Privacy

Effective Date: 29/04/2019 Notice Version: 1.1

Data Controller Contact Information
Missing School Incorporated
PO Box 155, Jamison Centre,
Canberra ACT 2614 Australia
Ph: +61 2 5104 2466
Email: info@missingschool.org.au

Our commitment to protecting your privacy
This privacy policy applies to the collection, storage, use and disclosure of personal information by or on behalf of the Missing School Incorporated (ABN 77 164 124 450) (referred to in this policy as “Missing School”, “our”, “we” or “us”).

Please read it carefully
We intend to protect personal information provided to us, and ensure its privacy, accuracy and security. We handle personal information in a responsible manner in accordance with the Privacy Act 1988, and the Australian Privacy Principles (APPs). By using any of our services or products, visiting our website (https://missingschool.org.au) or giving us your or a student’s personal information, you agree to the information you provide being collected, stored, used and disclosed as set out in this Privacy Policy.

Definitions
“Personal information” means information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether true or not, and whether or not recorded in a material form. “Sensitive information” (a type of personal information), means information or an opinion about an individual’s race or ethnic origins, political opinions and associations, religious beliefs or affiliations, philosophical beliefs, sexual preferences or practices, trade or professional associations and memberships, union membership, criminal record, health or genetic information or biometric information. “Students” means school students who are recipients of our services, such as our telepresence robot service (also known as SEE-BE) for students who are missing school as a result of illness or injury.

Whose personal information do we collect?
We may collect personal information concerning you (or students for whom you are a parent, teacher, health or other service provider, guardian or carer) from a range of sources, including from you, their schools, teachers, medical practitioners, families or friends of students, referral agencies, affiliates, contractors, business partners, and government agencies. For example, we may collect personal information when you enquire about, request or acquire a service or product from us (such as our telepresence robot service), donate funds or provide other support for us and our objectives, provide a service or product to us, apply for employment with us or communicate with us via our website or social media sites, by e-mail, telephone or in writing. Wherever reasonable and practicable, we collect personal information from the individual to whom the information relates. If you provide personal information about someone other than yourself, you warrant and agree that you have that person’s consent to provide the information for the purpose for which you provide it to us. You also agree that you have told the person about this Privacy Policy and where to find it. If you provide personal information about a student to us, you warrant and agree that you are authorised to give consent on behalf of that student and, where the student has legal capacity to consent, that you have that student’s consent to provide the information for the purpose for which you provide it to us.

What types of personal information do we collect and hold?
The personal information we collect includes:

names, addresses, e-mail addresses, phone numbers, demographic information, information required for services, payment details, occupation, social media links, and other information to assist us in conducting our operations, providing and promoting our services and products;
information about volunteers, staff and directors, as required in the normal course of human resource management and the operation of a not-for-profit organisation; and
information about current and previous Missing School donors, suppliers, partners, referrers, affiliates, clients and supporters with whom Missing School has dealings.

We will only collect sensitive information: if you have consented to us doing so – for example, as part of information collected about students as part of health information collected for the purposes of providing the telepresence robot service or other services; about volunteers, directors and employees for corporate and human resource management purposes; or where required or permitted by law.

How do we collect personal information?
We only collect personal information by lawful and fair means. We usually collect personal information from:

telephone calls, face-to-face meetings, forms, interviews, correspondence, and Missing School online programs; business cards;
electronic communications – for example, e-mails and attachments; online forms filled out by people, including as part of enquiring about or acquiring a service or product from us; subscriptions to our eNewsletters or other promotional material;
third parties – for example, for students from schools, teachers or family members, referral agencies and your representatives or agents;
our website, our Facebook page and other social media sites, including if you use it to contact us, make a donation to us, or register for an event organised by us; and
we may collect personal information from entities that provide or resell our services.

Why do we collect personal information?
We collect the personal information:

necessary for us to provide you with the services and products you have requested from us, including to provide our telepresence robot service and any other services or programs;
for promotional purposes and to provide you with information about services and products that may be of interest to you;
for monitoring, evaluation and research purposes as part of our objectives;
to improve the services and products we provide;
so that we can meet our reporting obligations to Missing School’s funding bodies; and
to enable us to conduct our operations, including meeting our legal and regulatory obligations.

