The CyberPass

This document sets out the Privacy Policy for the Roar Educate (ACN 084 853 092) website, www.thecyberpass.com.

The key points

Roar Educate is committed to providing you with the best possible customer service experience whilst adhering to privacy and security laws relevant in each territory. The following provides a broad understanding of our commitment to your privacy and security.

Roar Educate is an elearning company that produces and distributes online learning and training resources, including CyberPass. Roar Educate is committed to protecting the safety and security of its users. The personal data we collect is name, email, postcode, unique username and password. In addition, for each student or child you register with CyberPass we require their name, age and classroom, username and password. This information is necessary to collect for the purpose of;

Providing access to the full functionality of the CyberPass website
Direct marketing (an opt-in option is available at sign up if you wish to receive marketing updates). But note that marketing will never be sent to holders of student accounts
Complying with legal obligations
Responding to account user queries
Undertaking statistical analysis and the general management of the business

In addition to the personal information provided by you, we collect information using cookies in order to provide a streamlined and efficient online experience and service. The collection of cookies can be modified by your browser settings however this may affect website performance and the user experience.

We do not provide your personal data to any third party except for the explicit purpose of delivering the service. We do not provide any personal data to third parties for the purpose of marketing.

As Roar Educate distributes its resources across multiple international territories, this policy has been developed to meet privacy legislations across arrange of territories, including;

The Australian Privacy Act 1988
The New Zealand Privacy Act 1993
The United Kingdom Data Protection Act 1998
The United States Children’s Online Privacy Protection Act and Rule
The United States Family Educational Rights and Privacy Act
The Alberta Freedom of Information and Protection of Privacy Act
The Canadian Personal Information Protection and Electronic Documents Act
The Freedom of Information and Protection of Privacy Act (British Columbia)
The Personal Information International Disclosure Protection Act (Nova Scotia)
The Municipal Freedom of Information and Protection of Privacy Act (Ontario)
The Student Online Personal Information Protection Act (California)
The EU General Data Protection Regulation

Personal information we collect

For access to site content and functionality as well as customer support features you are required to submit personally identifiable information. This includes your name, email, postcode, unique username and password. In addition, for each student or child you register with CyberPass we require their name, age and classroom, username and password.

Why we collect personal data and what we use it for

This information is necessary to collect for the purpose of;

Providing access to the full functionality of the CyberPass website
Complying with legal obligations
Responding to account user queries
Undertaking statistical analysis and the general management of the business

Please note that links provided within CyberPass that lead to third party websites (not controlled by Roar Educate) are not covered by this Privacy Policy.

For each visitor to reach the site, we collect the following non-personally identifiable information, including but not limited to browser type, version and language, operating system, pages viewed while browsing the Site, page access times and referring website address. This collected information is used solely by Roar Educate for the purpose of gauging visitor traffic, trends and delivering personalised content to you while you are at this site.

From time to time, we may use customer information for new, unanticipated uses not previously disclosed in our privacy notice. If our information practices change at some time in the future we will use for these new purposes only, data collected from the time of the policy change forward will adhere to our updated practices.

How we collect your personal information

The personal information we collect is provided by;

The user (you) directly, or
The school or education institution, however the teacher and/or administrator providing student information must ensure they have explicit consent from all users (students, teachers, staff) prior to providing their personal details, or
Parents of children who consent to their child’s information being provided.

Sharing of your personal information

We may occasionally hire other companies to provide services on our behalf, including but not limited to handling customer support enquiries or processing transactions. Those companies will be permitted to obtain only the personal information they need to deliver the service. Roar Educate takes reasonable steps to ensure that these organisations are bound by confidentiality and privacy obligations in relation to the protection of your personal information.

How long we hold your information

Your data is held for as long as it is necessary to meet our requirement to provide you with the service. We will hold this information for 12 months after the expiry of your registration in case you re-register. After twelve months your personal data will be deleted from our system.

We may however retain and use personal information as necessary to comply with our legal and regulatory obligations, to resolve disputes and to enforce our agreements, and we may retain and use anonymous and aggregated information for performance reporting, benchmarking and analytic purposes and for product and service improvement.

Registrants can request that their personal information be deleted by contacting the Roar Educate Data Protection Officer (contact details below). Data will be deleted after 31 days.

Accessing your personal information

Whilst all information provided by you is available via your Account Management settings, you have a right to request Roar Educate provide access to your personal information, subject to exceptions allowed by law. If you would like to do so, please let us know by contacting the Roar Educate Data Protection Officer (contact details below).

