Privacy Policy

We at Proficiency Education have created this Privacy Policy to describe our practices regarding information we collect through our websites, mobile features, applications and any other interactive features or services owned or controlled by Proficiency Education that post a link to this Privacy Policy (each, a "Service" and collectively, the "Services"), as well as any information we collect offline and combine in our databases.

Certain features discussed in this Privacy Policy may not be offered on each Service at any particular time or may not be available in certain regions.

Note that we combine the information we collect through all of our websites, mobile applications, and other Services.

Note about Children: Our Services are general-audience in nature and are not intended for individuals younger than the age of 12.

SCOPE

This Privacy Policy applies to personal information processed by us in our business through our Services.

I. PERSONAL INFORMATION WE COLLECT

The categories of personal information we collect depend on whether you are a customer, user, applicant or visitor, and the requirements of applicable law.

Information You Provide to Us.

Account Creation.
When you create a user account, we collect your name, email address, username, and password and we may ask you to optionally provide demographic or other information such as your school, gender, age or birthdate, zip code, and information about your interests and preferences.

Profile Creation.
You may have the opportunity to create a profile which may include photographs, information about your academic and work history, and your interests and activities.

Your Communications with Us.
We collect personal information from you such as email address, phone number, or mailing address when you request information about our Services, register for our newsletter or loyalty program, request customer or technical support, apply for a job, or otherwise communicate with us.

Communications with Others on Our Platforms.
The Services may allow community members to communicate and collaborate with each other, including some Services that allow community members to engage in one-on-one communication using a video chat or text chat feature. Our servers may record, and we may retain records of the content of any such user-to-user communications.

Payment and Financial Information.
We will process your payment information if you purchase products or services through our Services. Note that we do not store payment credit or debit card numbers.

If you utilize the Services in a way that necessitates payment from Proficiency Education to you (such as offering services for sale through Proficiency Education or participating in research projects), we may collect additional information from you, such as your bank account information, social security number, social insurance number, or taxpayer identification number, as necessary to facilitate payment and to comply with related legal obligations.

Surveys.
We may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information which may include personal information.

Social Media Content.
We may offer forums, blogs, or social media pages. Any content you provide on these channels will be considered “public” and is not subject to privacy protections.

Information Collected Automatically or From Others

Automatic Data Collection.
We may collect certain information automatically when you use the Services including your Internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, details about your browser, operating system or device, location information, Internet or mobile service provider, pages that you visit before, during and after using the Services, information about the links you click, and other information about how you use the Services, including information collected from interactive services (including our e-Reader), such as notes you take and engagement during study sessions.

In addition, we may automatically collect data regarding your use of our Services, such as the types of content you interact with and the frequency and duration of your activities. We may combine your information with information that other people provide when they use our Services, including information about you when they tag you.

Cookies, Pixel Tags/Web Beacons, Analytics Information, and Interest-Based Advertising technologies.
We, as well as third parties that provide content, advertising, or other functionality on the Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through the Services. Technologies are essentially small data files placed on your computer, tablet, mobile phone, or other devices that allow us and our partners to record certain pieces of information whenever you visit or interact with our Services. We use the following types of Technologies:

· Cookies.
Cookies are small text files placed in visitors’ computer browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Services may not work properly.

· Pixel Tags/Web Beacons.
A pixel tag (also known as a web beacon) is a piece of code embedded in the Services that collects information about users’ engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement.

· Embedded Scripts.
Embedded scripts are programming code designed to collect information about your interactions with the Services, such as the links you click on. The code is temporarily downloaded onto your computer or other device from our server or a third-party service provider and is deactivated or deleted when you disconnect from the Services.

· Flash & HTML5.
We use Local Storage Objects (“LSOs”) such as HTML5 to store content, information, and preferences. Third parties with whom we partner to provide certain features on our site or to display advertising based upon your Web browsing activity use LSOs such as HTML 5 & Flash to collect and store information. Various browsers may offer their own management tools for removing HTML5 LSOs.

Our uses of these Technologies fall into the following general categories:

· Strictly necessary.
These cookies are strictly necessary to provide you with services available through our Websites and to use some of its features, such as access to secure areas. These include cookies that ensure security, prevent fraud, and debug where your data can be used to monitor for and prevent fraudulent activity, and ensure systems and processes work properly and securely and that technically deliver ads or content so your device can receive and send information that allows you to see and interact with ads and content.

· Store and/or access information on a device.
Cookies, device identifiers, or other information can be stored or accessed on your device for the purposes presented to you.

