Privacy Policy

ClickView Australia Pty Ltd (ACN 140 397 584), ClickView Limited (Company Registration Number 05919237) (UK Co), ClickView Limited (Company Number 2208806) (NZ Co), ClickView (US) (Corporate Number 86-3807728) (US Co) and their related and associated entities (“ClickView” or “us” or “we” or “our”) is committed to maintaining the privacy and security of personal information.

This Privacy Policy explains how we collect, store and use personal information in connection with our services, our websites (“Sites”) and our applications, platforms and associated software, products and programs (together, the “Platform”).

It also sets out the rights of our educational institution customers (“School Customers”) and their permitted individual users (“Permitted Users”) in connection with personal information. If you have any questions or if you wish to receive further details, please contact us using the method set out below.

This Privacy Policy has been developed in accordance with the General Data Protection Regulations (GDPR), the UK General Data Protection Regulation (UK GDPR), the Data Protection Act (UK), the Australian Privacy Act (including the Australian Privacy Principles), the New Zealand Privacy Act and applicable US data protection laws (including the Children’s Online Privacy Protection Act (COPPA), the California Consumer Privacy Act (CCPA) and the United States Family Educational Rights and Privacy Act (FERPA) (collectively, “Data Protection Laws”).

How we collect personal information

We may collect personal information in a number of ways, including:

School Customers

  • When a teacher, administrator, or other representative of a School Customer signs up to access to our Platform for their students and teachers either on a subscription or trial basis.
  • When a teacher, administrator, or other representative of a School Customer accesses our Sites or Platform.
  • During conversations and/or correspondence between a teacher, administrator, or other representative of a School Customer and the ClickView team (for example, customer service enquiries).

Permitted Users

  • From School Customers, to enable us to create accounts and to provide users with access to the Platform.
  • Directly, to verify log-in information or to provide support services in connection with the use of the Platform.
  • From the Platform, to follow a user’s usage, interaction and progress on the Platform.

The types of personal information we collect

The types of personal information we collect may include:

School Customers

  • Teacher, administrator or representative name, email address, phone number, job title and staff group.
  • Educational institution name, contact information and billing information.
  • Details of other interactions that you have with us, together with any other information that you choose to provide us, for example, through your interactions with our Sites or Platform and our customer and technical support teams.

Permitted Users

  • Individual user information such as a user’s name, school email address, username, school ID and school year.

What we do with personal information

The personal information you provide to us, or collected about you, is collected for the purpose of enabling us to provide and enhance our services and to provide access to and enhance usage of the Platform. This may include:

School Customers

  • To manage and administer our agreement with you, including relationship management, invoicing, training, implementation, performance of our agreement and the provision of support services.
  • To manage enquiries, free trials and prospective purchases.
  • To provide the content, functions and services offered on the Platform.
  • To limit access to the Platform to legitimate Permitted Users.
  • To keep School Customers and their representatives informed of our products and services that might be relevant to them.
  • To send newsletters or emails about our Platform, including information about current events, changes, improvements, upgrades, new product development and rules.

Permitted Users

  • To gain user insights and analysis to enable School Customers to observe the learning and behaviour of their Permitted Users and to improve the Platform.
  • To administer and manage accounts, including password resetting, responding to questions and to monitor usage and conduct on the Platform.
  • To contact Permitted Users to let them know about tools, features and content available on the Platform, and to make recommendations about content, in order to customise and enhance usage of the Platform by Permitted Users.
  • To let Permitted Users know about developments and updates to the Platform.
  • To provide results data to School Customers.

If we have obtained the personal information of a Permitted User through their use of the Platform (for example, when they log-on to use the Platform) or from that Permitted User’s educational institution, the personal information will be securely stored by us and not used for any purpose other than for the educational purposes specified in this Privacy Policy and to enable continued use and enhancement of the Platform.

What we will not do with personal information

We will keep your personal information confidential and not disclose or sell your personal information to any third parties, unless:

  • we believe, in good faith, that we are required to share your information with a third party such as a regulator or court in order to comply with a law, regulation, legal process or court order;
  • it is reasonably necessary to enforce our legal rights in relation to your access and use of our Platform;
  • the disclosure is to a third party service provider that provides services for us, for example to assist us with web hosting, Platform performance or customer relationship management (provided that all such disclosures are subject to the terms of this Privacy Policy);
  • results data or usage reporting tools are provided to School Customers for educational purposes (provided that the use the information is only for legitimate educational interests and not for any commercial purposes); and
  • to protect the safety and security of our users and our Platform.