If you do not provide your personal information, we may not be able to supply the requested service or product, employ you, allow you to be a volunteer, or otherwise deal with you.

How we deal with unsolicited personal information?
If we receive personal information about you that we have not requested, and we determine that we could not have lawfully collected that information under the APPs had we asked for it, we will destroy or de-identify the information if it is lawful and reasonable to do so.

Do you have to disclose your identity when dealing with us?
Where lawful and practicable, we will give you the option of interacting with us anonymously or using a pseudonym. However, this may limit or inhibit our ability to provide our services or products.

Use of personal information
We only use your personal information for the purpose for which it was provided to us, for related purposes or as required or permitted by law. Such purposes include:

in the ordinary course of conducting our operations. For example, supplying products or services (such as our telepresence robot service), acquiring products and services, responding to your enquiries and feedback, preparing publications, and providing information about our events, news, publications and services and products that may be of interest to you;
market research, monitoring and evaluation purposes, preparing research and publications, and product and service development, so that we are able to better understand the needs of students’, their families, carers and schools and tailor our future products and services accordingly;
performing general administration, reporting and management functions. For example, invoicing and account management, payment processing, risk management, training, quality assurance and managing suppliers;
reporting to our funding bodies; partners, affiliates and government agencies;
employment-related purposes, such as recruiting and providing services to staff;
as part of a merger or transfer (or proposed merger or transfer) of all or part of our not-for-profit organisation or operations; and
other purposes related to or in connection with our operations, including meeting our legal and contractual obligations to third parties and for internal corporate governance.
Disclosure of personal information
We may disclose, and you consent to us disclosing, your personal information to third parties:
engaged by us to provide products or services (such as our telepresence robot service), or to undertake functions or activities, on our behalf. For example, processing payment information, managing databases, marketing, research and advertising;
that are authorised by you to receive information we hold;
that are our business or not-for-profit partners, joint venturers, partners or agents;
as part of a merger or transfer (or proposed merger or transfer) of all or part of our not-for-profit organisation or operations. For example, we may disclose information to our external advisers;
where necessary to meet our reporting obligations to our funding bodies, partners, affiliates, or government agencies;
such as our external advisers, and government agencies. For example, where disclosure is reasonably required to obtain advice, prepare legal proceedings or investigate suspected unlawful activity or serious misconduct; or
as required or permitted by law.

We may disclose, and you consent to us disclosing, your personal information to any of our related bodies corporate whether located in Australia or overseas. If we disclose your personal information to a related body corporate, your information will be collected, stored, used and disclosed in accordance with this Privacy Policy and the APPs.

Marketing use and disclosure
We may use and disclose your personal information (other than sensitive information) to provide you with information about our services and products that we consider may be of interest to you. You may opt out at any time if you do not, or no longer, wish to receive marketing and promotional material. You may do this by: contacting us via e-mail or in writing at the address below and requesting that we no longer send you marketing or promotional material; or where applicable, clicking the “Unsubscribe” button.

Use or disclosure of sensitive information
We will only use or disclose sensitive information about you or any student for the purpose for which it was initially collected or for a directly related purpose, as required or permitted by law, or where you consent to the use or disclosure.

Disclosure of personal information overseas
We do not disclose personal information to third parties outside Australia, unless required to provide products or services (such as our telepresence robot service) or as permitted by law.

How is my personal information kept secure?
We take reasonable steps to protect your personal information from misuse, interference, loss and unauthorised access, modification and disclosure. Such steps include: physical security over paper-based and electronic data storage and premises; computer and network security measures, including use of firewalls, password access and secure servers; restricting access to your personal information to volunteers and employees and those acting on our behalf who are authorised and on a ‘need to know’ basis; retaining your personal information for no longer than it is reasonably required, unless we are required by law to retain it for longer; and entering into confidentiality agreements with staff and third parties. Where we no longer require your personal information, including where we are no longer required by law to keep records relating to you, we will ensure that it is de-identified or destroyed. Any personal information recorded in paper-based form is only for temporary purposes when direct data entry into our secure database is not possible. These records are physically secured and securely destroyed as soon as practicable following being entered into our database.

