CAPITAL TUTORING SERVICES PRIVACY POLICY

Capital Tutoring Services has a new address! Level 1, 103/42 Mort St, Braddon

Privacy Policy

Link to this section Introduction

We respect, and understand the importance of, the privacy of the personal information of the people and families we deal with, particularly the children we work with. We provide this Privacy Policy to explain how we collect, use, protect, and disclose information and data, including when you use our website (“Site”) and when you access the services we offer (“Services”). This Privacy Policy applies to all users of the Site and Services, and to the families with who we work.

For the purposes of this Privacy Policy, the term “you” refers to you as an individual and also your child/ren if you are accessing or providing information for your child/ren.

BY USING THE SITE OR SERVICES, YOU ARE CONSENTING TO THIS PRIVACY POLICY. PLEASE READ IT CAREFULLY.

Link to this section 1. Personal Information We Collect

“Personal Information” is any information which identifies an individual or from which an individual’s identity can be ascertained (or which can reasonably be ascertained). For our purposes, this can include sensitive information such as medical diagnoses of individuals we deal with (including learning or cognitive difficulties).

We may collect the following categories and types of “Personal Information” about individuals accessing our Service and their family:

a. Personal information provided when you commence a relationship with us, including information obtained from enrolment and information forms you fill out;

b. Your contact Information, including but not limited to first and last name, date of birth, mailing address, email address, phone number and details of education;

c. School reports and academic records of students engaged with the Service;

d. Information regarding any medical or learning difficulty diagnosis relevant to the student or the student’s family which may assist us in providing the desired Services;

e. Information regarding any assistance that has been or is being provided to a student in relation to any learning or academic difficulties;

f. Other identifying information: IP address, social media usernames, passwords and other security information for authentication and access;

g. Financial Information: credit card, debit card and bank account information;

h. Demographic information: gender, age and information about education;

i. Geolocation data;

j. Internet or other electronic activity: your browsing and click history, including information about how you navigate within our Site and Services and which elements of our Site and Services you use the most;

k. Any contracts and agreements that we may enter into with you;

l. Any correspondence between you and us;

m. Any other personal information provided when an inquiry is made by you, when you request information from us or otherwise correspond with us;

n. Commercial information: products or services purchased or viewed on our Site;

o. Audio and visual information: your videos and photos;

p. Inferences drawn from the categories described above in order to create a profile about you to reflect your preferences, characteristics, behaviour and attitude; and

q. Other information: some other information we collect as required to effectively provide the Services being offered.

Link to this section 2. Why we collect Personal Information

We collect personal information to best help us provide effective Services to you or your child. It is important that the personal information we hold about you is complete, accurate and current. If we do not have accurate personal information about you or your child, we cannot appropriately tailor Services for your child’s needs.

It is important that you tell us of any changes to the information we hold.

We may collect Personal Information for the following purposes:

a. To determine your requirements and to provide you with appropriate information about the Services we can offer;

b. To provide personalised Services to you/your child/ren with your/their particular needs and difficulties in mind;

c. To process information you send us (including answering queries or dealing with feedback);

d. To know how to contact you;

e. To review our Services to see what can be improved or changed; and

f. To comply with our legal obligations in relation to you (including the making of mandated reports where there are concerns about the safety of a child).

Link to this section 3. Sources of Personal Information

We may collect Personal Information from the following sources:

a. We collect information directly from you. We may collect contact, demographic and financial information directly from you, including when you fill out a form on our Site, sign up for communications from us, ask us to contact you, when you contact us or when you use our Services. The information that we collect depends on the nature of your interactions with us.

b. We may also collect information about you from third-party sources, including any information you make publicly available on social media platforms or other online or offline resources, or when you give us consent to link your account to a third-party service or provider. We may also, where appropriate and where you consent, obtain information directly from a child’s school or medical provider.

c. We collect information from you passively. We may collect internet or other electronic activity passively using tools like browser cookies. This activity is further described in the Cookies and Advertising and Online Tracking sections below.

