Applies to This policy applies to Startech Solutions Pty Ltd, Imaginative Technology Solutions Pty Ltd and Kudos Knowledge Pty Ltd.
Effective date January 2016
Date of last review January 2016
“Customer” means any customer or purchaser of goods and services including schools and sporting clubs who are party to a signed Agreement with Startech, ITS or Kudos.
“End Users” means any student user, player user or other individual utilising the services and solutions provided by Startech, ITS or Kudos via an arrangement with the School, Sporting Club or other registered company to which they are enrolled, employed or associated. In the case of students under the legal consent age, End Users also includes the parent or legal guardian of that student.
“Affiliated Company” means any company or entity that controls, is controlled by or is under common control with a company and includes Ozecom Pty Ltd (operating under trading Name of Ozenco).
Purpose and Aims
This document outlines our policy on handling the personal information it collects about individuals including Customers, potential customers and End Users (collectively Customers and End Users are referred to in this Policy as “you” or “your”.
Startech, ITS and Kudos comply with all obligations regarding the collection, use and disclosure of Personal Information contained in applicable privacy laws and policy including the Privacy Act, relevant State or Territory legislation and any relevant Company policies and procedures. When we request personal information, we will normally explain why we need it, how it will be used and who we may share it with.
This policy answers the following questions about privacy at Startech, ITS and Kudos (collectively Startech, ITS and Kudos are referred to in this Policy as “we”, “us” and “our”):
- What types of personal information do we collect?
- Do we collect sensitive information?
- How do we collect personal information?
- What happens if you do not provide information that has been requested?
- Can you remain anonymous or use a pseudonym when dealing with us?
- How do we protect your personal information?
- Who do we share personal information with?
- How do we update personal information?
- How long will we keep your information?
- How can you find out about the personal information we hold about you?
- What should I do if I have any privacy concerns?
What types of personal information do we collect?
We may ask for a range of personal information to assist us in providing Customers and End Users with relevant services and solutions. The information we may request includes (but is not limited to) name, address, date of birth, contact details and social media account information.
Do we collect sensitive information?
We sometimes need to collect and use sensitive information. The Australian Privacy Principles set out restrictions about the way sensitive information can be used. Unless the Customer or End User gives us consent, or we are required or permitted by law to do so, we will only use or disclose sensitive information for the purposes for which it was provided.
How do we collect personal information?
We collect personal information directly from the Customer or End User where this is reasonable, appropriate and practical to do so.
For example, in relation to schools, we only gather personal information regarding students when consent from both the school and the parent or legal guardian of the student have been obtained. In relation to sporting clubs, we only gather personal information regarding players when consent from both the sporting club and the player user has been obtained.
Personal Information is gathered mainly through forms that the parent or legal guardian completes on behalf of the student or that the player user completes.
We only use personal information provided for the purposes of providing the services offered to our Customers and End Users.
With regards to our social media and cyber bullying programs, we use a combination of the personal information provided by Customers and End Users to connect to the publicly accessible Application Programming Interfaces (API’s) from social media platforms such as Twitter and Instagram. This personal information assists us in identifying each End User so we can identify and filter social media messages individual students and players are sending.
Using a set of rules / filters already programmed into our solution, we help students and players to make their own decisions regarding social media posts by applying filters to detect and flag messages and posts which could be considered inappropriate or offensive.
What happens if you do not provide the personal information that has been requested?
It is your choice as to whether to provide your personal information. However, if you choose not to, we will be unable to fulfil a request for a specific product or service.
Can you remain anonymous or use a pseudonym when dealing with us?
Due to the specific nature of the services and solutions offered by Startech, ITS and Kudos, if you wish to remain anonymous or to use a pseudonym when dealing with us, we will be unable to provide the Customer with services.
How do we protect your personal information?
Startech, ITS and Kudos store the personal information you provide in secure computer systems which can only be accessed by authorised officers. We use industry standard encryption technologies when transferring and receiving data. All data is stored on dedicated servers, located in Australia.
Startech, ITS and Kudos take a number of steps to protect personal information from misuse, loss, unauthorised access, modification or improper disclosure. This includes instructing Startech, ITS and Kudos staff who handle personal information to respect the confidentiality of Customer’s personal information and the privacy of individuals.
Who do we share personal information with?
From time to time we may share Customer personal information with other parties outside Startech, ITS and Kudos. The information that is shared may vary according to the product or service involved, and will only include:
- Specialist technology providers that may be engaged on a periodic consulting basis to assist us with technology services and whose engagement will be covered by strict confidentiality provisions protecting the use and handling of Customer and End User personal information;
- Courts, tribunals and other dispute resolution bodies in the course of a dispute
- Anyone authorised by the Customer or End User or to whom the Customer or End User has provided consent that we may need to deal with on the Customer’s or End User’s behalf;
- Anyone to whom we are required or authorised by law to disclose Customer or End User personal information (for example, law enforcement agencies, and national and international government and regulatory authorities);
- Our legal and financial advisers.
How do we update personal information?
We may periodically check with Customers and End Users to verify that the personal information held is current. The frequency and process for verifying this information will be agreed with the Customer prior to any requests being made.
How long will we keep your personal information?
We will store information only for as long as it is necessary to provide our services and solutions to our Customers and End Users. Once these products and services are no longer required, we will delete any records containing personal information entirely.
How do I find out about the personal information we hold about you?
Under the Privacy Act, you have the right to access the personal information we holds about you. To make a request please send an email to email@example.com
Startech, ITS and Kudos are permitted to refuse access to personal information in certain situations. Examples include where:
- Giving access would have an unreasonable impact on the privacy of other individuals;
- Giving access would be unlawful, or where denying access is required or authorised by an Australian law or a court order;
- We have reason to suspect that unlawful activity, or misconduct of a serious nature, that relates to Startech’s, ITS’s or Kudos’ functions or activities has been, is being or may be engaged in;
- Giving access would be likely to prejudice the taking of appropriate action in relation to the matter; and
- Giving access is likely to interfere with law enforcement activities.
Before providing the requested information we will give the Customer or End User an estimate of any potential costs associated with this, including expenses for locating, retrieving, reviewing and copying any of the material needed.
What should I do if I have any privacy concerns?
We take privacy-related complaints very seriously and consider all complaints carefully as part of our commitment to being open, honest and fair in dealing with Customer and End User concerns. In most cases, we will contact you within five working days of receiving a complaint to let you know what actions Startech, ITS or Kudos is taking regarding the matter.
To raise any concerns the Customer might have in relation to privacy, please contact us firstname.lastname@example.org