Privacy Policy

BACKGROUND

CREATABLE PTY LTD ACN 637 852 441 (“us”, “our” or “we”) provides an online teacher professional learning platform, promoting equity and access to future skills for future jobs by sharing the innovation expertise of global industry partners (“Service”).  The Service is also inclusive of all other ancillary products and services provided by us from time to time.

Our collection, use and disclosure of personal information is governed by the Privacy Act 1988 (Cth) as amended from time to time (“Privacy Act”). This Privacy Policy describes how we collect, use and disclose your personal information in accordance with requirements of the Privacy Act and applies in respect of this website, our apps, and any of our content on social media sites (“Sites”) on any computer, mobile phone, tablet, console or other device (“Device”).  

The privacy of your personal information is really important to us so please take the time to read this Privacy Policy carefully.  This Privacy Policy is also to be read in conjunction with our Terms and Conditions.

CONSENT

Your consent to this Privacy Policy is the legal basis upon which we can collect, use, store, process and disclose your personal information.

You acknowledge and agree that:

• by registering for the Services and clicking on the “I Agree” field (or any similar field or link designated to indicate your acceptance of this Privacy Policy) and using our Services, you are consenting to providing us with your personal information and agree to your personal information being collected, stored, used, processed and disclosed in accordance with this Privacy Policy and the Terms of Use; 
• you have had a sufficient opportunity to access and review this Privacy Policy and you have read this Privacy Policy (in its entirety) and agreed to its terms; and
• you are 18 years of age or older.

If you do not wish to provide personal information to us, then you are not obliged to do so. However, please be aware that you will be unable to register for and access our Services without providing the minimum amount of personal information required in the registration process. You cannot register for our Services without agreeing to be bound by this Privacy Policy and Terms of Use.  

What information do we collect?

Personally Identifiable Information

We collect and use personal information from clients, customers, users or visitors of the Sites in connection with facilitating the Service.  The specific type of personal information that we collect and use will depend on the reasons for, or circumstances of its collection and may include, but is not limited to, the following:

• name and contact information (including telephone and mobile number, email address and residential and postal address);  
• individual information (including age, gender, race, ethnicity, place of birth, language(s) spoken, personality type, disabilities and photographic identification); 
• payment and transactional information (including banking, credit card and PayPal details);
• subject expertise, professional development focus, the name and location of your school, teaching experience and qualifications;
• company name and contact information (including ABN/ACN, business name, company contact, telephone and fax number, email address and registered, postal and business address); 
• other personal information (including information contained in communications between you and us, or forms or other documents provided to us by you and any information we are required to collect by law).  

We may also collect personal information as we reasonably determine necessary from time to time for any purpose in connection with the general conduct of our business, for example, in dealing with our agents, suppliers, service providers and contractors, internal business purposes or improving our Services. 

We only collect personal information which has been provided to us by you.  If you would prefer that we do not collect any personal information from you, please do not provide us with any such information.  However, please note that you may not be able to use the Service or the Sites if they depend on the collection of that personal information, including if the collection of that personal information is required by law or is required for the registration access to our Services.

Feedback and surveys 

From time to time you may have the option to participate in surveys or provide feedback intended to improve the Services offered by us which may involve providing additional personal information. Your participation in such activities is subject to your consent. 

Please be aware that we will not collect any personal information from any user of the Service under 18 years of age and all feedback obtained from these users will be gathered on an anonymous basis.

IP Addresses

An Internet Protocol (“IP”) address is a small set of numbers automatically assigned to your computer when you log onto the internet.  We may use general information about your visit to any of the Sites, including your IP address and the date and time of your visit, to assist us in improving the quality and useability of the Sites.  Typically, we will not link IP addresses with personal information, however, in rare instances we may need to link IP addresses to personal information if it becomes necessary to enforce compliance with the Terms and Conditions. 

Cookies

A cookie is a small data file that is placed on your computer or mobile device when you visit a website. Website owners widely use cookies in order to make their websites work, or to work more efficiently, as well as to provide reporting information. We use cookies to: 

• personalise your visit to any websites operated by us (as a cookie allows a web server to 'remember' visitors on subsequent visits without having to prompt them for information previously supplied. A cookie can also remember courses previously viewed by a site visitor);
• provide information about us to you while you browse; and
• obtain non-identifying information about your demographic group and general interests.

Additionally, when you use our Services, we may collect information about the location from which that use occurred (this will be in accordance with the settings of your particular device). This location data may be used by us for the purposes of personalising messaging and or offers. 

You may elect to disable cookies and/or geolocation sharing at any time. In such circumstances, you may still be able to utilise some of our Services (however, some functionality may be limited).

