“Personal Information” is information that allows someone to identify or contact you, including, for example, your name, address, telephone number, e-mail address, photograph, video, as well as any other non-public information about you that is associated with or linked to your personal information.
“Sensitive Information” is a type of personal information and includes information about an individual that requires direct consent for collection and limited secondary use. For example:
- health (including predictive genetic information)
- racial or ethnic origin
- political opinions
- membership of a political association, professional or trade association or trade union
- religious beliefs or affiliations
- philosophical beliefs
- sexual orientation or practices
- criminal record
- biometric information that is to be used for certain purposes
- biometric templates.
“Anonymous Information” is information that is not associated with or linked to your Personal Information. Anonymous Information does not enable identification of or contact with individual persons.
“Institution” is an entity that contracts with KeptMe to collect and manages their clients’ information to deliver their services. They acquire your consent to enter your personal information on your behalf. These are typically schools or childcare centres.
Scope and Application of Policy
How We Collect Information
In general, the Personal Information we gather enables us to provide the Services and helps us learn more about the use of the App, Site and/or Services. When you download the App, we may collect your device type, your wireless carrier, and your individual device ID and we associate this with your Personal Information, though we primarily use this information to support your account and provide you with Services. To use our Services, you must register through the App with our Services and open an “Account” with us by providing your name, email address and a password directly. We retain information on your behalf, such as entries, pages and messages that you store using your Account. We understand, however, that the most important thing we store is your personal artefacts such as photos and metadata. Our display of those artefacts will be subject to the privacy settings you establish for them. When you publish or share content (text, images, photographs, messages, comments or any other kind of content that is not your e-mail address) as part of our Services, other authorised users may be able to see it. Please consider this before publishing any information. When you order Services through our App, we may collect information necessary to complete and record the transaction, though some of this information may go directly to our payment provider. If you tell us where you are (e.g., by allowing your mobile device to send us your location when you publish), we may collect, store and use that information. If you want to deactivate this feature, you can either reinstall the App(s) or deactivate location services on your mobile device. Of course, your location may also be apparent from your entries. We collect your other Personal Information that you submit to us voluntarily as you use our App, Site and Services. If you provide us feedback or contact us via e-mail, we will collect your name and e-mail address, as well as any other content included in the e-mail, in order to send you a reply. You can choose not to provide us with certain information, but this may limit the features of the Services you are able to use.
The table below outlines the purposes for which we collect Personal Information, what Types of information are typically collected, and the types of Uses and Disclosures that are included but not limited to.
|Mobile App and Web Services||Device Information:
Such as device type, wireless carrier, individual device IDAccount Information:
Such as name, email address, preferences and password
Personal and Sensitive Information:
|To provide services to Institutions and Individuals to enabling Student Centric Learning
To provide personalized notifications based on preferences and App activity
To produce market research and analytics from anonymised and aggregated data which can improve KeptMe Services and the services provided by your Institutions
To provide a repository for individuals to document their educational and life journey.
To process a financial transaction
|Application Support||Contact Information: Such as Email address||To provide a response to your support request||
|General Enquiries||Contact Information: Such as Email address||To provide a response to your enquiry||
|Direct Marketing||Contact Information:
Such as Email address
|To provide you with updates about service offerings and new features, typically via email or push alerts||
If you tell us where you are (e.g., by allowing your mobile device to send us your location when you publish), we may collect, store, use that information. If you want to deactivate this feature, you can either reinstall the App(s) without permission or deactivate location services on your mobile device. Your location may also be apparent from your text submissions.
You can choose not to provide us with certain information, but this may limit the features of the Services you are able to use.
In addition to the Personal Information, we collect the following types of Anonymous Information:
- Information Collected by Our Servers. To make our Site and Services more useful to you, our servers (which may be hosted by a third party service provider) collect information from you, including your browser type, operating system, Internet Protocol (“IP”) address (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session), domain name, and/or a date/time stamp for your visit.
- Mobile Services. We may also collect non-personal information from your mobile device if you have downloaded our App(s) to your mobile device. This information is generally used to help us deliver the most relevant information to you. Examples of information that may be collected and used include your geographic location, how you use the App(s), and information about the type of device you use. In addition, in the event our App(s) crash on your mobile device, we will receive information about your mobile device model software version and device carrier, which allows us to identify and fix bugs and otherwise improve the performance of our App(s). This information is sent to us as aggregated information and is not traceable to any individual and cannot be used to identify an individual.
We require your consent to collect, use and disclose your personal and/or sensitive information in accordance with this Policy. Consent may be expressed or implied for personal information and must be expressed when Sensitive Information is collected.
Express consent may be given orally or in writing, including electronic transmission. Express consent may be collected by us or by your Institution. Implied consent is consent that can be reasonably inferred by your action or inaction.
Under limited circumstances (for example: submitting an enquiry or subscribing to a mailing list) by providing us with the personal information described in this Policy, we assume you have implicitly provided KeptMe with your consent to collect, use and disclose your personal information in accordance with this Policy.
You may withdraw or limit your consent to our collection, use and disclosure of your personal information at any time, subject to relevant laws. You must provide reasonable notice of the withdrawal of your consent. All communications with respect to the withdrawal or limitation of your consent should be directed to our Privacy Office in writing.