Data quality
We take reasonable steps to ensure that your personal information is accurate, complete and up-to-date. However, we rely on you to advise us of any changes or corrections to the information we hold about you. If you consider that the information we hold about you is not accurate, complete or up-to-date, or if your information has changed, please let us know as soon as possible.

Access
You may request access to the personal information we hold about you by contacting us. We will respond to your request within a reasonable time. We will provide you with access to the information we hold about you unless otherwise permitted or required by law. If we deny you access to the information, we will notify you of the basis for the denial unless an exception applies. Where reasonable and practicable, we will provide access to the information we hold about you in the manner you request. No fee applies for requesting access to information we hold about you. However, we reserve the right to charge a reasonable fee where we do provide access.

Correction
If you believe that personal information, we hold about you is incorrect, incomplete or not current, you may request that we update or correct your information by contacting us. We will deal with your request within a reasonable time. If we do not agree with the corrections you have requested (for example, because we consider that the information is already accurate, up‑to‑date, complete, relevant and not misleading), we are not required to make the corrections. However, where we refuse to do so, we will give you a written notice setting out the reasons.

Policy regarding Use of Cookies, Google and Facebook etc services
Our Use of Cookies Our platform uses cookies. A cookie is a small piece of data or a text file that is downloaded to your computer or mobile device when you access certain websites or mobile apps. Cookies may contain text that can be read by the web server that delivered the cookie to you. The text contained in the cookie generally consists of a sequence of letters and numbers that uniquely identifies your computer or mobile device; it may contain other information as well.

By agreeing to accept our use of cookies you are giving us and the third parties with which we partner permission to place, store, and access some or all the cookies described below on your computer or mobile device.

Strictly Necessary Cookies
These cookies are necessary for proper functioning of our platform, such as displaying content, logging in, validating your session, responding to your request for our products or services, and other functions. Most web browsers can be set to disable the use of cookies. If you disable these cookies, you may not be able to access features on our platform correctly or at all.

Performance Cookies
These cookies collect information about the use of our platform, such as pages visited, traffic sources, users’ interests, content management, and other measurements.

Functional Cookies
These cookies enable our platform to remember users’ choices, such as their language, usernames, and other choices while using our platform. They can also be used to let a user create a blog post, listen to audios, or watch videos.

Media Cookies
These cookies can be used to improve our platform and provide special features and content. They can be placed by us or third parties who provide services to us.

Advertising or Targeting Cookies
These cookies are usually placed and used by advertising companies to develop a profile of your browsing interests and serve advertisements on other websites that are related to your interests. You will see less advertising if you disable these cookies.

Session Cookies
These cookies allow our platform to link the actions of a user during a browser session. They may be used for a variety of purposes, such as remembering what a user has put in their shopping cart as they use our platform. Session cookies also permit users to be recognised as they use our platform so that any item or page changes they make are remembered from page to page. Session cookies expire after a browser session; they are not stored long term.

Persistent Cookies
These cookies are stored on a user’s computer or mobile device between browser sessions, which allows the user’s preferences or actions across a website or across different websites to be remembered. Persistent cookies may be used for several purposes, including remembering users’ choices and preferences or to target advertising to them. We may also use cookies for:

identifying the areas of our platform that you have visited
personalising content that you see when using our platform
our analytics
remarketing our products or services to you
remembering your preferences, settings, and login details
targeted advertising and serving ads relevant to your interests
affiliate marketing
allowing you to post comments
allowing you to share content with social networks.

Most web browsers can be set to disable the use of cookies. However, if you disable cookies, you may not be able to access our platform correctly or at all.

Web Beacons
We may also use a technology called web beacons to collect general information about your use of our platform and your use of special promotions or newsletters. The information we collect by web beacons allows us to statistically monitor the number of people who open our emails. Web beacons also help us to understand the behaviour of our customers and users.

