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KeptMe Privacy Policy

KeptMe Pty Ltd (“KeptMe,” “we,” “us,” or “our”) operates the KeptMe application and related websites, each with links to this privacy policy (each, an “App” or a “Site”, respectively) and a number of related services (all such services, “Services”). Because we gather important information from users of the Sites and Services, we have established this Privacy Policy as a means to communicate our information collection, use and dissemination practices. If you have any questions or concerns or complaints about our Privacy Policy or our information collection or processing practices, or if you want to report any privacy violations to us, please contact us at support@keptme.com or at “Privacy Department” KeptMe Pty Ltd, Suite 217, 838 Collins Street, Docklands, Victoria 3008, Australia. A Note to Users Outside of Australia. If you are a non Australian user of the App or Services, by visiting the Site and/or providing us with information, you acknowledge and agree that your Personal Information may be processed for the purposes identified in the Privacy Policy.

Definitions

“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

At KeptMe and our related entities, we are committed to protecting and maintaining the accuracy, confidentiality and security of your personal information as a client or user of our Services. This Privacy Policy describes the personal and/or sensitive information we collect from or about you, how we use that information, and to whom and in what circumstances we disclose that information.

This Privacy Policy (“Policy”) applies to all commercial and business relationships in which KeptMe is engaged. The Policy is intended to comply with privacy legislation relating to commercial activity in all jurisdictions in which KeptMe operates, where such legislation is in force.

 

How We Collect Information

Personal 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.

Purpose Type Uses Disclosures
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

Institution Information:
Such as entries, pages, messages

Personal and Sensitive Information:
Such as photos, videos, geo-location, comments, messages

Payment Information:
Such as bank account or credit card numbers

 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
  • Third party service providers utilised in connection with our Services (including IT service providers, payment providers and Wireless carriers);
  • Other authorised users based on context and access permissions;
  • As requested by you for sharing on Third Party Sites (like social networks);
  • Institutions collecting information on your behalf;
  • Related bodies corporate;
  • As required or authorised by law.
Application Support Contact Information: Such as Email address To provide a response to your support request
  • Third party service providers utilised in connection with our Services (including IT service providers, payment providers and Wireless carriers);
  • Related bodies corporate;
  • As required or authorised by law.
General Enquiries Contact Information: Such as Email address To provide a response to your enquiry
  • Third party service providers utilised in connection with our Services (including IT service providers and Wireless carriers);
  • Related bodies corporate;
  • As required or authorised by law.
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
  • Institutions collecting information on your behalf;
  • Related bodies corporate;
  • As required or authorised by law.

 

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.

Our App(s) and Services may enable you to post content to Third Party sites (e.g., Facebook or Twitter). If you choose to do so, we will provide information to such sites in accordance with your elections. You acknowledge and agree that you are solely responsible for your use of those websites and that it is your responsibility to review the terms of use and privacy policy of the third party provider of such sites. We will not be responsible or liable for: (i) the availability or accuracy of such sites; (ii) the content, products or services on or availability of such sites; or (iii) your use of any such sites.

 

Anonymous Information

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.
  • Log Files. As is true of most websites, we gather certain information automatically and store it in log files. This information includes IP addresses, browser type, Internet service provider (“ISP”), referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information to analyze trends, administer the Site, track users’ movements around the Site, gather demographic information about our user base as a whole, and better tailor our Services to our users’ needs. For example, some of the information may be collected so that when you visit the Site or the Services again, it will recognize you and the information could then be used to serve advertisements and other information appropriate to your interests. Except as noted in this Privacy Policy, we do not link this automatically-collected data to Personal Information.
  • Cookies. Like many online services, we use cookies to collect information. “Cookies” are small pieces of information that a website sends to your computer’s hard drive while you are viewing the website. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Site. This type of information is collected to make the Site more useful to you and to tailor the experience with us to meet your special interests and needs. We use Google Analytics to help analyse how users use the Site. Google Analytics uses Cookies to collect information such as how often users visit the Site, what pages they visit, and what other sites they used prior to coming to the Site. We use the information we get from Google Analytics only to improve our Site and Services. Google Analytics collects only the IP address assigned to you on the date you visit the Site, rather than your name or other personally identifying information. We do not combine the information generated through the use of Google Analytics with your Personal Information. Google’s ability to use and share information collected by Google Analytics about your visits to the Site is restricted by the Google Analytics Terms of Use and the Google Privacy Policy.
  • 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.

