Thank you for choosing to be part of our edPass community. edPass is committed to protecting your personal information and your right to privacy. The following Privacy Policy outlines our ongoing obligations to you in respect of how we manage user data. We thrive to incorporate our company values of transparency, usability, accessibility and sanity while managing your data.

If you have any questions or concerns about our policy, or our practices with regards to your personal information, please do not hesitate to contact us at edPass. 

This privacy policy applies to all information collected through our website, visitor management system and/or any related services, sales, marketing or events (collectively referred in the following context in this privacy policy as the “Services “). 

Thank you for entrusting information us. Holding onto your private information is definitely a serious responsibility, so we want you to understand how we’re
handling it. 

The Short Version 

Of course, the short version doesn’t tell you everything, so please read on for more details’.

The follwowing document is part of edPass’s Terms of Service, and by using edpass.co (the “Website”), or any of the related Services you agree to the terms of this Privacy Policy and the Terms of Service. Please read the both documents in their entirety, and refer to those for definitions and contacts.

The Long Version

THE INFORMATION WE COLLECT AND WHY DO WE COLLECT IT?

We collect variety of information that you voluntarily provide to us when using, expressing an interest in obtaining information about us or our products and services, when participating in activities on the Services or otherwise contacting us.

The information that we collect depends on the context of your interactions with us and the Services, the choices you make and the products and features you use. The information we collect include the following:

1. Personal Information.We collect your first and last name, email address, postal address, phone number, organization name and address, and other similar contact data.
   
   
2. Other Information automatically and manually collected We automatically collect anonymous data from every when you visit, use or navigate the Services through web/app, through cookies and similar technologies. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

HOW DO WE USE YOUR INFORMATION?

We process your information when necessary to provide you with the Services that you have subscribed for, where we have obtained your prior consent or where we have legitimate business interest to do so. The said information is processed in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.

• Personalization of Service. We also use the Personal Data we collect directly from you to operate, improve, understand and personalize our Services based on our legitimate business interest in operating our Services in a way that benefits us and our users.  For example, we use the Personal Data to:

– Create and manage user profiles
– Communicate with you about the Services
– Contact you about Service announcements, updates or offers
– Provide support and assistance for the Services
– Personalize website content and communications based on your preferences
– Meet contract or legal obligations
– Respond to user inquiries
– Fulfill user requests
– Comply with our legal or contractual obligations
– Resolve disputes
– Protect against or deter fraudulent, illegal or harmful actions
– Enforce our Terms of Service

• For other Business Purposes. We may use your information for other Business Purposes, which include but not be limited to security, data analysis, identifying usage trends, research and development, testing, reporting, maintenance, determining the effectiveness, evaluating and enhancing our Services, products, marketing and your experience. 
• Legal Obligations. From time to time, we may also need to process Personal Data to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest

This use of information is vital for us to continue providing you with our services or you may be limited in your use of service. When we process Personal Data based on your consent, it will be expressly indicated to you at the point and time of collection.

WILL YOUR INFORMATION BE SHARED WITH ANYONE?

We may process or share data based on the following legal basis:

• Consent:We may process your data if you have given us specific consent to use your personal information in a specific purpose.
• Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.
• Legal Obligations:We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
• Vital Interests:We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

More specifically, we may need to process your data or share your personal information in the following situations:  

• Vendors, Consultants and Other Third-Party Service Providers. We may share your data with third party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: payment processing, data analysis, email delivery, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the Services, which will enable them to collect data about how you interact with the Services over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity. Unless described in this Policy, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes.  We have contracts in place with our data processors. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will not share your personal information with any organization apart from us. They will hold it securely and retain it for the period we instruct. 

  ·       Social Buttons. We also use social buttons provided by services like Twitter, Google+, LinkedIn and Facebook. Your use of these third party services is entirely optional. We are not responsible for the privacy policies and/or practices of these third party services, and you are responsible for reading and understanding those third party services’ privacy policies. 

• We may choose to buy or sell assets. In these types of transactions, user information is typically one of the transferred business assets. Moreover, if we, or substantially all of our assets, were acquired, or if we go out of business or enter bankruptcy, user information would be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer of us or our assets may continue to use your personal information as set forth in this policy.

HOW LONG DO WE KEEP YOUR DATA?

