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Privacy Policy

Virtuoso (the Platform) is an online learning engagement platform developed and offered by Cinglevue International Pty Ltd (ABN 66 143 560 838) (Cinglevue, we, us or our). Schools, home schools, school districts and other educational institutions (Organisations) use the Platform to enhance learning, manage documents and to help with school administration. This Privacy Policy explains how and what of your personal information (including sensitive information) Cinglevue collects, uses, discloses and how we manage your personal information (sometimes called ‘personal data’) as a User of the Platform authorised by an Organisation or pursuant to a trial or other arrangement with us and/or as a Visitor to our website, cinglevue.com (Website).

We are bound by and adhere to the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs) under that Act (together, Privacy Act) and this Privacy Policy.

By using the Platform as a User, accessing the Website as a Visitor or providing any personal information whether via the Platform, the Website or otherwise to us, you agree and consent to Cinglevue (as operator of the Platform and Website) collecting, using and disclosing (sometimes referred to as ‘processing’) your personal information (including your sensitive information) in accordance with this Privacy Policy. By using the Platform as a User authorised by an Organisation you also agree and consent to your Organisation’s collection, use and disclosure of your Profile Information (as defined below) in accordance with your Organisation’s privacy policy.

By accessing the Platform as a User you also agree to and are bound by the Virtuoso Terms of Use.

Your consent to this Privacy Policy forms the ‘lawful basis’ on which we process your personal information. If you are a User aged 15 years or under you must refer this Privacy Policy to a parent/guardian and obtain their express consent to Cinglevue collecting, using and disclosing your personal information in accordance with this Privacy Policy prior to your access to the Platform and/or Website.

There is no obligation for you to provide us with any of your personal information but, if you choose not to provide us with your personal information, we will not be able to provide the information or services that you require.

What personal information is collected and how

For Users – Profile Information

As a User authorised by an Organisation, your Organisation may obtain (i.e. collect) your personal information via the Platform (when you type or upload it through the Platform’s user interface) depending on your relationship with the Organisation.

The Organisation may require that you provide to it the following personal information, whether directly or via the Platform (Profile Information):

  • as a Student of the Organisation, your full name, gender, date of birth, email address, residential address, phone number, country of birth, nationality, identities of your emergency contacts (i.e. your parents’/guardians’ name and personal contact details), classes/courses you are currently enrolled in, education history, academic results and interests. The Organisation may also collect sensitive information about you including your ethnicity, religion, whether you have special learning needs and medical information;
  • as the Parent of a Student of the Organisation, your full name, gender, email address, residential address and phone number; and
  • as a teacher or other staff member of the Organisation (Teacher), your full name, gender, email address, residential address and phone number. This Profile Information is collected, used and disclosed by the Organisation in accordance with the privacy policy of the Organisation. Cinglevue does not access your Profile Information.

For Users – Account Information

For all Users, Cinglevue collects (either directly from you or from your Organisation) personal information such as your full name, username and a photograph of you which becomes your profile picture on the Platform known as Account Information. We collect your personal information for the purpose of administering your account on the Platform. If we do not collect your Account Information directly from you, it is because your Organisation (where relevant) has created your account on Virtuoso for you.

For Visitors

As a Visitor, we collect your personal information when you provide it to us on the Website (i.e. entering information into a form or making an enquiry) and/or if you otherwise contact us by phone, email or mail. As a Visitor, we also collect information through the use of cookies in accordance with the Cookies section below.

For everyone

If you provide us with or request us to access (e.g. for maintenance or other support) the personal information of others you represent and warrant to us that: (i) you are authorised by that other person to provide their personal information to us; (ii) you have referred them to this Privacy Policy and obtained their express consent to Cinglevue collecting and disclosing their personal information in accordance with this Privacy Policy; and (iii) you have complied with the APPs in collecting that personal information.

How your personal information is used

For Users

As a User, we use the personal information we collect about you as Account Information for the purpose of operating the Platform, in particular to respond to your queries, process login issues and for other purposes as permitted or required by law.

