Privacy Policy

RADII/ProLearning Privacy Policy

 

Application

This Privacy Policy applies to RADII (ABN 72006684699) and ProLearning (ABN 36609572750).

This policy applies in addition to any Terms of Use, Licence Agreement or equivalent agreement which you may have entered into with either RADII or ProLearning in respect of a particular product or service.

 

Overview

RADII and ProLearning are subject to the Privacy Act 1988 (Cth) (Privacy Act), which regulates how RADII and ProLearning may collect, use, disclose and otherwise handle personal information.

This Privacy Policy outlines what types of personal information RADII and ProLearning collects, and how it deals with this personal information. Personal information includes any information or opinion about an identified individual or an individual who is reasonably identifiable. Sensitive information includes information or opinion about an individual’s racial or ethnic origin, political opinion, religious beliefs, sexual orientation, health information or criminal record.

 

What types of personal information do we collect and hold?

The types of personal information which RADII and ProLearning collects may include an individual’s name, phone number, fax number, email address, postal address, nationality, educational qualifications, date of birth, identifying number(s)/code(s), and job title. Depending on the product or service you use, and/or your relationship with us, you may also be asked for other types of personal information such as: location information, school affiliation, employment history, tax file number, and profile picture. We may also collect sensitive information such as criminal record history, race or ethnicity and health information for specific purposes where there is an obligation for us to do so.

Personal information may be collected by RADII and ProLearning in a number of circumstances, including when an individual:

  • uses a product or service provided by RADII and ProLearning (including by creating an account for or accessing a portal on RADII and ProLearning);
  • requests to download a document, product trial, video or sample data from RADII and ProLearning;
  • makes an enquiry through our website or online enquiry service;
  • lodges a support request regarding a RADII and ProLearning product or service;
  • subscribes for a newsletter;
  • attends, or registers to attend, a seminar or other event (such as a webinar or training event);
  • enters a competition;
  • applies for employment with us; or
  • otherwise contacts any entity within RADII or ProLearning.

If you provide personal information about someone else to RADII or ProLearning, you must ensure that you are entitled to disclose that information to RADII and ProLearning and that, without taking any further steps, RADII and ProLearning may use, hold and disclose such information for the purposes described in this Privacy Policy. For example, you should take reasonable steps to ensure the individual concerned is aware of the various matters detailed in this Privacy Policy, including our identity and how to contact us, the purposes for which the personal information has been collected, how it will be used and disclosed the individual’s right to obtain access to the information.

RADII and ProLearning may also collect personal information about you which is publicly available, such as on websites, or from third party organisations and bodies, including government bodies. We will comply with any confidentiality and privacy obligations imposed on us by such organisations and bodies.

RADII and ProLearning products are used to store personal information about third parties, which RADII and ProLearning itself does not collect. In these cases, individuals should refer to the privacy policy of the organisation collecting the data.

In the case of an individual setting up their own account with RADII and ProLearning, the personal information we will require is your name, email address, organisation, and information about your role in the organisation. You may also be asked to provide other information such as a profile picture and gender details, although whether you do provide such information will be your choice.

 

What other information do we collect?

When you visit a RADII and ProLearning website or use a product or service provided by RADII or ProLearning, the following anonymous information may be collected about you for statistical purposes:

  • your Internet Protocol address;
  • the date and time the RADII or ProLearning server received the request;
  • the pages, documents and files you requested;
  • the address of the resource which provided the link followed, if any, to a RADII or ProLearning website;
  • the type of browser and, in some cases, the operating system used; and
  • in some cases, data you send to a RADII or ProLearning website from web forms such as search engines.

This information is collated for analysis and is only available to a limited number of RADII or ProLearning staff. It is evaluated and published in reports that show usage patterns.

Some RADII and ProLearning websites use standard industry technologies, for example ‘cookies’, to make full use of the site. RADII and ProLearning uses cookies to distinguish you from other users of the websites. This helps us to provide you with a better experience when you browse our websites and also allows us to improve the sites.

Web beacons may also be used in some of our emails to let us know which emails (and which links within those emails) have been opened by recipients. This allows us to gauge the effectiveness of our customer communications.

For security reasons, RADII and ProLearning also uses software programs to monitor network traffic and identify unauthorised attempts to upload or change information, or otherwise cause damage.

No attempt will be made to identify individual users of a RADII or ProLearning website, except where we are required or permitted to do so by law. For example, RADII or ProLearning may gather more extensive information about an individual in the following circumstances:

  • unauthorised attempts are made to access our data or files;
  • unauthorised tampering or interference occurs in respect of data published on a RADII or ProLearning website;
  • unauthorised attempts are made by other websites to index the contents of a RADII or ProLearning website;
  • attempts are made to intercept messages of other RADII or ProLearning website users;
  • RADII or ProLearning product or service is used to send communications which are defamatory, abusive, vilify individuals or groups or give rise to a suspicion that an offence is being committed; and/or
  • attempts are made which otherwise compromise the security of a RADII or ProLearning web server, breach an applicable law, or interfere with the use of a RADII or ProLearning website by other users.
How do we use your personal information?

RADII and ProLearning may use personal information (including personal information which is not collected by us) for the following purposes:

  • providing our products and services to you, including sending you notifications;
  • responding to your queries;
  • administering and managing our products and services for prospective and current clients, including billing, maintaining information technology systems, customer service, managing product referrals and data storage;
  • marketing RADII and ProLearning products and services to prospective, current and past clients;
  • hiring and managing employees and contractors;
  • planning, monitoring, evaluating and improving RADII and ProLearning products and services, including conducting market research and surveys and assessing customer satisfaction; and
  • otherwise communicating with you.

