Clipboard Privacy Policy

1. INTRODUCTION

This privacy policy applies between you, the visitor to this website (whether directly as our customer and user of our product or as personnel of our customer), and us, Clipboard Management Pty Ltd (ACN 619 827 146) (‘Clipboard’ ‘our’, ‘we’ or ‘us’), the owner and provider of this website. This privacy policy applies to our use of any and all data collected by us or provided by you in relation to your use of the website and the provision of our services to you.

We take our privacy obligations seriously and we’ve created this privacy policy to explain how we collect and treat your personal information. 

Personal information is that information which is identifiable as being about you.

By providing personal information (including sensitive information) to us, you consent to our storage, maintenance, use and disclosing of personal information in accordance with this privacy policy.

2. TYPES OF PERSONAL INFORMATION WE COLLECT

The personal information we collect may include the following:

1. name;
2. mailing or street address;
3. email address;
4. school affiliation;
5. grade/year group of schooling;
6. profile photos;
7. schedules or timesheets;
8. social media information;
9. sensitive information as set out below;
10. telephone number and other contact details;
11. age;
12. date of birth;
13. credit card information;
14. marketing preferences (opt-in/opt-out choices & interests)
15. information about your business or personal circumstances;
16. your device identity and type, I.P. address, geo-location information, page view statistics, advertising data and standard web log information;
17. details of the products and services we have provided to you or that you have enquired about, including any additional information necessary to deliver those products and services and respond to your enquiries;
18. any additional information relating to you that you provide to us directly through our websites or products or indirectly through your use of our websites or products or online presence or through other websites or accounts from which you permit us to collect information; 
19. any other personal information that may be required in order to facilitate your dealings with us; and
20. information about third parties.

3. HOW WE COLLECT PERSONAL INFORMATION

We endeavour to ensure that information we collect is complete, accurate, accessible and not subject to unauthorised access. We will collect your personal information in a lawful and fair way. We will only collect your personal information where you have consented to it, or otherwise in accordance with the law.

We may collect personal information either directly from you, or from third parties, including where you:

1. contact us through our website;
2. sign up for our mailing list;
3. interact with digital advertisements;
4. receive goods or services from us (register on our website or use our product); 
5. communicate with us via email, telephone, SMS, social media applications (such as LinkedIn or Facebook) or otherwise;
6. interact with our website, social applications, services, content and advertising; and
7. invest in our business or enquire as to a potential purchase in our business.

How we collect information from third parties 

Where possible, we collect your personal information directly from you. However, there may be occasions when we collect personal information (including sensitive information) about you from someone else. For example, when your employer (an educational institution) provides us with your information so you can use our products and services. 

How you provide information from someone else 

If you are providing personal and/or sensitive information on behalf of someone else, you must have the consent of that person to provide their personal and/or sensitive information to us to be collected, used, and disclosed in accordance with this privacy policy. We reserve the right to request evidence of this consent. 

If you are providing personal and/or sensitive information on behalf of someone under the age of 18 (Minor), you must either be that Minor’s parent or legal guardian or have obtained explicit consent from that Minor’s parent or legal guardian and you must provide consent for the Minor’s personal and/or sensitive information to be collected, used and disclosed in accordance with this privacy policy.

How we collect information from cookies

We may also collect personal information from you when you use or access our website or our social media pages. This may be done through use of web analytics tools, ‘cookies’ or other similar tracking technologies that allow us to track and analyse your website usage. Cookies are small files that store information on your computer, mobile phone or other device and enable and allow the creator of the cookie to identify when you visit different websites. Cookies may be used to serve relevant ads to website visitors through third party services such as Google Adwords. These ads may appear on this website or other websites you visit. 

We use a cookie management platform to obtain your consent before placing non-essential cookies. You can manage your preferences at any time by Clicking the below button. For more detail, see our Cookie Policy.

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If you do not wish information to be stored as a cookie, you can disable cookies in your web browser.

We may use Google Analytics to collect and process data, including when you use third party websites or apps. To find out more see How Google uses data when you use our partners’ sites or apps.]