Link to this section 4. How We Use Personal Information

We use your personal information to help us to provide personalised services to you and your child. We may use your Personal Information for the following categories of use:

a. To contact you and provide you with information you have requested;

b. To provide you with information about Services we think you may be interested in as well as the Services themselves;

d. To maintain our relationship with you;

e. To help us develop, manage and improve the Services we provide;

f. Transactional Purposes: We may use your contact information, financial information, and commercial information to:

i. Receive, process and/or confirm your registration;

ii. Communicate with you about your registration; and

iii. Process payment for Services provided to you/your child/ren.

g. Analytical Purposes: We may use your other identifying information, internet activity and browsing history, commercial information, demographic information, and geolocation data to analyse preferences, trends and statistics.

h. Marketing and Promotional Purposes: We may use your contact information, commercial information, demographic information, internet or other electronic activity, geolocation data and inferences to:

i. Inform you of our new products, services and offers;

ii. Provide you with targeted advertising;

iii. Run competitions and promotions; and

iv. Provide you with other information from and about us, including personalised marketing communications.

i. Maintenance and Improvement of the Site and Services: We may use your contact information, commercial information, and internet activity and browsing history to:

i. Provide you with the Site and Services, including to send you alerts;

ii. Handle your customer services requests; and

iii. Help us diagnose technical and service problems and administer our stores, the Site, and the Services.

j. Review and content creation purposes: We may use your contact information, commercial information, and audio and visual information to enable reviews of our products and to display content that you have created and allowed us to display on our Site and Services and on social media.

k. Security and Fraud Prevention: We may use your contact information, other identifying information, commercial information, internet activity and browsing history, and inferences to protect the Site and services, our Business, and others and to prevent fraud, theft and misconduct.

l. Legal Requirements and Other Purposes: We may use your personal information to comply with legal requirements or when necessary to provide to our lawyers, accountants or other advisors. We may also use your personal information for other purposes for which you have consented to, or for other purposes as permitted by law. This may include for a secondary purpose that is related to a purpose for which we collected it, and for which you would reasonably expect us to use your information for.

m. To provide your information to others (with your consent, express or implied).

n. We may also provide information to some third parties:

i. Service Providers

From time to time, we may establish a business relationship with other businesses whom we believe trustworthy and have privacy practices consistent with ours (“Service Providers”). For example, we may contract with Service Providers to provide certain services, such as hosting and maintenance, data storage and management, and marketing and promotions. We only provide our Service Providers with the information necessary for them to perform these services on our behalf. These Service Providers may be in Australia or overseas.

ii. Our Affiliates - We may share Personal Information with businesses controlling, controlled by, or under common control with us.

iii. Corporate Transactions - If we merge, are acquired, or are sold, or in the event of a transfer of some or all of our assets, we may disclose or transfer Personal Information in connection with such transaction. You will have the opportunity to opt out of any such transfer if, in our discretion, it will result in the handling of your Personal Information in a way that differs materially from this Privacy Policy.

iv. Compliance with Laws and Law Enforcement - We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We may disclose Personal Information and any other information about you to government or law enforcement officials or private parties if, in our discretion, we believe it is necessary or appropriate in order to respond to legal requests (including court orders and subpoenas), to protect the safety, property, or rights of our company or of any third party, to prevent or stop any illegal, unethical, or legally actionable activity, or to comply with the law. This may include making a mandated report if we form a suspicion of child abuse or neglect.

Without the use of your information, we may not be able to provide you the products, services, or information you request.

Link to this section 5. How we will keep your information secured

As outlined above, we respect the privacy of you and your family. We will take reasonable steps to protect your personal information and will maintain robust security measures to protect your Personal Information from being subject to unauthorised access or misuse. This will include physical, electronic and procedural safeguards.

We will retain your information for a reasonable amount of time after you stop engaging with our Service. Thereafter, we will take reasonable steps to securely destroy or de-identify the personal information we hold about you.

You can ask for access to the personal information we hold about you by contacting us.