We will only use the sensitive information we collect from our staff and individuals who work with us to help with employment processes such as recruitment, sickness management, equal opportunities reporting, disciplinary proceedings, or making reasonable adjustments in the workplace.

We may send you direct marketing communications and relevant information about our products and services that we consider may be of interest to you. These communications may be sent in various forms, including SMS, email and fax. We will only send communications in accordance with applicable and relevant marketing laws such as the Spam Act 2003 (Cth). If you have indicated a preferential method of communication, we will do our utmost to send via that method whenever possible.

If you no longer wish to receive any communications, please send an email to our Privacy Contact Officer using the details set out below. If you want to be removed from any RADII or ProLearning database, please contact our Privacy Contact Officer using the details set out below.

 

Who do we disclose your personal information to?

Personal information about you may be disclosed to third parties if you have consented to such disclosure, either to RADII and ProLearning directly or to a school.

Personal information which is collected by one member of RADII and ProLearning may be used by and disclosed to other members of RADII or ProLearning for the purposes described in this Privacy Policy.

The RADII and ProLearning products are designed to foster communities of practice within the Education Sector. A user’s personal information may be visible to other users of the same software who reside outside of their organisation if they or their organisation choose to use it in this way. Additionally, a school or organisation may engage with third parties to support learning on its behalf, in which case personal information may be shared to the third party delivering the support. Third party learning support arrangements and relationships for content delivery remain the responsibility of the licensee at all times. RADII and ProLearning may share aggregated and de-identified usage information to content providers to help them understand how their products are used and improve their services.

RADII and ProLearning use cloud-based services, principally within Australia, but including entities that host data outside of Australia to store and process personal information. Where RADII and ProLearning utilise such overseas service providers, we will endeavour to maintain effective control of your information at all times, including by ensuring that parties located overseas are subject to strict controls that limit access and subsequent handling of your information to the extent strictly necessary to perform the relevant function and protect your information from unauthorised use and disclosure. This is part of our efforts to take reasonable steps to ensure that overseas recipients of your personal information do not breach the privacy obligations relating to personal information.

Under no circumstances will RADII or ProLearning sell (or otherwise receive payment for licensing or disclosure of) your personal information.

 

Is data stored in a secure way?

RADII and ProLearning strive to ensure the security, integrity and privacy of personal information which it holds and has security measures in place to protect such information against misuse, loss or unauthorised use or disclosure. However, no system is 100% secure and we cannot guarantee the security of your information.

 

Will your personal information be published on our website?

RADII and ProLearning will only publish personal information on our websites if it has been specifically collected for this purpose and with your knowledge and consent.

When giving such consent you should be aware that information published on a RADII or ProLearning website is accessible to millions of users from all over the world, that it will be indexed by search engines and that it may be copied and used by any web user. This means that once the information is published on a RADII or ProLearning website, RADII and ProLearning will have no control over its subsequent use and disclosure.

 

What about external links?

The RADII and ProLearning websites contain links to sites operated by third parties. RADII and ProLearning are not responsible for the privacy practices or the content of such websites and we recommend that you check the privacy policy and terms of use of each website you use, visit, or link to, and contact the owners or operators of such websites if you have any concerns or questions.

 

Anonymity and pseudonymity

Australian privacy law provides the option of not identifying yourself, or of using a pseudonym unless we are required or authorised by law or a court/tribunal to identify you, or it is impracticable to deal with you anonymously or by a pseudonym.

 

Can I access and correct my personal information?

RADII and ProLearning take reasonable steps to ensure the personal information it stores is accurate, complete and up-to-date. We may periodically contact customers for this purpose.

You have the right to request access to your personal information held by RADII and ProLearning. Where such information is held by us, we will endeavour to provide you with an appropriate means of accessing it, normally by email or post. We may charge you a fee to cover our administrative and other reasonable costs in providing the requested information to you. However, we will not charge for simply making the request and will not charge you for making any corrections to your personal information. There could be instances where we cannot grant you access to the personal information we hold. An example of where this might happen is where granting access would have an unreasonable impact on the privacy of others or if it would be unlawful. We will give you written reasons for any refusal.

If you believe that personal information we hold about you is incorrect, incomplete or inaccurate, then you can request us to amend it. We will then review your request and amend the data if we agree. If we do not agree that there are grounds for amendment, then we will add a note to the personal information stating that you disagree with it.

You may make such a request by contacting our Privacy Contact Officer as follows:

By Post: RADII, Suite 71, 197 Canterbury Road St Kilda, Victoria 3182 Australia 

By telephone: 613 9534 2934 (Monday to Friday, 8.30am to 4.30pm AEST)

By email: privacy@radii.org

 

Can I make a complaint about privacy?

If you wish to make a complaint regarding privacy, you should first contact our Privacy Contact Officer using the contact details above.

RADII and ProLearning will review all privacy related complaints which are submitted and will aim to respond in writing within a reasonable time. If you are not satisfied with the outcome, you may then refer the matter to the Office of the Australian Information Commissioner at:

Website: www.oaic.gov.au

Phone: 1300 363 992

 

Changes to this policy

We may change this policy periodically as needed. Any updated versions of this policy will be posted on our website.

 

This policy was last updated on 04/02/2019.

 

Peter Cuttance

Director, RADII

Founder & Chairman, ProLearning

Ph: 61 428 990 904

Fx: 61 386 400 741

 

Susi Steigler-Peters

CEO, ProLearning

Mob. 61 448 450 115

Susi.steigler-peters@prolearning.co

 

Postal address: RADII, Suite 71, 197 Canterbury Road, St Kilda West, Victoria 3182, Australia

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