Student personal information is used for educational purposes only. We do not sell student personal information to advertisers (whether personal, anonymous or aggregated). We do not engage in targeted advertising or direct marketing to students or children, and we do not create or build personal profiles of students other than for the purpose of supporting authorised educational purposes, as specified in this Privacy Policy or as otherwise specifically authorised by a School Customer.

Third party service providers which process personal information on our behalf (who may be classified as sub-processors under Data Protection Laws) are only engaged to assist us with providing and enhancing our Platform and our services. These providers are only granted access to personal information to the extent required to provide their services for us, strictly in accordance with our instructions, this Privacy Policy, applicable privacy laws, our contractual obligations to customers and not for any commercial purpose.

We will comply with our obligations under applicable Data Protection Laws when engaging sub-processors and we will ensure that all sub-processors comply with their obligations under applicable Data Protection Laws. Without limitation, we take reasonable steps to ensure that these organisations comply with technical and organisational security measures required to protect personal information.

Direct marketing

If we have obtained your personal information through your use of the Platform (for example, when you log-on to use the Platform) or from your institution in connection with your use of the Platform, we will not use your personal information for marketing purposes. We may contact Permitted Users for educational purposes as specified in this Privacy Policy, however we do not engage in direct marketing to students or children.

If we have obtained your personal information by other ways permitted in this Privacy Policy, including if you have enquired about the Platform or you have provided your personal information as a teacher or administrator on behalf of a School Customer (including for a trial), we may use your personal information to send you information about new developments, products, services and special offers.

You can, at any time, opt out of receiving marketing material from us by contacting us using the method set out below or, where we have sent you electronic marketing materials, by using the unsubscribe link within the communication. You agree and acknowledge that even if you opt out of receiving marketing material, we will still send you essential information that we are required to send you relating to the services we provide.

How long we hold personal information

We retain the personal information that we collect for as long as it is needed to provide access to our Platform and to provide our services. The personal information of Permitted Users is retained for educational and school purposes only. We will not knowingly retain student personal information which relates to a School Customer when we cease providing services to that School Customer. We will delete personal information when lawfully requested or directed to do so by a School Customer.

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, analytic purposes and for product and service improvement.

You can request that personal information is deleted by contacting us in the manner specified below.

Our use of cookies and similar technologies

We may use cookies, web beacons, pixels, log files and other technologies to collect information about visitors and visits to our Platform. This may include:

  • An IP address to monitor traffic and volume on the Platform;
  • A cookie to help us store session information when users are logged into the Platform and to facilitate seamless access between our different services;
  • A session ID to track usage statistics on the Platform; or
  • Information regarding participation habits, experiences and interaction with our Platform.

We may use this information to measure the effectiveness of content and how visitors use the Sites, so that we can enhance and improve our Sites.

If you choose to do so, you may configure your computer so that it disables “cookies” or does not accept them, however, this may impact the functionality of the Sites.

Consents

By signing up to a subscription, registration or trial access to our Platform, School Customers consent to the collection of the personal information of their Permitted Users for the purposes specified in this Privacy Policy. School Customers are responsible for ensuring that they have obtained consents from Permitted Users, including the parents or guardians of students, prior to those Permitted Users using the Platform.

Storage and security

We will take all reasonable steps to keep personal information in a secure environment in accordance with the requirements of applicable Data Protection Laws. We have implemented technical, administrative and physical security measures that are designed to protect personal information from unauthorised access, disclosure, use and modification. These measures include the encryption of personal information and student data. If you reasonably believe that there has been unauthorised use or disclosure of personal information, please contact us using the method set out below.

Changes to our Privacy Policy

We may vary the terms of this Privacy Policy from time to time, in which case we will update the link to the Privacy Policy on our Sites. You should check this Privacy Policy regularly so that you are aware of any variations made to this Privacy Policy. If we make material variations to our Privacy Policy, we’ll provide you with notice as appropriate under the circumstances. You will be deemed to have consented to such variations by your continued use of the Platform following such changes being made.

