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Privacy Policy

This Privacy Policy applies to all personal information collected by Safe on Social Media Pty Ltd via the website located at www.safeonsocial.com.

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1. What is "personal information"?

(a) As per the Privacy Act 1988 (Cth), "personal information" refers to data or an opinion about an identified individual or someone who is reasonably identifiable:
 

(i) Regardless of its truthfulness.

(ii) Regardless of whether it's documented or not.

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(b) Information that doesn't reveal your identity or enable identification will typically not qualify as "personal information" and won't fall under this privacy policy.

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2. What information do we collect?

The type of personal information collected depends on your website usage. We may process (eg collect, use, store and/or transfer) different kinds of personal data about you which we have grouped together as follows:

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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.

Contact Data includes billing address, delivery address, email address and telephone numbers.

Financial Data includes bank account and payment card details.

Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.

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Technical Data includes internet protocol (IP) address, your login data, browser type and version, 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.

Usage Data includes information about how you use our website, products and services.

Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

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3. How we collect your personal information

(a) We gather personal information whenever you input such details into the website.
 

(b) Additionally, from time to time, Safe on Social may collaborate with 3rd party vendors to host our online programs. Please read below to be aware of the terms and conditions of our online portal provider.

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We collect your Contact Data, Identity Data and Technical Data about our customers to provide you with the services, for example, to confirm your identity or contact you.

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When transactions between you and our website involve payment by credit card, debit card, checks, money orders, and/or third party online payment services, we will collect Financial Data and Transaction Data as part of the course of doing business.

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This personal data is collected when you sign up for our services, when you access our services or otherwise provide us with the personal data. In some circumstances, when you have given us express permission, we may also use and store your personal data.

How our 3rd Party Providers collect personal data about our customers’ students/subscribers.

In order to provide our services, we collect and process personal data about our customers’ students/subscribers. Here is a summary of the personal data that we collect from our customers’ students/subscribers:

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We collect Contact Data, Identity Data, Technical Data and Profile Data about our customers’ students/subscribers to allow them to access our services for processes such as enrollment, authentication, or otherwise administering our customers’ courses. This information is given on a voluntary basis when a customer uses or accesses our services.

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We collect Usage Data about how our customers’ students interact with a course(s) and website(s), including but not limited to, their progress through the course, quiz scores, survey results, discussion or forum contributions and other student activities.

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Some transactions between learners and our website or our customers’ courses may involve payment by credit card, debit card, checks, money orders, and/or third party online payment services. In such transactions, we will collect Financial Data and Transaction Data in order to provide our customers with the services, including a billing address, telephone number, and other information related to the transaction.

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How we collect personal data about Thinkific & 3rd Party website visitors and support users:

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We collect your Usage Data including your IP addresses and how you interact with our website.

We also collect backend Usage Data  such as when you visited, the website from where you came prior to visiting us, the website where you go when you leave our website, your computer’s operating system, location data, and the type of web browser that you are using.

We also collect Contact Data and Identity Data submitted by you via any messaging or email feature available from any of our websites.

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4. Purpose of collection

(a) Our aim in collecting personal information is to offer you the best possible service experience on the website. We will only use your personal data when the law allows us to.

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(b) Typically, we disclose personal information solely to our service providers aiding in website operations. Your personal information may also be accessible to maintenance and support personnel as part of their routine tasks.

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(c) By using our website, you consent to receiving direct marketing material. We use your personal information for this purpose only if directly collected from you, related to anticipated communication types. Sensitive personal information isn't used in direct marketing. Our direct marketing includes a simple opt-out method.

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(d) Most commonly, we will use your personal data in the following circumstances:

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  • Where we need to perform a contract we are about to enter into or have entered into with you.

  • Where it is necessary for our legitimate business interests (or those of a third party) and your interests and fundamental rights do not override those interests.

  • Where we need to comply with a legal obligation.
     

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 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 and you can unsubscribe from any such marketing communications at any time.

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5. Access and correction

As per Australian Privacy Principles 12 and 13, you have rights to access and rectify your personal information in certain situations, except under specific exceptions. Contact us for such access.

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6. Overseas transfer

Your personal information may be transferred to recipients located in locations where Safe on Social conducts work.  These locations have data protection laws which protect personal information in a way which is at least substantially similar to the Australian Privacy Principles, and there will be mechanisms available to you to enforce protection of your personal information under that overseas law. In the circumstances, we do not require the overseas recipients to comply with the Australian Privacy Principles and we will not be liable for a breach of the Australian Privacy Principles if your personal information is mishandled.

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7.  GDPR

In some circumstances, the European Union General Data Protection Regulation (GDPR) provides additional protection to individuals located in Europe. Where this is the case, there may be additional rights and remedies available to you under the GDPR if your personal information is handled in a manner inconsistent with that law.

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8. Complaint procedure

If you have privacy-related complaints, contact us below. We'll address complaints and may request more information to clarify concerns. If validated, we'll take steps to rectify the issue. If unresolved, refer the matter to the Office of the Australian Information Commissioner.

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9. Third-Party Integration

From time to time, Safe on Social may work with 3rd party vendors to host our online programs. Please read below to be aware of the terms and conditions of our online portal provider.