· Personalized ads and ad measurement.
Ads can be shown to you based on the content you’re viewing, the app you’re using, your approximate location, or your device type. A profile can be built about you and your interests to show you personalized ads that are relevant to you. The performance and effectiveness of ads that you see or interact with can be measured.

· Personalized content, content measurement, audience insights, and product development.
A profile can be built about you and your interests to show you personalized content that is relevant to you. The performance and effectiveness of content that you see or interact with can be measured. Market research can be used to learn more about the audiences who visit sites/apps and view ads. Your data can be used to improve existing systems and software, and to develop new products.

· Precise geolocation data, and identification through device scanning.
Data from offline data sources can be combined with your online activity in support of one or more purposes. Different devices can be determined as belonging to you or your household in support of one or more of purposes.

Information from Other Sources.
We may obtain information about you from other sources, including through third-party services and organizations to supplement information provided by you. For example, if you access our Services through a third-party application, such as an app store, a third-party login service, or a social networking site or you log in to a third party’s service using your Proficiency Education credentials, we may collect information about you from that third-party application that you have made public via your privacy settings. Information we collect through these services may include your name, your user identification number, your user name, location, gender, birth date, email address or other contact information, profile picture, activities such as test completion and results, and your contacts stored in that service. This supplemental information allows us to verify information that you have provided to us and to enhance our ability to provide you with information about our business, products, and Services

Analytics.
We may also use Google Analytics and other service providers to collect information regarding visitor behavior and visitor demographics on our Services. For more information about Google Analytics, please click here. You can opt out of Google’s collection and processing of data generated by your use of the Services by clicking here.

II. HOW WE USE YOUR INFORMATION.

We use your information for a variety of business purposes, including to:

Fulfil our contract with you and provide you with our Services, such as:

· Managing your information and accounts;

· Providing access to certain areas, functionalities, and features of our Services including providing access to eBooks;

· Support the shipping, tracking and recovery of your orders (such as textbooks) and/or other products;

· Communicating with you about your account, activities on our Services and policy changes;

· Undertaking activities to verify or maintain the quality or safety of a service or device;

· Processing your financial information and other payment methods for products or Services purchased;

· Providing advertising, analytics and marketing services (including to business partners). Through our Terms of Use, you agree that Proficiency Education may use your name and profile picture in connection with social ads to advertise products and services to your network based on your use of the Services and your interactions with Proficiency Education and third parties through the Services;

· Processing transactions and applications; and

· Allowing you to register for events.

Analyze and improve our Services pursuant to our legitimate interest, such as:

· Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;

· Measuring interest and engagement in our Services and short-term, transient use, such as contextual customization of ads;

· Undertaking research for technological development and demonstration;

· Researching and developing products, services, marketing or security procedures to improve their performance, resilience, reliability or efficiency;

· Improving, upgrading, or enhancing our Services or device;

· Developing new products and Services;

· Ensuring internal quality control;

· Verifying your identity and preventing fraud;

· Debugging to identify and repair errors that impair existing intended functionality;

· Enforcing our terms and policies; and

· Complying with our legal obligations, protecting your vital interest, or as may be required for the public good.

Provide you with additional content and Services, such as:

· Furnishing you with customized materials about offers, products, and Services that may be of interest, including new content or Services;

· Auditing relating to interactions, transactions, and other compliance activities; and

· Other purposes you consent to, are notified of, or are disclosed when you provide personal information.

Automated profiling.
We may use technologies considered automated decision making or profiling. We will not make automated decisions about you that would significantly affect you, unless such a decision is necessary as part of a contract we have with you, we have your consent, or we are permitted by law to use such technology. You may escalate any concerns you have by contacting us below.

Use De-identified and Aggregated Information.
We may use personal information and other data about you to create de-identified and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access our Services, or other analyses we create.

Testimonials.
We display personal testimonials of satisfied customers on our Services in addition to other endorsements. With your consent we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us at privacy@proed.com.au.

Cross-Device Tracking.
Your browsing activity may be tracked across different websites and different devices or apps. For example, we may attempt to match your browsing activity on your mobile device with your browsing activity on your laptop. To do this our technology partners may share data, such as your browsing patterns, geo-location, and device identifiers, and will match the information of the browser and devices that appear to be used by the same person.

Notice Regarding Third-Party Websites.
The Services may contain links to other websites, and other websites may reference or link to our website or other Services. These other websites are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen, or approve and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.