Access to information we hold about you

We will take reasonable steps to ensure that all personal information we hold is accurate, up-to-date and relevant. A person may request access to, review of, corrections of, or erasure of personal information held by us, or complain or object to the use of personal information by us. You can contact us using the methods set out below. We will respond to your request as quickly as possible and in accordance with applicable Data Protection Laws.

How to contact us

All requests to access, update and delete personal information as well as questions and concerns about your personal information and this Privacy Policy should be directed to the following contacts:

Australia

Privacy Officer, ClickView Australia Pty Ltd
Suite 125, 26-32 Pirrama Road, Pyrmont, New South Wales 2009
or sending an email to us at info@clickview.com.au

The European Union and the UK

Privacy Officer
Fifth Floor, 4 Bath Place
London, EC2A 3DR
or sending an email to us at info@clickview.co.uk

The United States

ClickView (US)
C/- 104 West Anapamu Street
Suite B, Santa Barbara, CA 93101
or sending an email to us at info@clickvieweducation.com

New Zealand

Privacy Officer, ClickView Limited
PO Box 911503, Victoria Street, West Auckland 1142
or sending an email to us at info@clickview.co.nz

Specific information for residents of the European Union and the UK

We are committed to compliance with our obligations under the applicable Data Protection Laws in the EU and the UK.

Data Processor

In most cases ClickView will be a data processor for the purposes of applicable Data Protection Laws and the School Customer will be the data controller.

This means ClickView only uses the personal information of Permitted Users as instructed by the School Customer and for the purpose of providing the Platform and our services in accordance with the terms of our agreement with the School Customer. We may also enter into a data processing agreement with School Customers for the processing of student personal information.

Basis for processing

Depending on the context and the purpose of our processing activities we generally process personal information on the basis of consent, or the legitimate interests pursued by ClickView and our School Customers in delivering learning resources for schools, institutions, teachers, parents and students. Our legitimate interests are further detailed in the section entitled “What we do with personal information” above.

Transfer of personal information

Personal information we collect may be transferred and stored on servers located in Australia, the United States, or other countries in which the privacy or data protection laws differ from those of the European Union and the UK. We ensure that suitable safeguards exist in relation to transfers of personal information to recipients outside of the EU and the UK, including through the use of the Standard Contract Clauses approved by the European Commission and further recognised by the UK Government for data transfers from the UK under the UK GDPR.

Contact us

If you are a representative of a School Customer and you have questions about the use of personal information in relation to the GDPR or the UK GDPR, you can contact us using the method set out above in this Privacy Policy.

If you are a student and you have questions about the use of your personal information in relation to the GDPR or the UK GDPR, you should ask your teachers first. You can also contact us using the method set out above in this Privacy Policy.

Specific information for residents in the United States

ClickView only uses personal information for educational purposes as a “service provider”, as instructed by the School Customer and in accordance with the terms of our agreement with the School Customer.

No sale of personal information

ClickView does not sell the personal information of Permitted Users to third parties and ensures that its service providers do not sell that personal information to third parties.

No collection of personal information of children without consent

We do not knowingly permit children under the age of 13 to create an account or provide us with personal information without us first obtaining verifiable consent of the School Customer. School Customers are responsible for ensuring that they have obtained consents from the parents or guardians of Permitted Users prior to those Permitted Users using the Platform.

We will not require Permitted Users to provide us with more information than is reasonably necessary to use our Platform.

If you believe we have collected information from a child under the age of 13 without obtaining consent from the School Customer, please contact us using the method set out above in this Privacy Policy.

Right to know, access and delete personal information

California residents have certain rights to request access to or deletion of their personal information in accordance with the CCPA. You can do this by contacting us using the method set out above in this Privacy Policy. We may require you to take certain steps to verify your identity.

California residents also have the right to opt out of the sale of their personal information. ClickView does not provide this option as we do not sell your personal information.

Contact us

We have obligations to our School Customers in our agreements with our School Customers and under applicable Data Protection Laws. As such, to exercise your rights under CCPA, please contact your education institution first. Should they need our assistance in facilitating your request, we will provide them with the appropriate support. You may also contact us using the method set out above in this Privacy Policy.

You will not be discriminated against for exercising your rights under the CCPA or other applicable Data Protection Laws.