Privacy Policy

This Privacy Policy sets out our commitment to protecting the privacy of personal information provided to us, otherwise collected by us, offline or online, including through this website (Site). In this Privacy Policy we, us or our means Coassemble which is Coassemble Pty Ltd ABN 92 616 882 047. When we collect, store and use your personal information, we do so in accordance with the rules set down in the Australian Privacy Act 1988 (Cth) and, where applicable, by the European Union General Data Protection Regulation (EU) 2016/679 (the GDPR). Although the GDPR does not apply to our activities, we are committed to your privacy and we will provide you with the rights outlined in this Privacy Policy.

Personal information

The types of personal information or personal data we may collect about you include:

  • your name;
  • images of you;
  • your contact details, including email address, mailing address, street address and/or telephone number;
  • your demographic information, such as postcode;
  • your preferences and/or opinions;
  • information you provide to us through customer surveys;
  • details of products and services we have provided to you and/or that you have enquired about, and our response to you;
  • your browser session and geo-location data, device and network information, statistics on page views and sessions, acquisition sources, search queries and/or browsing behaviour;
  • information about your access and use of our Site, including through the use of Internet cookies, your communications with our Site, the type of browser you are using, the type of operating system you are using and the domain name of your Internet service provider;
  • additional personal information that you provide to us, directly or indirectly, through your use of our Site, associated applications, associated social media platforms and/or accounts from which you permit us to collect information; and
  • any other personal information requested by us and/or provided by you or a third party.

We may collect these types of personal information directly from you or from third parties.

Collection and use of personal information

We may collect, hold, use and disclose personal information for the following purposes:

  • to enable you to access and use our Site, associated applications and associated social media platforms;
  • to contact and communicate with you;
  • users of our website may have their mouse events and behaviour recorded for the sole purpose of optimising the Site;
  • for internal record keeping and administrative purposes;
  • for analytics, market research and business development, including to operate and improve our Site, associated applications and associated social media platforms;
  • to run competitions and/or offer additional benefits to you;
  • for advertising and marketing, including to send you promotional information about our products and services and information about third parties that we consider may be of interest to you;
  • to comply with our legal obligations and resolve any disputes that we may have; and
  • to consider your employment application.

Disclosure of personal information to third parties

We may disclose personal information to:

  • third party service providers for the purpose of enabling them to provide their services, including (without limitation) IT service providers, data storage, web-hosting and server providers, debt collectors, maintenance or problem-solving providers, marketing or advertising providers, professional advisors and payment systems operators;
  • our employees, contractors and/or related entities;
  • our existing or potential agents or business partners;
  • payment systems operators;
  • sponsors or promoters of any competition we run;
  • anyone to whom our business or assets (or any part of them) are, or may (in good faith) be, transferred;
  • credit reporting agencies, courts, tribunals and regulatory authorities, in the event you fail to pay for goods or services we have provided to you;
  • courts, tribunals, regulatory authorities and law enforcement officers, as required by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights;
  • third parties, including agents or sub-contractors, who assist us in providing information, products, services or direct marketing to you. This may include parties located, or that store data, outside of Australia including in the U.S.A.; and
  • third parties to collect and process data, such as Google Analytics or other relevant businesses. This may include parties that store data outside of Australia including in in the U.S.A.

Where we disclose your personal information to third parties, including data processors, we will request that the third party handle your personal information in accordance with this Privacy Policy. The third party will only process your personal information in accordance with written instructions from us. When we refer to ‘processing’ in this clause and this Privacy Policy in general, we mean any operation or set of operations which is performed on personal information, whether or not by automated means, such as collecting, recording, organising, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available personal information.

Please note that we use the following third parties to process your personal information:

  • Amazon Web Services (AWS EC2/S3, etc. located in Australia)
  • Intercom
  • Google Analytics
  • Appcues
  • Hubspot

By providing us with personal information, you consent to the disclosure of your personal information to third parties who reside outside Australia and, if you are a European Union (EU) citizen, to third parties that reside outside the EU. Where the disclosure of your personal information is solely subject to Australian privacy laws (and not subject to the GDPR), you acknowledge that we are not required to ensure that those third parties comply with Australian privacy laws.

How we treat personal information that is also sensitive information

Sensitive information is a sub-set of personal information that is given a higher level of protection under the Australian Privacy Principles. Sensitive information means information relating to your racial or ethnic origin, political opinions, religion, trade union or other professional associations or memberships, philosophical beliefs, sexual orientation, sexual practices or sex life, criminal records, health information or biometric information.