Social Media and Other Publicly Accessible Forums.
Our Services may include publicly accessible blogs, forums, social media pages, and private messaging features. By using such Services, you assume the risk that the personal information provided by you may be viewed and used by third parties for any number of purposes. In addition, social media buttons such as Facebook, Instagram, YouTube, Twitter, Pinterest, and LinkedIn (that might include widgets such as the “share this” button or other interactive mini-programs) may be on our site. These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. These social media features are either hosted by a third party or hosted directly on our site. Your interactions with these features apart from your visit to our site are governed by the privacy policy of the company providing it.

APIs and SDKs.
We may use third-party application programming interfaces (“APIs”) and software development kits (“SDKs”) as part of the functionality of our Services. APIs and SDKs may allow third parties including analytics and advertising partners to collect your personal information for various purposes including to provide analytics services and content that is more relevant to you. For more information about our use of APIs and SDKs, please contact us as set forth below.

III. DISCLOSING YOUR INFORMATION TO THIRD PARTIES.

Except as provided below, we do not share/disclose/sell your personal information. For lists of categories of personal information disclosed for a business purpose or sold in the last 12 months, please see below.

We do not share your Personal Information with third parties for their marketing purposes without your consent.

We may share non-Personal Information (such as aggregate user statistics, de-identified information, demographic information such as gender, age, graduation years, and other scholastic-related information), and Usage Information with third parties, including advertisers, content providers, and analytics providers; and third parties may collect non-Personal Information when you visit the Services.

When You Request That We Share Your Information.
We may offer opportunities and features through the Services that are brought to you by a third party or that otherwise involve sharing your information with a third party. If you request, direct us or agree at that time to have your information shared, your information will be disclosed to that third party (or parties) and will be subject to the privacy policy and practices of that third party. This includes, without limitation, instances in which you use our Services to purchase products or services provided, in whole or part, by third parties. You also may request, sometimes through your use of an interactive feature or social media feature, that we share information about you with a third party or publicly.

Sweepstakes, Contests and Promotions.
We may offer sweepstakes, contests, and other promotions ("Promotion") that may require registration. By participating in a Promotion, you are agreeing to governing terms, conditions or official rules, which may contain specific requirements of you, including allowing the sponsor(s) of the Promotion to use your name, voice, likeness or other indicia of persona in advertising or marketing associated with the Promotion. If you choose to enter a Promotion, Personal Information, such as your name and shipping address, may be disclosed to third parties or the public in connection with the administration of such Promotion, including, without limitation, in connection with winner selection, prize fulfillment, and as required by law or permitted by the Promotion's official rules, such as on a winners list.

Service Providers.
We may share any personal information we collect about you with our third-party service providers. The categories of service providers (processors) to whom we entrust personal information include: IT and related services; information and services; payment processors; customer service providers; and vendors to support the provision of the Services.

Business Partners.
We may provide personal information to business partners with whom we jointly offer products or services. In such cases, our business partner’s name will appear along with ours.

Affiliates.
We may share personal information with our affiliated companies.

Advertising Partners.
Through our Services, we may allow third-party advertising partners to set technologies and other tracking tools to collect information regarding your activities and your device (e.g., your IP address, mobile identifiers, page(s) visited, location, time of day). We may also combine and share such information and other information (such as demographic information and past purchase history) with third-party advertising partners. These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit the third-party websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising. We may allow access to other data collected by the Services to share information that may be useful, relevant, valuable, or otherwise of interest to you. If you prefer not to share your personal information with third-party advertising partners, you may follow the instructions below.

Disclosures to Protect Us or Others.
We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.

Disclosure in the Event of Merger, Sale, or Other Asset Transfers.
If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.

International Data Transfers.
You agree that all information processed by us may be transferred, processed, and stored anywhere in the world, including but not limited to, the United States, Canada, Israel, India or other countries, which may have data protection laws that are different from the laws where you live. We have taken appropriate safeguards to require that your personal information will remain protected and require our third-party service providers and partners to have appropriate safeguards as well. Further details can be provided upon request. Please note that your personal information will be accessible to law enforcement and/or regulatory authorities according to the applicable laws of such foreign jurisdictions.

Categories of Information Disclosed for a Business Purpose.

In the past 12 months, Proficiency Education may have disclosed the following categories of information about consumers for a business purpose:

· Name and Other Identifiers.
Such as real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.

· Purchase History.
Records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

· Network Activity Information.
Including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement.

· Geolocation Data.

