide and we do use a secure third party service to process payments. Aside from the disclosure or transfer of your Personal Information to our Data Hosting Service Provider (see “Where your information is stored” below), when we use third party service providers, we seek to keep the amount of Personal Information they hold to a minimum and obviously 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. 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 Website and the Services offered via the Website. Servers in which your information (including Personal Information) is stored by our Data Hosting Service Provider are currently located in Australia, although additional or other locations may be used by our Data Hosting Service Provider in the future. In particular, our Data Hosting Service Provider will likely also store your Personal Information on servers located in the United States. 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 Website 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.
We may withhold or refuse you access to your Personal Information if we are legally authorised 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.
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.