You may be required to put your request in writing for security reasons. Roar Educate reserves the right to charge a fee for searching for, and providing access to, your information on a per request basis.

Keeping your personal information secure

Roar Educate has implemented technical, administrative and physical security measures to protect personal information from unauthorised access, disclosure, use and modification. As part of our privacy compliance processes we review these security procedures on a regular basis.

We provide our personnel with training about data security and privacy, and we require all our employees and contractors to comply with this Privacy Policy and their obligations of confidentiality. We will take appropriate actions to address breaches by employees and contractors of the obligations imposed by this Privacy Policy.

Data transfers, storage and processing globally

Registrants’ personal information is uploaded to and stored on servers that are maintained by third parties that comply with strict contractual privacy obligations.

As we operate globally, we may on occasion allow your personal information to be accessed in countries other than your own location. We may do this where data is accessed:

by our sales, operational or customer support teams (primarily, although not exclusively, located in Australia); or
where a copy is sent to the Registrant itself at their request.

By consenting to the collection and use of their personal information, Registrants’ consent to their personal information being transferred and stored in this manner.

Anonymous or aggregated information

In addition to personal information and results data, Roar Educate also collects anonymous information about users and the activities of users on the site. Anonymous information is information that is not linked to the name or identity of a user. This information is used for educational performance reporting and analytics and to assist us in enhancing the learning resources. The information remains anonymous at all times.

When agreeing to the Term and Conditions, Registrants grant us the right to use this anonymous information for our own purposes, such as the preparation of statistical reports or to change the content of our products.

Cookies

A cookie is a little piece of information handed to a web browser from a web server that contains information that can be retrieved from the server later. When you visit the site the server may attach a cookie to your computer’s memory. Roar Educate uses cookies only to the limited extent to recognise the Registrant when they visit the Site and pairing that Registrant with the account (and account preferences) that the Registrant created. We use cookies to better display our website, to save you time, to provide better technical support and to track website usage. For example, cookies help us to:

Keep track of whether you are signed in or have previously signed in so that we can display all the features that are available to you;
Remember your settings on the pages you visit, so that we can display your preferred content the next time you visit;
Customise the function and appearance of the pages you visit based on information relating to your account; for example, in order to default you to a particular grade level, or to remember customised settings for a report.

However, this information is not linked to any personal information that Registrant may provide and cannot be used to identify Registrants.

Changes to this Privacy Policy

Roar Educate reserves the right to make amendments to this Privacy Policy at any time. Changes in our Privacy Policy will be communicated to Registered Users and customers, but we also encourage our Registrants to check the Privacy Policy periodically to read about any changes, modifications, or revisions. Registrants may wish to check it each time they submit personal information. You will be deemed to have consented to such variation by your continued use of the Site following any changes being made.

If you have objections to the Privacy Policy, you should not access or use the Site.

Special Information for users in the European Union

Roar Educate welcomes the EU General Data Protection Regulation (GDPR) as an essential set of regulations to affirm our commitment to data protection across the European Union. We are committed to ensuring:

Personal data is processed fairly, lawfully and in a transparent manner
Personal data is collected and processed only for specified and lawful purposes
Processed data is adequate, relevant and not excessive
Processed data is accurate and, where necessary, kept up to date
Personal data is not kept longer than necessary
Personal data is processed in accordance with an individual’s rights
Personal data is kept secure
Personal data is not transferred to countries outside of the EU without adequate protection

The information below should be read in addition to our Privacy Policy, and outlines specific information relevant to certain aspects of our GDPR compliance. Roar Educate Pty Ltd is a company registered in Australia with ACN 084 853 092 and Roar Educate Ltd is a company registered in England and Wales with company registration no. 06682995

Lawfulness of processing: Please refer to the “Personal information we collect” and “Why we collect personal data and what we use it for” sections of this Privacy Policy.

Is personal information transferred outside of the European Union? Yes, personal information in relation to Registered Users and customers located in the EU may be transferred outside of the EU. User data is uploaded to and stored on our servers located in Singapore and Australia.

Contacting us

Roar Educate welcomes your comments regarding this Privacy Policy. If you have any questions about this Privacy Policy and would like further information, please contact us by any of the following means during business hours Monday to Friday.

Call: +61 3 6224 5222

Email: privacy@roareducate.com.au

Post: Attn: Data Protection Officer, Roar Educate, Suite 340, 77 Salamanca Place, Hobart, TAS 7000, Australia