In this agreement, references to ‘us’, ‘we’ or ‘our’ means The Reading Spelling Toolkit, ABN 55 740 574 524 and we are the operator of www.connectliteracyandlearningcentre.com.au and any other websites or platforms operated by us (‘website’).
References to ‘you’ or ‘your’ means you as the person or legal entity using our website.
'Personal information' is information that directly identifies you, such as your name and email address, or data that could be used, on its own or in combination with other data, to identify you.
We take your privacy seriously and strive to always collect, process and protect your personal information in accordance with the privacy standards as set out in the GDPR. We have developed this policy, so you can easily see what information is collected about you, how we use your information, who we share it with, how we keep it safe and what your rights are.
You can browse this website anonymously (although cookies may identify your IP address). If you identify yourself to us, at that point we will collect your personal information. Due to the nature of the services we offer, if you purchase our program, we will necessarily collect personal information about you.
Collecting Personal Information
At all times we aim to only collect the minimum information we need for the services we are providing. For example, if you sign up to our newsletter or purchase our program, we will collect and use your email address for marketing purposes. As you would expect, the more involved you are with us, the more information about you we will collect.
The main way we collect information about you is when you give it to us and this can happen in a variety of ways. We may process the following categories of personal information about you:
- Communication data: which includes any communication that you send to us. This might be when you fill out a survey or questionnaire, join our mailing list or when you contact us through the contact form on our website, through email, social media messaging, social media posting or any other communication that you send us. If you sign in using social media, we may receive (by your consent) additional information such as your profile picture and social profile ID. We process this data for the purposes of communicating with you, for record keeping and for the establishment, pursuance or defence of legal claims. Our lawful ground for this processing is our legitimate interests which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.
- Customer Data: which includes data you give to us when you purchase goods and/or services from us including purchasing our program. This will include basic information about you including the information we require for billing purposes such as your name, title, billing address, delivery address, email address, phone number, contact details, purchase details and your card details (last digits only). We use third party services for processing payments such as PayPal and Stripe and we do not receive or store your full card payment information. We process this data to supply the goods and/or services you have expressed an interest in or purchased (such as our program) and to keep records of such transactions. Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract and our legitimate business interest of keeping records for accounting purposes.
- User Data: which includes data about how you use our website and any online services together with any data that you post for publication on our website (if applicable) or through other online services (for example our closed Facebook group). We process this data to operate our website and ensure relevant content is provided to you, to ensure the security of our website, to maintain back-ups of our website and/or databases and to enable publication and administration of our website, other online services and business. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business.
- Technical Data: which includes data about your use of our website and online services such as your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website. The source of this data is from our analytics tracking system. We also use our own cookies for functions such as checking if you are logged in (if enabled) and which products you have access to. We process this data to analyse your use of our website and other online services, to administer and protect our business and website, to deliver relevant website content and advertisements to you and to understand the effectiveness of our advertising. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business and to grow our business and to decide our marketing strategy.
- We may also use your personal information to carry out some automated decision making about you. For instance, our email manager may monitor which mails you open and use this information to automatically manage future emails you receive. Our lawful ground for this processing is our legitimate interests which in this case are to study how customers use our products/services and to grow our business.
Collecting Information From Third Parties
As discussed above, we collect personal information about you when you give it to us and when it is collected by our website however we may also collect personal information that is given to us or made available to us by a third party (for example, information that is on a publicly maintained record or that you have made available on a public platform).
We may automatically collect certain data from you as you use our website by using cookies and similar technologies. Please see our cookie section below.
We may receive data from third parties such as analytics providers like Google, advertising networks such as Facebook, information providers such as Google, providers of technical, payment and delivery services, such as data brokers or aggregators. Most of this information does not specifically identify you.
This information forms part of the personal information described in this policy. We will not intentionally collect personal information that is unintentionally disclosed.
Collecting Sensitive Information
We do not intend to collect sensitive information about you and request you never disclose information about your health, racial or ethnic origin, political opinions, religious beliefs or sexual orientation to us in person or on our website or any blog or social media account associated with our website or business.
We do not intentionally collect data about children under the age of 16. We may however collect personal information about a minor if that information is provided by you as the parent or legal guardian of that child and you have given your specific consent for the collection and use of the personal information. A parent or guardian may withdraw this consent at any time by contacting us at [email protected].
Reviews or Testimonials
If you provide us with a review or testimonial, you give us your consent for the use of your name, your child’s name and details of their literacy journey together with the content of the testimonial you provide to be displayed on our website or in our other marketing material. We may edit your testimonial but will only do so where possible without changing the meaning of what you have said. We may store and/or use your testimonial for as long as the information is relevant to our business. We process this information based on your consent which you may withdraw.
If you provide us with your email address or postal address for marketing purposes, we may send you information we think you will be interested in relating to the services we offer. This may include general information eg about marketing, specific emails promoting our services or information about other areas we believe our subscribers will be interested in. We may also send you joint affiliate offers if we believe this might be of value to you. Our lawful ground of processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely to grow our business).
You may unsubscribe from our marketing list at any time by using the unsubscribe link in the email. If for any reason this does not work, and you still receive information from us, or you would like to have your postal address removed from our database, please email us at [email protected] and we will fix this for you.