If you are a User authorised by an Organisation, we do not use your personal information that is Profile Information which remains under the Organisation’s control. For information on how your Organisation uses your personal information, please check your Organisation’s privacy policy.

For Visitors

As a Visitor, we use the personal information we collect from you for the purpose of responding to your queries after you contact us and for other purposes as permitted or required by law.

For everyone

Occasionally, where Cinglevue helps with maintenance, support and troubleshooting of the Platform (e.g. for Organisations), we may have access to your personal information (including that in your Profile Information). However, we limit access to only those individuals who need to see or access that personal information to do their job and we do not keep records that contain any of the personal information so accessed.

How your personal information is shared

Generally, we host the data of the Organisation in the country in which they are located. However, a number of third party service providers support the functionality of the Platform and we may share your personal information with our third party service providers for them to assist us to perform one or more of the purposes set out in this Privacy Policy and, in particular Openbravo, S.L.U. whose software provides some of the Platform’s functionality.

The Platform also integrates, and by using the Platform you may be asked to provide personal information to, collaboration software provided by Cisco Systems, Inc. and its related entities, which facilitates certain functionality of the Platform. If you use Webex functionality on the Platform, please read Cisco Systems, Inc.’s privacy statement to learn about how it collects, uses and discloses your personal information.

Our third party service providers are located in Australia, Spain and the United States.

When we engage third party service providers to perform services for us as part of the Platform, those third parties may be required to handle your personal information. If such third party service providers are not ordinarily subject to the Privacy Act or a law with equivalent privacy protections and access (e.g. the EU General Data Protection Regulation), we ensure they take reasonable steps to safeguard your personal information, only use your personal information for the purposes for which it was supplied and we will take reasonable steps to ensure that such third parties are subject to or bound by the privacy obligations of the Privacy Act with respect to the protection of your personal information.

Pedagogical Research

Please note that Cinglevue may collate, extract and/or aggregate data from the Platform in de-identified form for the purposes of research. This is not personal information. If you would like to learn more about the use of de-identified data for these purposes, please read the Terms of Use on the Platform.

Marketing communications

We do not send marketing communications to Users. We may send marketing communications to Organisations and Visitors who give their prior consent to receive such communications.

These communications to Organisations and Visitors may be in various forms, including mail, telephone, SMS or via email in accordance with the Spam Act 2004 (Cth). If you indicated a preference for a method of communication we will endeavour to use that method to communicate with you whenever practicable to do so. If at any time you decide you no longer wish to receive marketing communications from us you may use the opt-out/unsubscribe facility option in our email or SMS or make a request not to receive marketing communications from us by contacting us using the details noted in the Contact Information section below, or by a request through the Website.

Security of your personal information

We take reasonable steps to protect your personal information from loss, misuse and interference and from unauthorised access, modification and disclosure. We encrypt your personal information when it is transmitted over the internet and, if you are a User with an account associated with an Organisation, your personal information is stored in a dedicated instance of Virtuoso and access to your personal information is limited to those who specifically need it to conduct their responsibilities and as authorised by the Organisation.

We also monitor our systems for possible vulnerabilities and cyber-attacks. We will notify you and supervisory authorities such as the Office of the Australian Information Commissioner (OAIC) of data breaches where required by law or otherwise as we feel appropriate.

We (and we require our third party service providers with whom we share your personal information to) take all reasonable steps to destroy or permanently de-identify your personal information where it is no longer required, once any legal obligation to retain it has expired.

However, our data protection measures are not a guarantee of the security of your personal information. You must also take care to protect your personal information. Please notify us as soon as possible if you become aware of any security breaches.

Updating and/or accessing your personal information

We take reasonable steps to ensure that your personal information that we hold is accurate, complete and up-to-date. To assist us to do this, please ensure you provide us with correct information and inform us whenever your personal information changes.

If you are a User and wish to access or update your Account Information, please contact us using the details noted in the Contact Information section below.

If you are a Visitor and wish to access or update your personal information that we hold about you, please contact us using the details noted in the Contact Information section below.