We will not collect sensitive information about you without first obtaining your consent.

Provided you consent, your sensitive information may only be used and disclosed for purposes relating to the primary purpose for which the sensitive information was collected.

Sensitive information may also be used or disclosed if required or authorised by law.

Fair and transparent processing

Your personal data will:

  • be processed lawfully, fairly and in a transparent manner by us;
  • only be collected for the specific purposes we have identified in the ‘collection and use of personal information’ clause above and personal information will not be further processed in a manner that is incompatible with the purposes we have identified;
  • be collected in a way that is adequate, relevant and limited to what is necessary in relation to the purpose for which the personal information is processed;
  • be kept up to date, where it is possible and within our control to do so (please let us know if you would like us to correct any of your personal information);
  • be kept in a form which permits us to identify you, but only for so long as necessary for the purposes for which the personal data was collected;
  • be processed securely and in a way that protects against unauthorised or unlawful processing and against accidental loss, destruction or damage.  

Specifically, we have the following measures in place, in accordance with the GDPR:

  • Data protection policies: We have internal policies in place which set out where and how we collect personal information, how it is stored and where it goes after we get it, in order to protect your personal information.
  • Right to ask us to erase your personal information: You may ask us to erase personal information we hold about you.
  • Right to ask us to restrict data processing: You may ask us to limit the processing of your personal information where you believe that the personal information we hold about you is wrong (to give us enough time to verify if the information needs to be changed), or where processing data is unlawful and you request us to restrict the processing of personal information rather than it being erased.
  • Notification of data breaches: We will comply with the GDPR in respect of any data breach.

Your rights and controlling your personal information

Choice and consent: Please read this Privacy Policy carefully. By providing personal information to us, you consent to us collecting, holding, using and disclosing your personal information in accordance with this Privacy Policy. If you are under 16 years of age, you must have; and warrant to the extent permitted by law to us that you have, your parent or legal guardian’s permission to access and use the Site and they (your parents or guardian) have consented to you providing us with your personal information. You do not have to provide personal information to us, however, if you do not, it may affect your use of this Site or the products and/or services offered on or through it.

Information from third parties: If we receive personal information about you from a third party, we will protect it as set out in this Privacy Policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have such person’s consent to provide the personal information to us.

Restrict: You may choose to restrict the collection or use of your personal information.  If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by contacting us using the details below. If you ask us to restrict how

we process your personal information, we will let you know how the restriction affects your use of our Site or products and services.

Access and data portability: You may request details of the personal information that we hold about you.  You may request a copy of the personal information we hold about you. Where possible, we will provide this information in CSV format or other easily readable machine format. You may request that we erase the personal information we hold about you at any time. You may also request that we transfer this personal information to another third party (data portability).

Correction: If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the details below. We will take reasonable steps to correct any information found to be inaccurate, incomplete, misleading or out of date.

Complaints: If you believe that we have breached the Australian Privacy Principles or an article of the GDPR and wish to make a complaint, please contact us using the details below and provide us with full details of the alleged breach. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint. You also have the right to contact the Office of the Australian Information Commissioner if you wish to make a complaint.

Unsubscribe: To unsubscribe from our e-mail database or opt-out of communications (including marketing communications), please contact us using the details below or opt-out using the opt-out facilities provided in the communication.

Storage and security

We are committed to ensuring that the personal information we collect is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures such as the pseudonymisation and encryption of personal information, to safeguard and secure personal information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.

We cannot guarantee the security of any information that is transmitted to or by us over the Internet. The transmission and exchange of information is carried out at your own risk. Although we take measures to safeguard against unauthorised disclosures of information, we cannot assure you that the personal information we collect will not be disclosed in a manner that is inconsistent with this Privacy Policy.

Cookies and web beacons

A cookie is a small text file which is placed on your Internet browser. As you browse, cookies gather information about your use of our website. We may access this cookie each time you visit our website to provide you with a better, more customised service and provide a more effective website.  We also use cookies for secure services (that is, an area where you are logged in to access) on our Site. These cookies are used for a variety of purposes, including for security, marketing and personalisation reasons. If and when you choose to provide our Site with personal information, this information may be linked to the data stored in the cookie.