· Professional or Employment-Related Information.

· Education Information.

· Inferences Drawn.
Inference drawn from any of the information above to create a profile about a consumer reflecting their preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Categories of Information Sold.

In the past 12 months, Proficiency Education may have sold the following categories of information about consumers:

· Name and Other Identifiers, Internet protocol address and device ID.

· Geolocation Data.

IV. YOUR CHOICES.

General.

You have certain choices about your personal information. Where you have consented to the processing of your personal information, you may withdraw that consent at any time and prevent further processing by contacting us as described below. Even if you opt out, we may still collect and use non-personal information regarding your activities on our Services and for other legal purposes as described above.

Email and Telephone Communications.

If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails regarding products or Services you have requested. We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those communications (e.g., communications regarding the Services or updates to our Terms or this Privacy Policy).

We process requests to be placed on do-not-mail, do-not-phone and do-not-contact lists as required by applicable law.

Mobile Devices.

You may be able to opt-in to receiving text messages from Proficiency Education. You may opt-out by replying "STOP" to one of the text messages received.

We will send you push notifications if you agree to receive them regarding updates on the Services and other items that may be relevant to you.

“Do Not Track.”

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

Cookies and Interest-Based Advertising.

You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy, at www.networkadvertising.org/managing/opt_out.asp, http://www.youronlinechoices.eu/,https://youradchoices.ca/choices/, and www.aboutads.info/choices/. To separately make choices for mobile apps on a mobile device, you can download DAA’s AppChoices application from your device’s app store. Alternatively, for some devices you may use your device’s platform controls in your settings to exercise choice.

To manage Flash LSOs please click here.

Please note you must separately opt out in each browser and on each device. Advertisements on third-party websites that contain the AdChoices link may have been directed to you based on information collected by advertising partners over time and across websites. These advertisements provide a mechanism to opt out of the advertising partners’ use of this information for interest-based advertising purposes.

Updating Your Account Information.

You may be able to review the information you provided to us on a Service and make any desired changes to the information, or to the settings for your account on that Service, by logging in to your account for that Service and editing or deleting the information.

Your Privacy Rights.

In accordance with applicable law, you may have the right to:

· Access to/Portability of Personal Data about you consistent with legal requirements. In addition, you may have the right in some cases to receive or have your electronic Personal Data transferred to another party.

· Request Correction of your personal information where it is inaccurate or incomplete. In some cases, we may provide self-service tools that enable you to update your personal information or we may refer you to the controller of your personal information who is able to make the correction.

· Request Deletion of your personal information, subject to certain exceptions prescribed by law.

· Request restriction of or object to processing of your personal information, including the right to opt in or opt out of the sale of your Personal Data to third parties, if applicable, where such requests are permitted by law.

If you would like to exercise any of these rights, please email manager@proed.com.au. We will process such requests in accordance with applicable laws. To protect your privacy, we will take steps to verify your identity before fulfilling your request.

Closing Your Account

If you wish to close your account with one of our Services, please send your request to closemyaccount@proed.com.au indicating which Service(s) you wish to close from the email account that you have registered with Proficiency education.

V. DATA RETENTION.

We store the personal information we receive as described in this Privacy Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, prevent fraud, and comply with applicable laws.

VI. SECURITY OF YOUR INFORMATION.

We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any information you provide to us. To the fullest extent permitted by applicable law, we do not accept liability for unintentional disclosure.

By using the Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Services, by mail or by sending an e-mail to you.

VII. CHILDREN’S INFORMATION.

The Services are not directed to children under 13. Parents or legal guardians (“Parents”) must provide their verified consent for the collection, use, or disclosure of a child's personal information. Proficiency Education will not collect, use, or disclose any personal information from a child if their parent or guardian does not provide such consent.

VIII. OTHER PROVISIONS.

Supervisory Authority.

If you are located in the European Economic Area, the UK, Canada, or Australia you have the right to lodge a complaint with a supervisory authority if you believe our processing of your personal information violates applicable law.

Changes to Privacy Policy.

We may revise this Privacy Policy from time to time in our sole discretion. If there are any material changes to this Privacy Policy, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you continue to use the Services after the new Privacy Policy takes effect.

IX. CONTACT US.

If you have any questions about our privacy practices or this Privacy Policy, or if you wish to submit a request to exercise your rights as detailed in this Privacy Policy, please contact us at:

Proficiency Education:

Level 1, 14 Railway Parade

Burwood, NSW 2134

Australia