If we refuse to correct your personal information following a request by you to do so, then we will provide you with a written notice of the reason(s) for such refusal and the procedure to complain about our refusal. We will respond to any requests regarding the correction of your personal information so that it is accurate, complete and up-to-date within a reasonable period after a request is made. We will not charge you for any request to correct your information.

Where you request access to your personal information, we will respond to any such request within a reasonable period after the request is made. If we refuse to provide access to your personal information for any reason, we will provide you with a written notice of the reason(s) for such refusal and the procedure to complain about the refusal.
We may recover from you our reasonable costs of supplying you with access to your personal information, but we will not charge you for any request you might make to access your personal information.

If you are a User and wish to update or access your Profile Information, please contact your Organisation to update or access your Profile Information as this information is controlled by your Organisation not us.

Other Rights

As a User, you have certain rights over your Account Information that we hold. However, your Profile Information is under the control of your Organisation. Please consult your Organisation to understand what rights you have over your Profile Information held by your Organisation.

You have the right to request to access or update the personal information that we hold about you (i.e. Account Information, see the section on Updating and/or Accessing Your Personal Information above). However, we also provide the following entitlements, provided that we can reliably verify your identity. You can request, in relation to your Account Information, that we:

  • delete all the personal information that we hold about you;
  • restrict our processing of your personal information;
  • package up the personal information that we hold about you to send to you or some other person that you specify; and
  • in certain circumstances, stop processing your personal information (sometimes called the ‘right to object’).

To make any of these requests, please contact us using the details noted in the Contact Information section below.

To learn about your rights in relation to your Profile Information, please read your Organisation’s privacy policy and/or contact your Organisation.

Cookies

Information may be collected through the use of “cookies” on our Website and the Platform. Cookies are small text files that a website can use in order to recognise visitors who revisit a website so as to facilitate their ongoing access to and use of the site. They enable usage behaviour to be tracked and aggregate data to be compiled that would facilitate more targeted advertising and improved content. Typically, cookies involve the assigning of a unique number to the visitor. We use Google Analytics on the Website and the Platform to support authentication processes, measure traffic and the data can be used to tailor advertising of products and services that are more relevant to you. Google LLC has its own Privacy Policy which you can review here. You can prevent the use of cookies by setting up your web browser to block them.

Links on our Website

The Website may contain links to websites which are owned or operated by other parties. You should make your own enquiries as to the privacy policies of these parties/websites. We are not responsible for the information on, or the privacy practices of, such websites.

If you have a privacy complaint

We are committed to maintaining and protecting your privacy. If you wish to make a complaint please contact us using the contact information in the Contact Information section below.

Please provide us with sufficient detail regarding your complaint and any supporting evidence. We will notify you in writing if we require any additional information or otherwise of the outcome of our investigation of the complaint.

If your complaint is not satisfactorily resolved, you may refer your complaint to the OAIC at www.oaic.gov/about-us/contact-us.

Contact Information

Any queries about this Privacy Policy, correction or access requests or privacy complaints should be addressed to:

Dr. Michael Garrett
Privacy Officer
Cinglevue International

Address: Unit 22, 1 Walsh Loop, Joondalup
WA 6027, Australia

Email: privacy@cinglevue.com
Phone: +61 8 6202 0024

Changes to this Privacy Policy

We may, from time to time, update this Privacy Policy. We reserve the right to change our Privacy Policy at any time. You can find the date of the most recent review of this We may, from time to time, update this Privacy Policy. We reserve the right to change our Privacy Policy at any time. You can find the date of the most recent review of this policy at the end of the document. When we make material changes to this Privacy Policy we will highlight these in a banner on the Website and send a notification to Users by email or by way of a popup when you next login to Virtuoso.

Your continued use of the Platform and/or the Website, requesting our services or the provision by you of further personal information to us after this Privacy Policy has been revised will be deemed to be your acceptance of and consent to the revised Privacy Policy.

This Privacy Policy was last revised on 16 July 2020.

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