Data Champions Privacy Policy

  1. Purpose

    1. This Privacy Policy applies to Clever School Australia Pty Ltd ACN 673 480 432 (CSA).
    2. CSA is committed to complying with the Australian Privacy Principles as contained in the Privacy Act 1988 (Cth) (Privacy Act).
    3. This Privacy Policy is intended to provide a clear and concise summary of CSA's approach to the handling of personal information in accordance with the Australian Privacy Principles as contained in the Privacy Act.
    4. CSA's Privacy Policy appears on CSA's website at https://cleverschool.au/privacy (Website) and CSA will also provide a copy of this Privacy Policy free of charge to any person who requests it.

  2. Consent

    1. By using CSA's Website or any software, services or products offered by CSA, you will be deemed to have consented to CSA maintaining, using and disclosing your personal information in accordance with this Privacy Policy.

  3. What is personal information?

    1. Under the Privacy Act, personal information is defined to mean information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information or opinion is true or not, and whether the information or opinion is recorded in a material form or not.
    2. Personal information can include sensitive information. Sensitive information is defined as information or an opinion about a person's race, ethnic origin, political opinions, membership of political associations and trade associations, religious or philosophical beliefs, sexual orientation or practices, criminal record, health information, genetic information about an individual that is not otherwise health information, biometric information that is used for the purpose of automated biometric verification or biometric identification and biometric templates.

  4. Personal information that CSA collects and hold

    1. CSA generally collects personal information in the following ways:
      1. information that you give to CSA (for example through CSA's Website, via your use of software, via email or via telephone);
      2. information that CSA gets from your use of CSA's Website and software;
      3. information CSA receives from third parties, for example CSA's payment gateway service provider;
      4. publicly available sources;
      5. using cookies and similar technologies;
      6. when CSA is required to do so by any applicable law, regulation, legal process or governmental request (Law); and
      7. from CSA's own records.
    2. The types of personal information that CSA may collect and hold include:
      1. personal information, including your name and contact details including address, email address and telephone number;
      2. order information, including details of all products purchased by you;
      3. payment details to complete payment which may include details of credit cards, debit cards or any other method of payment;
      4. information that you provide when you register or create an account with us;
      5. information about your location at the time you use any of CSA's software or services;
      6. information about the device that you use to access CSA's software or services;
      7. other details about how or when you used any of CSA's software or services, or the services of any of CSA's customers;
      8. records of competitions or promotions you enter with CSA; and
      9. information from third party services to enable CSA to monitor and analyse web-traffic and can be used to keep track of Website user behaviour.
    3. CSA's server automatically records information your browser sends when it connects to a website. The information provided may include your Internet Protocol (IP) address and your browser type and language.
    4. CSA's Website may contain links to other third party websites which may collect your personal information. CSA cannot be held responsible for the privacy practices of other businesses. CSA encourages you to be aware and to read the privacy statements of each website which may collect your personal information.

  5. Cookies

    1. CSA may use cookies. A cookie is a small text file which may be placed on your Internet browser and which CSA accesses each time you visit a website. Without limitation, CSA may use cookies to:
      1. help the website to function correctly or to improve the usability, content or user experience of the website;
      2. monitor CSA's website's performance;
      3. improve security;
      4. build up a picture of the websites, products and services you prefer, so that CSA can then provide you with a personalised experience of the Website and provide you with recommendations, advertisements and information of interest to you;
      5. place advertisements for CSA's products on other external sites;
      6. monitor how CSA's marketing is performing.
    2. Most browsers automatically accept cookies, but you can usually modify your browser settings to decline cookies. You may delete or decline cookies by changing your browser settings. (Click “Help” in the toolbar of most browsers for instructions or review the cookie management guide produced by the Interactive Advertising Bureau – www.allaboutcookies.org). If you do so, some of the features and services of the site may not function properly.

