<p>INTRODUCTION</p>
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<p>For customers based in Australia, the United States and other countries (not including the European Union, United Kingdom and New Zealand which are subject to separate privacy policies set out on this website), this Privacy Policy “We” “Us” “Compass” refers to Compass Education Pty Ltd, a company registered in Australia, having its registered office at Level 2, 36-38 Burwood Road, Hawthorn, Victoria, Australia 3122.</p>
<p>Compass respects your privacy and is committed to protecting your personal data.
This Privacy Policy will inform you as to how We look after your personal data where We collect your personal data from a third party or when you:</p>
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visit our websites at http://*.compass.education (the “Site”, our “Website(s)”, the “Compass Platform”), and all related web sites;</p>
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download software and/or mobile applications (including tablet applications);</p>
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use other services provided by us and on which a link to this Privacy Policy is displayed.
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where you communicate with Us in written or oral means, such as email or phone.</p>
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<p>When We use the word "Services" We mean the "compass.education" domain, all the other websites, products, services, provision of software, the Compass Platform and applications made available by Compass (for example, the Compass School Manager Android app available via the Android Marketplace, and the Compass School Manager App for iPhone and iPad on the Apple App Store).</p>
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<p>This Privacy Policy will also tell you about your privacy rights and how the law protects you.</p>
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<p>It is important that you read this Privacy Policy together with any other Privacy Policy or fair processing policy We may provide on specific occasions when We are collecting or processing personal data about you so that you are fully aware of how and why We are using your personal data.
This Privacy Policy supplements other notices and privacy policies and is not intended to override them.</p>1.
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Definitions<p>“Client” means a customer of Compass.</p>
<p>“Client Data” means personal data, reports, addresses and other files, folders or documentations in electronic form that a User or Client of the Services provides to us.</p>
<p>“Public Area” means the area of the Website, application or Compass Platform that can be accessed by both Users and Visitors, without needing to log in.</p>
<p>“Restricted Area” means the area of the Website, application or Compass Platform that can be accessed by Users only where they have logged in.</p>
<p>“User” means an employee, agent, student, parent, guardian or representative of a Client, who primarily uses the restricted areas of the Website, application or Compass Platform .
for the purpose of accessing the Services.</p>
<p>“Visitor” means an individual other than a User, who uses the Public Area, but has no access to the Restricted Areas of the Website, application or Compass Platform.</p>2.
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Our role2.1 .
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For most personal data collected through our Website(s) traffic, where you submit a request or query to directly to Us or where We market to you, We will be considered the holder of that personal data.2.2 .
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For most personal data within the Compass Platform, applications, or Website or where We provide services and online solutions to our Clients, access to the Compass Platform (and Services) is through a service agreement with our Clients. .
From time-to-time, We may also provide Services where We request information directly from you. 2.3 .
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If you have any questions as to your data or Compass account, you may email legal@compass.education.
Emails must include the URL of the service/portal you are using as well as your full name and account ID (username).3.
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The data we collect about you<p>Personal data, or personal information, means any information about a living individual from which that person can be identified.
It does not include data where the identity has been removed (anonymous data).</p>
<p> We may collect, use, store and transfer different kinds of personal data about you which We have grouped together below.
Processing and collection of data will differ depending on your status, for example parent, education professional or student.
some categories of data may not be collected with respect to parents or education professionals by Compass such as race or ethnicity, religious or philosophical beliefs, sex life, identity, information about your health, and genetic and biometric data.
The extent to which this data may be stored in Compass may vary based on the data collection policies of the education institution.
For more information on what data may be collected we recommend contacting the relevant education institution. </p>
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Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender, city, profile picture URL, unique identifiers.</p>
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Contact Data includes billing address, delivery address, email address and telephone numbers, geographic location.</p>
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Financial Data includes bank account and payment card details and billing information.</p>
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Transaction Data includes details about payments to and from you and other details of products and services you have purchased from Us.</p>
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Technical Data includes device data, internet protocol (IP) address or other device address or ID, your login data, browser type and version, details of the web pages visited just before or after using a Service, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.</p>
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Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.</p>
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Usage Data includes information about how you use our website, products and services.</p>
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Location Data includes information about your actual location.</p>
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Special Categories of Personal Data includes details about your race or ethnicity, religious or philosophical beliefs, sex life, identity, .
information about your health, and genetic and biometric.</p>
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Marketing and Communications Data includes your preferences in receiving marketing from Us and our third parties and your communication preferences.</p>
<p>We also collect, use and share aggregated data such as statistical or demographic data , however this is de-identified.
Aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity.
For example, We may aggregate your Usage Data to calculate the percentage of Users accessing a specific website feature.
However, if We combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, We treat the combined data as personal data which will be used in accordance with this Privacy Policy.</p>
<p>We do not provide areas within our platform designed to collect any information about criminal convictions and offences but may collect information in relation to court orders and directions. </p>
<p>Where We need to collect personal data by law, or under the terms of a contract We have with you, and you fail to provide that data when requested, We may not be able to perform the contract We have or are trying to enter into with you (for example, to provide you with access to the Compass Platform).
In this case, We may have to cancel a product or service you have with us but We will notify you if this is the case at the time.</p>4.
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How is your personal data collected?<p>We use different methods to collect personal data from and about you including through:</p>
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Direct interactions.
You may give us your personal data by filling in forms or by corresponding with us by post, phone, email or otherwise.
This includes personal data you provide when you:</p>
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apply for or use our products or Services;</p>
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create an account on our Website, Compass Platform or through our applications;</p>
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Post personal data on our Website, applications or the Compass Platform;</p>
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Interact through the applications, Compass Platform, our Website or with other Users (through communication or messaging capabilities);</p>
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subscribe to our service or publications;</p>
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use one of our self-service kiosks or POS terminals or services;</p>
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request marketing to be sent to you.
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give us feedback, make a customer service or helpdesk request or contact us.</p>
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Automated technologies or interactions.
As you interact with our Website, applications or the Compass Platform, We will automatically collect Technical Data about your equipment, browsing actions and patterns.
We collect this personal data by using cookies, “clear gifs”, “pixels”, “location services” or “beacons” and other similar technologies.
We may also receive Technical Data about you if you visit other websites employing our cookies.
Please see our Cookies Policy for further details.</p>
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Integrated Services.
You may be given the option to access or register for use of Services on the Website, Compass Platform or applications through the use of your username and passwords for certain services provided by third parties (each, an “Integrated Service”), such as through the use of your Google account, authentication provider, or otherwise have the option to authorise an Integrated Service to provide personal data or other information to Us.
You should check your privacy settings on each Integrated Service to understand what information that Integrated Service makes available to Us, and make changes as appropriate.
Please review each Integrated Service’s terms of use and privacy policies carefully before using their services and connecting to our Service.</p>
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Information collected through our Clients or Users.
A Client or User may store or upload information about you via the Website, applications or Compass Platform.
Compass does not necessarily hold a direct relationship with the individuals whose personal data it hosts as part of Client Data.
Each Client/User is responsible for ensuring it has the appropriate legal basis to process such information and is responsible for providing notice to its customers and third parties concerning the purpose for which Client/User collects their personal data and how this personal data is processed in or through the Service as part of Client Data.
This personal data may include Contact, Identity, Financial and Special Category Data.</p>
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Third parties or publicly available sources.
We may receive personal data about you from various third parties and public sources as set out below:</p>
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Technical Data from analytics providers such as Google who may be based outside of your service jurisdiction, advertising networks and search information providers.</p>
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Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Visa or MasterCard. </p>
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Contact, Financial and Transaction Data from credit rating agencies.</p>
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Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU or advertisers.</p>
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Other entities within the Compass group structure (“Compass Group”).</p>5.
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How we use your personal data<p>We will only use your personal data when the law allows us to.
Most commonly, We will use your personal data in the following circumstances:</p>
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Where We need to perform the contract We are about to enter into or have entered into with you or your school.</p>
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Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Legitimate interest means the interest of our business in conducting and managing our business to enable Us to give you the best service/product and the best and most secure experience.
We make sure We consider and balance any potential impact on you (both positive and negative) and your rights before We process your personal data for our legitimate interests.
We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
You can obtain further information about how We assess our legitimate interests against any potential impact on you in respect of specific activities by contacting Us at legal@compass.education</p>
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Where We need to comply with a legal obligation.
This means processing your personal data where it is necessary for compliance with a legal obligation that We are subject to.</p>
<p>Generally, We do not rely on consent as a legal basis for processing your personal data although We will get your consent before sending third party (non-company associated) direct marketing communications to you via email or text message.
You have the right to withdraw consent to marketing at any time by contacting Us.</p>
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<p>We have set out below, in a table format, a description of all the ways We plan to use your personal data, and which of the legal bases We rely on to do so.
We have also identified what our legitimate interests are where appropriate.</p>
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<p>Note that We may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your personal data.
Please contact us if you need details about the specific legal ground We are relying on to process your personal data where more than one ground has been set out in the table below.</p>
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