Link to this section 6. Cookies

We may use cookies (a small text file placed on your computer to identify your computer and web browser) and may use anonymous identifiers (a random string of characters that is used for the same purposes as a cookie). We may use cookies and other similar technologies to analyse use of and improve the Site and Services and as described in the ‘Advertising and Online Tracking’ Section of this Privacy Policy. Most web browsers are initially set up to accept cookies. You can reset your web browser to refuse all cookies or to indicate when a cookie is being sent, however, certain features of the Site or Services may not work if you delete or disable cookies. Some of our Service Providers (defined above) may use their own cookies, anonymous identifiers, or other tracking technology in connection with the services they perform on our behalf.

We may use Google Analytics on the Site and Services to analyse how users use the Site and Services, and to provide advertisements to you on other websites. For more information about how to opt out of having your information used by Google Analytics, visit https://tools.google.com/dlpage/gaoptout/.

Link to this section 7. Advertising and Online Tracking

We may allow third-party companies to serve ads and collect certain information when you visit the Site and Services. These companies may use certain information (e.g. click stream information, web browser type, time and date, subject of advertisements clicked or scrolled over) during your visits to the Site and other websites in order to provide advertisements about goods and services likely to be of interest to you. These companies typically use a cookie to collect this information. Our systems do not recognise browser “Do Not Track” signals, but several of our Service Providers who utilise these cookies on our Site enable you to opt out of targeted advertising practices. To learn more about these advertising practices or to opt out of this type of advertising, you can visit www.networkadvertising.org or www.aboutads.info/choices/. We also provide you with additional tools to opt out of marketing from us. You can learn about this in the ‘Managing Your Information Preferences’ section of this Privacy Policy.

Link to this section 8. Managing Your Information Preferences

You can opt out of receiving marketing e-mails from us by following the link provided at the bottom of all marketing e-mails you receive from us. You are able to opt out of receiving marketing e-mails from us, however, you cannot opt out of receiving all e-mails from us, such as e-mails about the status of your account.

Link to this section 9. Be Careful When You Share Information with Others

Please be aware that whenever you share information on any public area of the Site or Services, that information may be accessed by others. In addition, please remember that when you share information in any other communications with third parties, that information may be passed along or made public by others. This means that anyone with access to such information can potentially use it for any purpose, including sending unsolicited communications.

Link to this section 10. Security

We maintain physical, electronic, and procedural safeguards to protect the confidentiality and security of information transmitted to us. However, no data transmission over the Internet or other network can be guaranteed to be 100% secure. As a result, while we strive to protect information transmitted on or through the Site or Services, we cannot and do not guarantee the security of any information you transmit on or through the Site or Services, and you do so at your own risk.

Our Site and Services may contain links to other websites or allow others to send you such links. A link to a third party’s website does not mean that we endorse it or that we are affiliated with it. We do not exercise control over third-party websites. You access such third-party websites or content at your own risk. You should always read the privacy policy of a third-party website before providing any information to the website.

Link to this section 12. Overseas Transfers

Please be aware that your Personal Information and communications may be transferred to and maintained on servers or databases located outside of Australia. Please be advised that we may process and store information overseas, including in the United States

Link to this section 13. Privacy Policy Changes

We may change this Privacy Policy from time to time. If we decide to change this Privacy Policy, we will inform you by posting the revised Privacy Policy on the Site. Those changes will go into effect on the “Revised” date shown in the revised Privacy Policy. By continuing to use the Site or Services, you are consenting to the revised Privacy Policy.

Link to this section 14. Access and Correction

If you would like to access or correct your information in our records, please contact us on the contact information available on the Site. We will promptly respond to your request.

Link to this section 15. How to Contact Us / Complaints

If you have any questions regarding this privacy policy or concerns about the management of your personal information, you may contact us at the contact information available on the Site.

If you have a complaint, we will aim to investigate and resolve your complaint as soon as possible, usually within 30 days of receiving it. If you are not satisfied with our response, you may lodge a formal complaint with the Office of the Australian Information Commissioner (https://www.oaic.gov.au/)