If you opt out of receiving marketing communications, this opt-out does not apply to personal data provided for other transactions such as purchases.
Social Networking Services and links to other websites
You can connect with us via our social media pages eg. Facebook and Youtube. We may provide links to other websites or use social networking services to communicate with the public about our work. When you communicate with us using these services we may collect your personal information. The social networking service will also handle your personal information for its own purposes and have their own privacy policies.You should become familiar with the privacy policies of any service you use.
We use a range of tools provided by third parties including our website host, third party service providers and search engine browsers to collect or view access and traffic information for statistical, reporting and maintenance purposes. Third party providers have their own privacy policies. We also may also use tracking pixels, cookies and session tools to improve your experience when accessing our online services.
The data collected by cookies does not usually identify you but may be combined with other information to identify you. If we identify you using information from cookies, we may use that information to track how you use our online services and send you information more specific to your needs, or to invite you to purchase our services.
The kind of information that will be collected includes:
- device specific information such as mobile network information
- server logs including your IP address, the times you use our services and system activity
- location information including IP address, GPS, and Wi-Fi access points
- local storage availability
We use the information to help to track your use of our online services to improve your user experience and the quality of our services.
Some of the cookies we use are for targeted advertising. To find out how to opt out of tailored advertising please check the options available here - http://www.networkadvertising.org/choices/.
Use and disclosure of personal information
In summary, as a legitimate business interest, the personal information we collect about you is used:
- to verify your identity
- to enable you to use our services
- to process orders, purchases and enquiries
- to provide you with information about events, products and services that may interest you
- to provide you with personalised service or special opportunities
- to allow you to participate in interactive features of our online services
- to run promotions (if any)
- to facilitate our internal business operations
- to improve our products or services and in planning new products or services
- to conduct market research surveys
- to monitor compliance with our Terms and Conditions.
With your consent or at your request we may:
- share your contact information with third party organisations who offer products or services that may be of interest to you (if you agree to receive such information)
We may also disclose your information to:
- Other companies in our group who provide services to us.
- Payment third parties if there is a dispute over a payment. For example, if PayPal contacts us regarding a dispute over a payment, we will provide PayPal with user activity information such as IP address, course enrolment and activity linked to the IP address, billing details on our system etc to allow the payment dispute to be resolved.
- Professional advisers including accountants, lawyers, bankers, auditors and insurers.
- Government bodies that require us to report processing activities.
- Third parties where we are required to in accordance with the law and reserve the right to fully co-operate with any law enforcement authorities or court order requiring or requesting us to disclose the identity or other usage details of any user of our online services, or in accordance with a properly executed court order, or as otherwise required to do so by law.
Security and Overseas Recipients
We are committed to ensuring that your information is secure to industry standards however no system can be 100% secure and we are not responsible for loss you may suffer should your personal information be unlawfully accessed. Using the Internet to collect and process personal data necessarily involves the transmission of data on an international basis. For example, the cart we use for payments, Stripe, have their storage/ data centres in the United States. Not all countries have the same level of privacy protection as the country within which you reside. You acknowledge and agree to our processing of personal data across international borders in this way. We will do our best to ensure your data is protected to a similar standard as set out in this policy by using third party providers with similar privacy protections.By submitting your personal information to us, you agree to the transfer of your data across international borders.
We will also take reasonable steps to protect all personal information within our direct control from misuse, interference, loss, unauthorised access, unlawful or accidental destruction, modification or disclosure. To prevent unauthorised access or disclosure we use respected hosting services, firewall and other electronic security procedures and managerial procedures to safeguard and secure the information we collect from you.
We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we are legally required to.
All hard copy records we keep are stored in Australia.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. When deciding what the correct time is to keep the data for we look at its amount, nature and sensitivity, potential risk of harm from unauthorised use or disclosure, the processing purposes, and if these can be achieved by other means and legal requirements. For tax purposes the law requires us to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for some time even after they stop being customers.
In some circumstances we may anonymise your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Third Party Links
Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
Accessing and Correcting Your Personal Information – Your Legal Rights
Under the GDPR, EU citizens have rights in relation to their personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent.
Under Australian privacy law, an Australian resident has the right to know what information we have stored and check on or update the accuracy of that information.
If you wish to exercise any of the rights set out above, please email us at [email protected].
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive or refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and check your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. For record keeping purposes, we will record and store all information exchanged during an exercise of your rights under this clause. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you.
If you are an EU citizen and you request to have your information erased (also known as the right to be forgotten), we will, if appropriate, delete your personal information from our active business operating system. Your personal information will however continue to be stored within our backup(s) as we are unable to delete specific items from our backup. It will be deleted at the next scheduled backup deletion. We will keep a log of your request to be forgotten so that, should our backup be used to restore our operating system while your personal information is still stored, your personal information will again be removed from our active system upon restoration.
If you have any concerns about our use of your personal information, please email us at [email protected] and let us know what the problem is, and we will see if we can resolve the problem. If you are still not satisfied, you have the right to complain to the Information Commissioner’s Office in your country. For instance, in Australia, this is the Australian Privacy Commission (www.oaic.gov.au).