4. USE OF YOUR PERSONAL INFORMATION

We collect and use personal information for the following purposes:

1. to provide services or information to you;
2. for record keeping and administrative purposes including analytics;
3. to operate, protect, improve and optimise our websites, products, business and our users’ experience, such as to conduct research and for advertising and marketing;
4. to personalise content and communications, improve and optimise our service offering and customer experience;
5. to manage user preferences and consent;
6. to provide information about you to our contractors, employees, consultants, agents or other third parties for the purpose of providing services to you;
7. to comply with our legal obligations, resolve disputes or enforce our agreements with third parties;
8. to send you marketing and promotional messages and other information that may be of interest to you and for the purpose of direct marketing (in accordance with the Spam Act 2003 (Cth) and the Privacy Act) in the form of emails, SMS, mail or other forms of communication;
9. to send you service, support and administrative messages, reminders, notices, updates, security alerts, and other information requested by you; and
10. to consider an application of employment from you.

We may also use your personal information for:

11. secondary purposes closely related to the primary purpose, in circumstances where you would reasonably expect such use;
12. such purposes where we reasonably believe that use of your personal information is necessary to lessen or prevent a serious threat to the life, health or safety of any individual, or to public health or safety, and it is unreasonable or impracticable to obtain your consent;
13. any other purpose for which we receive consent from you; or
14. any other purpose which is permitted or required under applicable privacy laws.

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5. HOW WE DISCLOSE YOUR PERSONAL INFORMATION 

We respect your privacy, and we will take reasonable steps to keep your personal information confidential and protected. We may disclose your personal information to:

1. contractors and third parties located inside or outside of Australia. If we do so, we will take reasonable steps to ensure that any overseas recipient deals with such personal information in a manner consistent with how we deal with it;
2. our professional advisors such as lawyers, accountants and auditors;
3. our related entities; 
4. anyone to whom our assets or businesses (or any part of them) are transferred; 
5. affiliated educational partners where relevant and with appropriate consent; 
6. other persons, including government agencies, regulatory bodies and law enforcement agencies, or as required, authorised or permitted by law; and
7.  any third parties you have consented personal information to be disclosed to.

We may also disclose personal information to third party contractors as required for us to provide our goods and services to you, such as cloud-service providers, IT professionals, marketing agencies and debt collection agencies.

We take care to work with such third parties who we believe maintain an acceptable standard of data security and require them not to use your personal information for any purpose except for those activities we have asked them to perform on our behalf.

We will not otherwise disclose your personal information unless:

1. you have consented to us disclosing your personal information for particular circumstances;
2. as needed in an emergency or in investigation suspected criminal activity;
3. we are required to disclose under a subpoena, court order or other mandatory reporting requirements;
4. we reasonably believe that disclosure of your information is necessary to lessen or prevent a serious threat to the life, health or safety of any individual, or to public health or safety, and it is unreasonable or impracticable to obtain your consent;
5. it is reasonably necessary for the establishment, exercise or defence of a legal claim; or
6. it is otherwise authorised or required by law.

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6. STORAGE OF YOUR PERSONAL INFORMATION 

All personal information we collect may from time to time be stored, processed in or transferred between parties or sites located in Australia and in countries outside of Australia. These may include, but are not limited to Australia, UK, New Zealand and USA. You consent to the transfer, storage and retention of that information onto the servers of our host provider used from time to time by us, regardless of the location of those servers.

Further, the cloud service providers we engage may operate overseas disaster recovery sites or have personnel overseas who may access the personal information we hold to assist us in managing our servers.

We also may use Google Analytics to track web traffic information which is operated by Google which stores information across multiple countries.

When you communicate with us through a social media service such as Facebook or Twitter, the social media provider and its partners may also collect and hold your personal information overseas.

7. SENSITIVE INFORMATION

We may collect sensitive information about you (and your child if applicable), during the course of providing you services. The type of sensitive information we may collect includes: information relating to your racial or ethnic origin, political opinions, religion, trade union or other professional associations or memberships, philosophical beliefs, sexual orientation or practices, criminal records or health information.

Where we collect sensitive information (such as health, ethnicity, or religious data), we do so only with your explicit consent or that of a parent/guardian for a minor.

If you consent, your sensitive information may only be used and disclosed for purposes relating to providing you with our services, data analytics, sending you messages, reminders, notices, updates, security alerts, and other information requested by you, and/or referring you to medical or health service providers in circumstances where we cannot obtain your consent.