Google Ad and Content Network Privacy Notice
Third-party vendors, including Google, use cookies to serve ads based on a user’s past visits to our platform. Google’s use of cookies enables it and its partners to serve ads to our users based on their visits to our platform and/or other websites on the Internet. Users may opt out of the use of Google’s cookies for interest-based advertising by visiting http://www.aboutads.info/choices/ For European users visit http://www.youronlinechoices.eu

Google Analytics Privacy Notice
We use Google Analytics to collect information about the use of our platform. Google Analytics collects information from users such as age, gender, interests, demographics, how often they use our platform, what pages they visit, and what other websites they have used before using our platform. We use the information we get from Google Analytics to analyse traffic, improve our marketing, advertising, and our platform. Google Analytics collects only the IP address assigned to you on the date you use our platform, not your name or other identifying information. We do not combine the information collected using Google Analytics with personal information. Although Google Analytics plants a permanent cookie on your web browser to identify you as a unique user the next time you use our platform, the cookie cannot be used by anyone but Google. For more information on how Google collects and processes your data visit https://www.google.com/policies/privacy/partners/

You can prevent Google Analytics from using your information by opting out at this link: https://tools.google.com/dlpage/gaoptout

Google Remarketing
Our platform uses a remarketing advertising service. The remarketing service is provided by Google and other companies that show our ads on websites across the Internet. With remarketing you may see ads for our products you have previously looked at. As an example, suppose you visit a website that sells computers, but you do not buy a computer on your first visit. The website’s owner might like to encourage you to revisit his/her website and buy a computer by showing you his/her ads again on other websites that you visit. We use remarketing for similar purposes. For this to happen Google will read a cookie that is already in your browser, or place a cookie in your browser when you use our platform or other websites using remarketing. You can opt out of Google’s use of cookies and remarketing at this link: https://support.google.com/ads/answer/2662922?hl=en or you can opt out using the Network Advertising Initiative opt out page at: http://optout.networkadvertising.org/?c=1#!%2F Facebook Remarketing Third parties, including Facebook, may use first-party cookies, third-party cookies, web beacons, and other storage technologies to collect or receive information from our platform and elsewhere on the Internet, and use that information to provide measurement services and target ads. With Facebook remarketing you may see our ads on Facebook after you have used our platform. For this to happen Facebook uses unique cookies that are activated and placed in a visitor’s browser when they land on a webpage. To opt out of Facebook’s collection and use of information for ad targeting visit: https://www.facebook.com/help/568137493302217

Links to other websites and platforms
Our products and services (such as our telepresence robot service) may contain links to other websites and platforms. These websites and platforms are not under our control and are not subject to our privacy notice. These websites and platforms are subject to their own privacy notices. We have no responsibility for these websites and platforms. You acknowledge that your use of and access to these websites and platforms are solely at your risk. It is your responsibility to check the privacy notices of these websites and platforms to review how they treat your personal information.

Complaints
If you have a complaint in relation to the collection, storage, use or disclosure of your personal information, please contact our CEO using the details below. You will need to provide us with details of your complaint, as well as any supporting evidence and information. We will review all complaints received and our CEO will respond to you. If you are not satisfied with our response, you may discuss your concerns with or complain to the Australian Privacy Commissioner via www.oaic.gov.au.

Changes to this Privacy Policy
We reserve the right to revise this Privacy Policy or any part of it from time to time. Please review this Policy periodically for changes. Any revised policy will be placed on our website at https://missingschool.org.au/privacy. Your continued use of our website, services or products, requesting our assistance, or the provision of further personal information to us after this Privacy Policy has been revised, constitutes your acceptance of the revised Privacy Policy.

How to contact us:
If you have any questions about this Privacy Policy, please contact:
Post: CEO, Missing School Incorporated
PO Box 155, Jamison Centre,
Canberra ACT 2614 Australia
Ph: +61 2 5104 2466
Email: info@missingschool.org.au

Privacy

Effective Date: 29/04/2019 Notice Version: 1.1

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