When your Personal Information is no longer needed for the purpose for which it was obtained, we will take reasonable steps to destroy or permanently de-identify your Personal Information. However, most of the Personal Information is or will be stored in client files which will be kept by us for a minimum of 7(# number of years) years.

HOW DO WE KEEP YOUR INFORMATION SAFE?

We employ industry standard techniques to protect against unauthorized access of data about you that we store, including personal information.

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, please also remember that we cannot guarantee that the internet itself is not 100% secure. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the services within a secure environment. 

DATA BREACH

A privacy breach occurs when there is unauthorized access to or collection, use, disclosure or disposal of personal information. You will be notified about data breaches when Brainy Housing believes you are likely to be at risk of serious harm. For example, a data breach may be likely to result in serious financial harm or harm to your mental or physical well-being. In the event that  Brainy Housing becomes aware of a security breach which has resulted or may result in unauthorized access, use or disclosure of personal information  Brainy Housing will promptly investigate the matter and notify the applicable Supervisory Authority not later than 72 hours after having become aware of it, unless the personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons.

SENSITIVE INFORMATION

Sensitive information is defined in the Privacy Act to include information or opinion about such things as an individual’s racial or ethnic origin, political opinions, membership of a political association, religious or philosophical beliefs, membership of a trade union or other professional body, criminal record or health information.

Sensitive information will be used by us only:

• For the primary purpose for which it was obtained
• For a secondary purpose that is directly related to the primary purpose
• With your consent; or where required or authorised by law.

THIRD PARTIES

Where reasonable and practicable to do so, we will collect your Personal Information only from you. However, in some circumstances we may be provided with information by third parties. In such a case we will take reasonable steps to ensure that you are made aware of the information provided to us by the third party.

• Account information for third party services: If you interact with a 3rd party service when using our Services, For exampleif you utilize a 3rd party service to log-in to our Services (e.g., Facebook Connect), or if you share content from our Services through such third party service, the applicable third party service will send us certain Personal Data (specifically your given name, ID, token and profile picture URL) if the third party service and your account settings allow such sharing. Specifically, this Personal Data permits us to form and manage user profiles and sync your progress once you connect with Facebook through the Services. The Personal Data we receive will depend upon the policies and your account settings with the applicable third party service. We process this Personal Data on the basis of our legitimate business interest of personalizing and optimizing the Services to enhance user experience.
  
  
• Information from our advertising partners: We receive information about you from a number of our service providers who assist us with marketing or promotional services associated with how you interact with our websites, applications, products, services, advertisements or communications. We process this Personal Data on the basis ofour legitimate business interest in providing marketing about our products and services.

DISCLOSURE OF PERSONAL INFORMATION

Your Personal Information may be disclosed in a number of circumstances including the following:

• Third parties where you consent to the use or disclosure; and
• Where required or authorized by law.

SECURITY OF PERSONAL INFORMATION

Your Personal Information is stored in a manner that reasonably protects it from misuse and loss and from unauthorized access, modification or disclosure.

We seek to protect Personal Data using appropriate technical and organizational measures based on the type of Personal Data and applicable processing activity.

ACCESS TO YOUR PERSONAL INFORMATION

You may access the Personal Information we hold about you and to update and/or correct it, subject to certain exceptions. If you wish to access your Personal Information, please contact us in writing.

edPass will not charge any fee for your access request, but may charge an administrative fee for providing a copy of your Personal Information.

In order to protect your Personal Information, we may require identification from you before releasing the requested information.

MAINTAINING THE QUALITY OF YOUR PERSONAL INFORMATION

It is an important to us that your Personal Information is up to date. All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information. We will take reasonable steps to make sure that your Personal Information is accurate, complete and up-to-date. If you find that the information we have is not up to date or is inaccurate, please advise us as soon as practicable so we can update our records and ensure we can continue to provide quality services to you.

POLICY UPDATES

We may update this privacy policy from time to time as necessary to stay compliant with relevant laws. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible on our website. If we make material changes to this privacy policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy policy frequently to be informed of how we are protecting your information. 

HOW CAN YOU CONTACT US ABOUT THIS POLICY?

If you have questions or comments about this policy, you may email us at edPass or else submitting your message through our contact form.

HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the laws of Australia, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please submit a request through our service email. We will respond to your request within 30 days.

PRIVACY POLICIES, COMPLAINT AND INQUIRIES

If you have any queries or complaints about our Privacy Policy please contact us at:

Email: sales@edpass.co