In some circumstances, KeptMe is entitled, or required, to disclose your personal information without your consent. These circumstances include, but are not limited to:
- Protecting your health or safety
- The disclosure is required or authorized by law
- The disclosure is required to comply with a subpoena, warrant or order of a court or other body authorized to compel production of the information
- The disclosure is to a lawyer who is representing KeptMe
- The disclosure is required to respond to an emergency
How We Use Information
We will use your Personal Information to: – Provide you with Services and customer support; – Market our products and services to you that we believe may be of interest to you; – Respond to your requests, resolve disputes and/or troubleshoot problems; – Improve the quality of the Sites and the Services; and – Communicate with you about the Sites and the Services. We may also use your Personal Information to create Anonymous Information records by excluding information that makes the information personally identifiable to you. We will communicate with you primarily in the form of push alerts and emails. You can manage the frequency and/or opt out of receiving these communications by changing your settings on the App and/or clicking the “Unsubscribe” link at the bottom of each email. Please note that even if you unsubscribe or opt-out, we may still send you Site and Services related communications (e.g., emails related to your account or the App).
How We Disclose Information
We reserve the right to disclose Anonymous Information publicly without restriction.
How We Protect Your Information
We are continuously reviewing and upgrading our systems to keep your data safe now, and into the future. We take reasonable precautions to avoid a data breach including but not limited to:
- Data encryption to protect data at rest on our servers
- Local data encryption option on mobile devices to prevent unauthorised access where a device is stolen
- SSL secured communications to and from our servers to protect data in transit
- Granular role-based access controls
- A distinct data ownership model
- Network restrictions to prevent access to our servers from outside of your school
- Membership restrictions to ensure only authorised staff within your school have access
- Network level security protections
- A world class data centre which complies with international information security standards including ISO27001, HIPAA, SOC 1/SSAE 16/ISAE 3402 and FedRAMP
Controlling Your Information
Access And Correction of Your Information
To access or change some personal information may require approval by an authorized individual from your Institution. Contact your Institution or our Privacy Office to access or correct any information not accessible by logging into the App(s).
Deletion of Your Information
You may request the deletion of your information by contacting our Privacy Office. KeptMe maintains a data deletion policy to ensure that data is maintained in accordance with relevant laws and contracts. KeptMe will take reasonable steps to delete information when requested with appropriate authentication and authorization.
Our Service is often used to collect information about children (including persons under 13). KeptMe does not knowingly collect or solicit personal information from or about children without the consent of a legal guardian. If we become aware that we have collected personal information from or about a child without verification of parental consent, we will take steps to remove that information. If you believe that we might have any information from or about a child without proper consent, please contact our Privacy Office.
International Data Transfer
We may transfer information that we collect about you, including personal and sensitive information, to affiliated entities, or to other third parties (as provided herein) across borders and from your country or jurisdiction to other countries or jurisdictions around the world.
We will communicate with you primarily in the form of push alerts and emails with your permission. Please note that even if you unsubscribe or opt-out, we may still send you operational App and Services related communications.
If information is collected which is later determined to be unnecessary or unsolicited then it will be handled in accordance with KeptMe’s data deletion policy.
Since the personal information collected could be sensitive in nature, KeptMe takes reasonable steps in line with this data classification when using and disclosing the personal information. Access controls and data security measures are defined in line with the increased sensitivity of the information.
Links to Other Web Sites
Information Disclosed to Third Parties
Enquiries or Complaints
If you have any questions or would like to file a complaint please contact our Privacy Office via:
- Email: firstname.lastname@example.org
- Post: “Privacy Department” KeptMe Pty Ltd, Suite 217, 838 Collins Street, Docklands, Victoria 3008, Australia
PLEASE READ THIS CAREFULLY AS IT WILL HAVE IMPORTANT CONSEQUENCES FOR YOU IN RELATION TO THE COLLECTION, USE AND DISCLOSURE OF YOUR PERSONAL INFORMATION YOU PROVIDE TO KEPTME.
You understand that:
- 2. We will endeavour to collect personal and/or sensitive information directly from you or a legal guardian. In certain circumstances, KeptMe may require to collect personal information from third parties, including but not limited to:
- (a) other companies owned by KeptMe Limited;
- (b) our contractors, agents, partners, suppliers or other companies who assist us in providing our services to you; and
- (c) when we collect personal information about you from an institution who uses our Services.
- 3. The purpose of KeptMe collecting your personal information is:
- (a) to process an enquiry you submit to us so we can contact and provide you with information in relation to your enquiry;
- (b) to process your request to use our Services, which include but are not limited to:
- (1) maintain a record of school or child care activities
- (2) provide a repository for individuals to document their educational and life journey.
- (e) KeptMe marketing and analytics, which will include but will not be limited to:
- (1) aggregate anonymised information for market research which may be published to improve childcare and educational practices;
- (3) improve our services (including contacting you about those improvements and asking you to participate in surveys and reviews about our products and services);
- (4) to provide you with personalised direct marketing communications (including electronic communications) from us but not from Third Parties.
- 4. If we do not collect this personal information in connection with the purposes in paragraph 3, then:
- (a) KeptMe will be unable to process your enquiry or supply you with information in relation to your enquiry;
- (b) we will be unable to provide our services to you;
- 5. Your personal information may be disclosed to the following types of people and organisations in connection with the purposes in paragraph 3:
- (a) KeptMe and its personnel;
- (b) third parties connected with the sales and after sales process including, payment platform providers, and financial institutions;
- (c) third party services providers, such as IT services providers;
- (d) third parties connected with the marketing process including, messaging service providers, marketing list providers or other third parties who assist us in providing our products and services to you; and
- (e) our contractors, agents and service providers, including but not limited to our suppliers or other companies who assist us in providing our products and services to you.
- 6. It is possible that some of the information collected via our web or mobile application may be disclosed to KeptMe’s related body corporate outside of Australia. You consent to your information being disclosed to a destination outside Australia for this purpose and you understand and acknowledge that Australian Privacy Principle 8.1 will not apply to such disclosures of your personal information.