Your (or your child’s), sensitive information may also be used or disclosed for any other purpose which is permitted or required under applicable privacy laws and to comply with our legal obligations.

How you can withdraw consent

If you wish to withdraw your consent to our collection, use or disclosure of your sensitive information, please contact us using the contact details set out below. We will deal with all such requests within a reasonable timeframe.

8. MARKETING

We may at times send you marketing communications which will be done in accordance with the Spam Act 2003 (Cth) (Spam Act).

If we do, we may use email, SMS, social media, phone or mail to send you direct marketing communications.

Where consent is needed, we will ask you for your consent before sending you marketing communications, except where you:

(i) have explicitly opted-in to receiving email marketing from us in the past; or

(ii) were given the option to opt-out of email marketing when you initially signed up for one of our platforms and you did not do so.

You can, at any time, opt out of receiving marketing materials from us by using the opt-out facility provided (e.g., an unsubscribe link on emails we send you) or by contacting us via the details provided at the end of this privacy policy. We will implement such a request as soon as possible, however, cannot guarantee that such a response will be immediate.

9. DE-IDENTIFIED INFORMATION

The information we collect may have analytical, educational, or commercial value to us. Where we have de-identified the information we have collected, we reserve the right to process and distribute such information. 

 10. SECURITY

We take reasonable steps to ensure your personal information is secure and protected from misuse, interference, unauthorised access and loss. Our information technology systems are password protected, and we use a range of administrative and technical measures to protect these systems. For example, we use a secure third party data provider to store all personal information. However, we cannot guarantee the security of your personal information.

11. LINKS

Our website may contain links to other websites. Those links are provided for convenience and may not remain current or be maintained. We are not responsible for the privacy practices of those linked websites and we suggest you review the privacy policies of those websites before using them.

12. REQUESTING ACCESS OR CORRECTING YOUR PERSONAL INFORMATION

If you wish to request access to the personal information we hold about you, please contact us using the contact details set out below including your name and contact details. We may need to verify your identity before providing you with your personal information. In some cases, we may be unable to provide you with access to all your personal information and where this occurs, we will explain why. We will deal with all requests for access to personal information within a reasonable timeframe.

If you think that any personal information we hold about you is inaccurate, please contact us using the contact details set out below and we will take reasonable steps to ensure that it is corrected.

13. HOW LONG WE KEEP DATA / RETENTION PERIODS

We retain your personal data for as long as necessary to fulfil the purposes for which it was collected, including to satisfy legal, contractual, educational, or reporting obligations. Personal data relating to students is retained for 7 years following cessation of service use, unless otherwise required by applicable education law or institutional policy. Personal data relating to schools is retained for 7 years following cessation of service use, unless otherwise required by applicable education law or institutional policy.

14. DATA BREACH NOTIFICATION POLICY 

We are committed to protecting personal information and handling data breaches in accordance with applicable Australian privacy laws.

If we become aware of a data breach involving personal information that is likely to result in serious harm (as defined under the Privacy Act 1988 (Cth)), we will act promptly to:

1. assess the situation; and
2. where required, notify the affected individuals and the Office of the Australian Information Commissioner (OAIC) under the Notifiable Data Breaches scheme.

We will provide affected individuals with timely information about the nature of the breach, the data involved, potential impacts, and steps they can take to protect themselves.

15. CHANGE OF CONTROL

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. We would seek to only disclose information in good faith and where required by any of the above circumstances.

16. COMPLAINTS

If you wish to complain about how we handle your personal information or held by us, please contact us using the details set out below including your name and contact details. We will investigate your complaint promptly and respond to you within a reasonable time.

17. Contact Us

For further information about our privacy policy or practices, or to access or correct your personal information, or make a complaint, please contact us using the details set out below:

Phone: 1300 363 992

Email: enquiries@oaic.gov.au

Post: GPO Box 5218, Sydney NSW 2001

Complaint Form found here https://www.oaic.gov.au/privacy/privacy-complaints/lodge-a-privacy-complaint-with-us

By providing personal information to us, you consent to our storage, maintenance, use and disclosing of personal information in accordance with this privacy policy.

We may change this privacy policy from time to time by posting an updated copy on our website and we encourage you to check our website regularly to ensure that you are aware of our most current privacy policy.

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