Cookies are frequently used on websites and you can choose if and how a cookie will be accepted by configuring your preferences and options in your browser.  If your browser is configured to reject all cookies you may be unable to use secure services on our Site that require cookies in order to participate.

Accessing your cookie data does not allow use to collect personally identifiable information about you. The cookies are used for security, marketing and personalisation purposes including:

  1. a) To determine if you have previously visited our Site and remembering your settings/preferences;
  2. b) Tracking and reporting on website usage;
  3. c) Identifying other pages on third parties’ websites your browser has accessed;
  4. d) Personalising your experience, including your access to services that we provide on our Site, for example, providing customised content, support and advertising that may be relevant to your interests;
  5. e) Providing enhanced security and fraud detection.

We may use web beacons on our Site from time to time. Web beacons (also known as Clear GIFs) are small pieces of code placed on a web page to monitor the visitor’s behaviour and collect data about the visitor’s viewing of a web page. For example, web beacons can be used to count the users who visit a web page or to deliver a cookie to the browser of a visitor viewing that page.

We may use Sharable Content Object Reference Model (SCORM) standards to track resource usage.

We may use Google Analytics and Google Website Optimizer to collect and process data. To find out how Google uses data when you use third party websites or applications, please see: https://www.google.com/intl/en/policies/privacy/ or any other URL Google may use from time to time.

We may use Bitly to collect and process data. To find out how Bitly uses data when you use third party websites or applications, please see:

https://bitly.com/pages/privacy

We may use Intercom to collect and process data. To find out how Intercom uses data when you use third party websites or applications, please see:

https://www.intercom.com/terms-and-policies#privacy

We may use Hotjar to collect and process data. To find out how Hotjar uses data when you use third party websites or applications, please see:

https://www.hotjar.com/privacy

We may use Appcues to collect and process data. To find out how Appcues uses data when you use third party websites or applications, please see:

https://www.appcues.com/privacy

Advertising

We use advertising companies, for example Google, LinkedIn and Facebook to deliver online advertising where our advertisements are placed on Third Party websites.

When you view our advertisement on a third party website, the advertising company uses cookies to collect information such as:

  1. a) Your browser type
  2. b) The date and time of your visit; and
  3. c) The performance of their marketing efforts.

When you access our Site after viewing our advertisement on a third party website, the advertising company collects information on how you use the website, for example, which pages you view, and whether you complete a desired action, for example, an online enquiry.

We may also use cookies to tell you about things that be relevant to your interests.  You are able to opt out of the interest based cookies at any time. Additionally, we use Google Analytics to collect information on how you use our Site, using cookies to collect information similar to that collected by the advertising company.  You can opt out of your data being used by Google Analytics here: https://tools.google.com/dlpage/gaoptout/

The advertising companies and Coassemble use this information to perform statistical analysis of aggregate user behaviour, but this analysis is not based on personal information. We use this information to measure advertising effectiveness and relative consumer interest in the various areas of our Site.  No personal information is collected in this process.

SCORM and LTI tracking

Sharable Content Object Reference Model (SCORM) is a collection of standards and specifications for web-based electronic educational technology. It defines communications between client side content and a host system (called “the run-time environment”), which is commonly supported by a learning management system. SCORM also defines how content may be packaged into a transferable ZIP file called “Package Interchange Format”.  IMS Learning Tools Interoperability (LTI) is a standard set of specifications for allowing third party learning applications (or “tool providers”) to integrate with educational platforms (or “tool consumers”). Some of our plans provide access to shareable SCORM packages and support for sharing via LTI; we collect limited user data in order to track resource usage (within our service or via placement on 3rd party Learning Management Systems). Data collected can include: name, unique identifier, date/time of access and access URL.

Links to other websites

Our Site may contain links to other websites. We do not have any control over those websites and we are not responsible for the protection and privacy of any personal information which you provide whilst visiting those websites. Those websites are not governed by this Privacy Policy.

Amendments

We may, at any time and at our discretion, vary this Privacy Policy.  We will notify you if we amend this Privacy Policy, by contacting you through the contact details you have provided to us. Any amended Privacy Policy is effective once we notify you of the change.

For any questions or notices, please contact us at:

Coassemble Pty Ltd ABN 92 616 882 047

Our offices are located in Newcastle, Australia and you may contact us at any time on +61 448 224 544.

Last update: 12 April 2019

View our Terms of Service here.

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