Use of personal information

We will only use your personal information for the purpose which it was collected or as otherwise in accordance with this Privacy Policy. Purposes for collecting personal information include, but are not limited to:

• providing you with use of and improving the Service;
• notifying you of opportunities (whether product, service, marketing, promotional or advertising related) that we think you may be interested in;
• responding to your enquiries;
• to identify you when you contact us; 
• processing payments you have authorised; and 
• any other purposes identified at the time of collecting your personal information

In addition, you permit us to use your personal information:

• where you have consented to the use or disclosure;
• where we reasonably believe that use or disclosure is necessary to lessen or prevent a serious, immediate threat to someone's health or safety or the public's health or safety;
• where we reasonably suspect that unlawful activity has been, is being or may be engaged in and the use or disclosure is a necessary part of our investigation or in reporting the matter to the relevant authorities;
• where such use or disclosure is required under or authorised by law (for example, to comply with a subpoena, a warrant or other order of a court or legal process);
• where we reasonably believe that use or disclosure is necessary for the prevention, investigation, prosecution and punishment of crimes or wrongdoings or the preparation for, or conduct of, proceedings before any court or tribunal (or the implementation of orders of a court or tribunal or on behalf of an enforcement body);
• to develop and improve our (and our related entities’) business, products and services;
• in servicing our relationship with you by creating and maintaining a customer profile or presenting options that we think may interest you based on your browsing and preferences and on your past use of the Services;
• to involve you in market research, gauging customer satisfaction and seeking feedback;
• to facilitate your participation in loyalty programs;
• for research and analysis in relation to our (and our related entities’) business, products and services; and
• for our internal accounting and administration.

Third Party Disclosure

By using our Services and/or by providing us with your personal information (or allowing another person to do so), you acknowledge and consent to us disclosing some or all of your personal information to third parties in accordance with this Privacy Policy and in accordance with local data protection laws. This includes disclosure of your personal information and details:

• to payment service providers for any payments you make via the Services (we use a third party payment service provider that is required to take reasonable steps to protect your information);
• to our partners, contractors, suppliers and service providers including without limitation:

1. our partners located domestically or abroad for the purpose of developing and improving the Services;
2. suppliers of IT based solutions that assist us in providing products and services to you;
3. distributors of electronic marketing and promotional communications;
4. marketing, market research, research and analysis and communications agencies; 
5. external business advisers;

to a person that uses the Services on your behalf and/or a person you have authorised; 

• in accordance with requirements or authorisations under applicable laws or to comply with our legal obligations; and
• to any other persons contemplated by this Privacy Policy.

From time to time, we may also provide summarised or aggregate, non-identifiable data to third parties for the purposes of:

• enhancing the services that we provide;
• creating summaries and insights with respect to usage of and interactions with the Services and our Sites; and
• analysing and reporting on trends (including comparisons as against historical activities).

We take reasonable steps to ensure that third party recipients are obliged to protect the privacy and security of your personal information and use it only for the purpose for which it is disclosed.

Occasionally, we may be required to disclose your personal information to third parties that are located outside of Australia.  In this instance, we will take all reasonable steps to ensure that those third parties, in whichever jurisdiction, adhere to the terms of this Privacy Policy.

To the maximum extent provided by the relevant laws, we are not responsible or liable for the protection and privacy of any personal information which is provided to third parties. This means that, where your personal information has been disclosed, you accept and agree that the disclosed personal information will be held by third parties and may be used by them in accordance with  the Privacy Act and any privacy policy they may have and in such circumstances, the third party recipient will be solely responsible for their use of this personal information.

Storage

We take all reasonable and lawful steps to keep personal information secure, accurate and up to date and only retain your personal information for as long as reasonably required to satisfy the purpose for which they were collected and used (unless a longer period is necessary for our legal obligations or to defend a legal claim). This means that:

• personal information is stored on secure servers in digital format;
• our employees and data processors are obliged to respect the confidentiality of any personal and/or sensitive information or data and receive training in personal information handling;
• we only permit authorised personnel to access your information; 
• we encrypt and anonymise personal information wherever possible; and
• we ensure all personal details are de-identified and transferred anonymously before any information, which is stored securely, is provided to external organisations for data analysis or disclosed to any third parties (except where that disclosure is directly contemplated by this Privacy Policy).

We will take reasonable steps to protect your personal information as you transmit your information from your electronic device to us and to protect such information from loss, misuse, and unauthorised access, use, modification, disclosure, alteration, or destruction. However, electronic transmission of information is never completely secure or error-free.  As a result, while we strive to protect users' personal information, we cannot ensure or warrant the security of any information electronically transmitted by a user, and users provide their personal information at their own risk. To the maximum extent provided by the relevant laws, we are not responsible or liable for the electronic transmission of personal information to us or to third parties.

Complaints

If you know of or suspect any violations of your privacy in connection with your use of the Sites and/or the Service, please contact us immediately via email at [email protected]

Other websites

The Services we operate may contain links to other websites ("Third Party Links"). We do not endorse such Third Party Links and are not responsible for any content contained therein. If you decide to access any Third Party Links, you do so entirely at your own risk.

Updates

We reserve the right to change, modify, add or remove portions of this Privacy Policy from time to time and without notice you. If we do so, we will post the revised policy here. Please note that the collection and use of your personal information will be governed by this Privacy Policy at the time of collection and use of the personal information. By continuing to use, access or browse any of the Sites following any changes to this Privacy Policy, you consent to those changes.

Contact

If at any time you:

• would like to access, correct or change any personal information provided to us by you;
• know of or suspect any violations of your privacy in connection with your use of the Sites and/or the Service; or 
• have any questions, comments or concerns about this Privacy Policy, please contact us via email at [email protected] and include in the subject line “To the Privacy Officer”. 

Further information

Should you wish to read more information on privacy legislation or the Australian Privacy Principles we recommend that you visit the web-site of the office of the Australian Information Commissioner at www.oaic.gov.au.