  6. Analytics

    1. CSA may use Google Analytics or other similar tools to collect information about the use of its Website. These tools collect information about your visit to CSA's Website but do not collect your personal information.
    2. Analytics tools may use so-called "cookies". These are text files that are stored on your computer and that allow an analysis of the use of CSA's Website by you. The information generated by the cookie about your use of the Website is usually transmitted to another server which may be in the United States of America or in Europe and stored there.
    3. CSA may activate the IP anonymisation feature on its Website. Your IP address may be shortened by Google. In exceptional cases the full IP address may be sent to a Google server in the United States of America and shortened there. Google may use this information on behalf of CSA to evaluate your use of the website, to compile reports on website activity, and to provide other services regarding website activity and internet usage. The IP address is transmitted by your browser as part of Google Analytics.
    4. You can prevent these cookies being stored by selecting the appropriate settings in your browser. However, CSA wishes to point out that doing so may mean you will not be able to enjoy the full functionality of CSA's Website. You can also prevent the data generated by cookies about your use of the Website (including your IP address) from being passed to Google, and the processing of this data by Google, by downloading and installing the browser plugin available at: https://tools.google.com/dlpage/gaoptout?hl=en .
    5. CSA may enter into an agreement(s) with Google or others for the outsourcing of CSA's data processing.

  7. Use of your personal information

    1. CSA collects, holds and uses personal information in order to provide and improve its products and services. If CSA does not collect personal information, or the information provided is incomplete or inaccurate, CSA may not be able to deliver products or provide its services, or its services may be compromised.
    2. Personal information is also used for the following:
      1. promoting, marketing and advertising CSA's products and services;
      2. contacting you or communicating with you;
      3. to understand more about you, so that CSA can provide better products;
      4. managing and processing your inquiries and requests for contact and support;
      5. to improve CSA's products and services;
      6. to develop existing and new products;
      7. to advise you of information which may be of interest to you;
      8. providing your contact details to CSA's partners who have agreed to provide you with any offers, goods or services;
      9. displaying content from external platforms;
      10. managing support and contact requests;
      11. analytics;
      12. hosting and back-end infrastructure;
      13. to meet contractual obligations; and
      14. internal record keeping, management and administration.
    3. If you provide CSA with endorsements, we may use these (including any visual images you provide) to promote and advertise our business, services and products.

  8. Disclosure of your personal information

    1. CSA never sells any personal information.
    2. CSA may disclose your personal information to:
      1. CSA's related entities, including employees, agents and consultants of those related entities;
      2. personnel involved with the operation of CSA software, websites and similar including IT, administration, sales, marketing and system administration staff;
      3. lawyers, insurers and other professional advisers;
      4. CSA's service providers and contractors including third-party AI models, mail carriers, couriers, hosting providers, IT companies and communications agencies;
      5. CSA's agents, associates and business partners;
      6. to prospective or actual buyers in the event CSA sells its business or assets; or
      7. any person or entity to which we deem it necessary (in our sole discretion) for complying with any applicable Law.

  9. Access and correction

    1. Subject to any Law, upon receipt of a written request from you, we will inform you of the personal information we hold about you. If your request is particularly complex or requires detailed searching of our records, there may be a cost to you in order for CSA to provide this information.
    2. Individuals can request access to their personal information held by CSA by sending a written request to CSA's Privacy Officer via email at privacy@cleverschool.au .
    3. You can ask CSA's Privacy Officer to correct or update your personal information. CSA does not impose any charge with respect to requests for correction or updates.
    4. Before providing access to personal information, or correcting or updating personal information, CSA will require your identity to be confirmed.
    5. Requests for access or correction may be refused upon the grounds contained in the Privacy Act. If CSA refuses to provide access, or to correct or update personal information, CSA will provide you with reasons for the refusal. If CSA refuses to correct your personal information you have the right to associate with the information a statement that the information is inaccurate, out-of-date, incomplete, irrelevant or misleading. CSA will take such steps as are reasonable in the circumstances to associate that statement with all records CSA holds that contain the relevant information.

  10. Marketing and advertising

    1. CSA will never use or disclose any sensitive information for marketing or advertising purposes.
    2. CSA may use and disclose your personal information (other than sensitive information) to provide you with information about products or services offered by CSA or other companies or entities. You consent to receipt of direct marketing information, including by email or SMS.
    3. If at any time you do not wish to receive marketing communications from CSA or you do not want your personal information disclosed for marketing purposes, please contact CSA's Privacy Officer via email at privacy@cleverschool.au and CSA will remove your details from CSA's marketing database.

  11. Data integrity

    1. CSA endeavours to ensure that all personal information that CSA holds is accurate, complete and up-to-date. To assist CSA with this, you should contact CSA if any of your personal information changes, or if you believe that the personal information CSA holds is not accurate or complete.
    2. When personal information that CSA collects is no longer required by us, CSA will destroy or de-identify that personal information unless CSA is required by a court, tribunal or any Law to retain the personal information.
    3. CSA may retain personal information for so long as it is required for any of CSA's business purposes, for the prevention of fraud, for insurance and governance purposes and in CSA's IT back-up.