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10. Minors

If you are below the age of 16, you may use our website or online learning platform only with the permission and active involvement of a parent or legal guardian or on behalf of approved school resources. If you are a minor, please do not provide us or other website visitors with any personal information unless previously approved.

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11. What we don’t do with your personal Information

We do not and will never share, disclose, sell, rent, or otherwise provide Personal Information to other companies (other than to specific Online Learning System customers you may be interacting with) for the marketing of their own products or services.  Safe on Social works directly with 3rd party providers including LMS software that works with third parties to help provide our services and may share your personal data with them to support these efforts in accordance with the purposes and lawful bases set out in the table above. In certain limited circumstances, we may also be required to share personal data with third parties to conform to legal requirements or to respond to lawful requests by public authorities, including to meet national security or law enforcement requirements.

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Personal data may be shared with third parties to prevent, investigate, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our Terms of Service or any other agreement related to the services, or as otherwise required by law.

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Personal data may also be shared with a company that acquires our business, whether through merger, acquisition, bankruptcy, dissolution, reorganization, or other similar transaction or proceeding. If this happens, our 3rd party providers will post a notice on their homepage.

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We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

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12. Keeping your personal information secure

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

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We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

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13. International transfers of personal data

Safe on Social use a 3rd party provider to host our online programs. This is a Canadian company that provides services to customers, and their technology processes data from users, around the world.

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Accordingly, Thinkific may transfer your personal data outside of the country, state, or province in which you are located. Thinkific ensures that whenever we transfer your personal data out of the UK and EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following appropriate safeguards is implemented:

 

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for processing of personal data pursuant to adequacy regulations made in accordance with applicable data protection laws.

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Where we use certain service providers, we will enter into an agreement with those providers in the form of the standard contractual clauses approved in accordance with applicable data protection laws and which give personal data the same protection it has in the UK and EEA.

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Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

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14. Usernames and Passwords

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a username and password for access to certain parts of our website, you are responsible for keeping the username and password confidential. Do not give your password to anyone. If you enter a section of our website that requires a password, you should log out when you leave. As a safety precaution, you should also close out of your web browser completely and re-open it before viewing other parts of the Internet.

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15. Online Learning System Security

Online Learning System’s platform is built on a strong foundation of security and privacy that keeps our platform secure while helping our creators of all sizes meet their security, privacy, and compliance requirements.

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If you are a customer using Online Learning System’s services, we do not use the Personal Information we collect from you or your customers to independently contact or market to your customers. However, Online Learning System may contact or market to your customers if we obtain their information from another source, such as from the customers themselves.

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16. Thinkific Security and Data Privacy Measures

Safe on Social has a direct relationship with Thinkific’s online learning platform and has implemented a combination of best-in-class security, privacy, and compliance controls to ensure the safety of customers and their learners' data:

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  • Encryption: Thinkific encrypts data using secure cryptographic algorithms. All data in transit is encrypted using TLS 1.2 or greater. AES-256 encryption is leveraged for data at rest, and key management is in place for all encryption keys.
     

  • Data Privacy Overview: Thinkific's data privacy controls honor obligations concerning the collection, processing, use, and sharing of personal data. Data retention and disclosure processes comply with applicable privacy laws. Thinkific collects and uses personal data following its Privacy Policy and provides course creators with a Data Processing Addendum and CCPA Service Provider Addendum in compliance with GDPR and CCPA.
     

  • Data Sharing and Processing: Thinkific’s platform complies with GDPR and CCPA, providing a high level of protection for course creator and learner personal data. It only collects, processes, and stores customer data in compliance with these obligations, offering you the right to access or delete it at any time. Policies are in place for deleting customer data when no longer needed for a legitimate business purpose. Thinkific uses cookies according to its Cookies Policy and requires data processing vendors to certify the use of customer data solely for service provision.
     

  • Data Disposal: As a customer, you can request data deletion at any time during the subscription period. Thinkific can honor requests for erasure, access, and rectification so that our course creators can comply with the GDPR. Thinkific's hosting providers maintain industry-standard security practices for ensuring the permanent removal of data from storage media.
     

  • Vendor Management: Thinkific only shares customer data with third parties that contractually agree to protect the confidentiality and privacy of the data. Thinkific has established agreements that require subprocessors to adhere to confidentiality commitments and take appropriate steps to ensure our security posture is maintained. Thinkific only exports personal data outside of the EEA in compliance with the GDPR, including by transferring personal data to subprocessors on the basis of the updated Standard Contractual Clauses where required. Thinkific monitors these sub-processing vendors by conducting reviews of their controls before use and at least annually.
     

17. Disclaimer

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal data, we cannot guarantee the security of your personal data transmitted to our website. Any transmission of personal data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the website, including the illegal acts of third parties (such as criminal hacking).
 

How to contact us about privacy

We keep this privacy policy under regular review, so the terms of this policy may change from time to time. If we make material changes to how we treat our users’ personal data, we will notify you by posting the revised policy on this website or by other means when appropriate. Your continued use of this website constitutes your consent to such revised privacy policy.
 

For queries, access requests, or privacy complaints, contact us via wecanhelp@safeonsocial.com.

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