  12. Security

    1. While CSA will take reasonable steps to protect the personal information that CSA holds from misuse, loss, unauthorised access, modification or disclosure, you should be aware that no system is completely secure against cyber-attack.
    2. In addition, the open nature of the internet is such that information exchanged via the internet may be accessed and used by people other than those for whom the data is intended. Any information sent via the internet is sent at the sender's risk.
    3. You should contact CSA immediately if you believe that there has been unauthorised access or disclosure with respect to any personal information that CSA holds about you.

  13. Disclosure overseas

    1. CSA's servers are located in Sydney, Australia.
    2. CSA may have service providers and associated entities located in the United Kingdom and Europe.
    3. You consent to any disclosure of your personal information by CSA overseas on the understanding that if the overseas recipient handles the personal information in breach of the Australian Privacy Principles, the entity will not be accountable under the Privacy Act, and you will not be able to seek redress under the Privacy Act. The overseas recipient may not be subject to privacy obligations or to any principles similar to the Australian Privacy Principles. Individuals may not be able to seek redress in some overseas jurisdictions, and overseas recipients may be subject to a foreign law that could compel the disclosure of personal information to a third party, such as an overseas authority.

  14. De-identified data

    1. You consent to CSA using and disclosing your de-identified data (data that no longer identifies you) for any purpose, including without limitation research, statistical analysis, product development, marketing and business planning and any other commercial purpose. CSA undertakes technical measures to make sure that this data cannot be associated back to you.

  15. Notifiable data breaches

    1. CSA will notify you and the Office of the Australian Information Commissioner about any data breach that is likely to result in serious harm to you. There are exceptions where notification is not required, for example where CSA has already taken appropriate remedial action that removes the risk of serious harm to any individuals.

  16. Limitation of liability

    1. CSA is not liable for any direct, indirect, incidental, special, punitive or consequential loss (including but not limited to loss of data, income, profit or opportunity, loss of or damage to property and claims of third parties, death, personal injury or any loss, damage or expense) you incur or suffer that arises out of your access to, use of or reliance on CSA's Website or services or any of the content of the Website or your inability to use it. This applies even if CSA has been informed that the liability, loss, damage or expense will or may result.
    2. To the extent permissible by Law, CSA will not be liable to you or to any third party for any loss or damage or claim arising from CSA's collection and use of personal information in accordance with this Privacy Policy.
    3. Where liability is not able to be excluded by Law, CSA's liability to you in any circumstances will be limited, at CSA's choice, to re-performance of any services CSA has provided to you, payment for those services to be provided by a third party or payment of the sum of AUD $10.00 (Ten Australian Dollars).
    4. Nothing in this Privacy Policy affects your statutory rights, including those under the Competition and Consumer Act 2010 (Cth) and the Privacy Act. To the extent of any inconsistency between this Privacy Policy and your statutory rights under the Competition and Consumer Act 2010 (Cth) or the Privacy Act, your statutory rights under the Competition and Consumer Act 2010 (Cth) or the Privacy Act (as the case may be) will apply.

  17. Changes to this Privacy Policy

    1. This Privacy Policy may be amended from time to time. CSA will publish any updated versions of this Privacy Policy on the Website at privacy@cleverschool.au .
    2. By continuing to use CSA's Website, software or any CSA service, you will be deemed to have consented to any amended versions of this policy that are published on the Website.

  18. Effect of this Privacy Policy

    1. This Privacy Policy does not create any rights or obligations that you can legally enforce beyond the rights and obligations provided by the Australian Privacy Principles.

  19. Enquiries and complaints

    1. If you would like further information on our Privacy Policy, have any concerns over the protection of the information you have given to CSA or that CSA has collected from others, or wish to make a complaint relating to privacy, please contact CSA by email at privacy@cleverschool.au .
    2. If you make a complaint relating to privacy, CSA will do its best to ensure that an investigation is completed and a decision about your complaint is communicated to you within 30 days of CSA being advised of the complaint. CSA will inform you if it needs more time.
    3. If you are dissatisfied with CSA's response, you can take your complaint to the Office of the Australian Information Commissioner:

    20. Last updated: 4 March 2024.