Consent

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

Personal 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).

 

Anonymous Information

We may use Cookies to keep track of logins and personalize your experience (including by tailoring content to you). We may use other Anonymous Information for our business purposes, including to enhance the Sites or Services, improve the content of our software, and customize the App, Sites or Services to you. We may also use your Anonymous Information to contact you and/or market our products and services to you on our Sites or through our Services.

 

How We Disclose Information

Personal Information

We also disclose certain Personal Information: To third party vendors who help us provide the Services or the Sites; To third parties to whom you ask us to send Personal Information; To a parent company, any subsidiaries, joint ventures, or other companies under a common control (collectively, “Affiliates”), in which case we will require our Affiliates to honor this Privacy Policy; In connection with or during negotiation of any merger, financing, acquisition or dissolution, transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets. In the event of an insolvency, bankruptcy, or receivership, Personal Information may also be transferred as a business asset. If another company acquires our company, business, or assets, that company will possess the Personal Information collected by us and will assume the rights and obligations regarding your Personal Information as described in this Privacy Policy If we believe in good faith that such disclosure is necessary to (a) resolve disputes, investigate problems, or enforce our Terms of Service; (b) comply with relevant laws or to respond to requests from law enforcement or other government officials relating to investigations or alleged illegal activity, in which case we can (and you authorize us to) disclose Personal Information without subpoenas or warrants served on us; or (c) protect and defend our rights or property or the rights and property of you or third parties. Our Apps and Services may enable you to post content to SNSs (e.g., Facebook or Twitter). If you choose to do this, we will provide information to such SNSs in accordance with your elections. You acknowledge and agree that you are solely responsible for your use of those websites and that it is your responsibility to review the terms of use and privacy policy of the third party provider of such SNSs. We will not be responsible or liable for: (i) the availability or accuracy of such SNSs; (ii) the content, products or services on or availability of such SNSs; or (iii) your use of any such SNSs.

 

Anonymous 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

You can review and/or change certain of your Personal Information by logging into the Site or the App and accessing your account. You authorize us to use and disclose any new or modified information that you provide in accordance with this Privacy Policy, and you agree that we are under no obligation to delete or modify information that you have previously chosen to provide us. Upon your request, we will close your Account. We may retain your Personal Information to comply with laws, prevent fraud, resolve disputes, troubleshoot problems, assist with any investigations, enforce our Terms of Use, and take other actions otherwise permitted by law. You can stop all collection of information by the App(s) by uninstalling the App(s) or ceasing to use our web services. You may use the standard uninstall processes as may be available as part of your mobile device or via the mobile application marketplace or network.

Access And Correction of Your Information

You can review and/or change most pieces of your Personal Information by logging into the App(s) and accessing your account. You authorize us to use and disclose any new or modified information that you provide in accordance with this Privacy Policy. Any data provided may be retained and visible to authorized users even when it is removed from your view.

 

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

Upon your request, we will close your Account. We may retain your Personal Information to comply with laws, prevent fraud, resolve disputes, troubleshoot problems, assist with any investigations, enforce our Terms of Use, and take other actions otherwise permitted by law. You can stop all collection of information by the App(s) by uninstalling them.

 

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.

Children’s Privacy

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.

 

If you are located in the European Union or other regions with laws governing data collection and use that may differ from Australia law, please note that you are transferring information, including personal or sensitive information, to a country and jurisdiction that may not have the same data protection laws as your jurisdiction, and you consent to the transfer of information and the use and disclosure of information about you, including personal and sensitive information, as described in this Privacy Policy.

Direct Marketing

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.

Unsolicited Information

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.

Sensitive Information

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

We are not responsible for the practices employed by websites linked to from within the App(s) or Services, nor the information or content contained therein. Please remember that when you use a link to go from the App(s) to another website, our Privacy Policy is no longer in effect and your activities on that third party website is subject to such third party website’s own rules and policies.

 

Governing Law

This Privacy Policy is governed by the laws in force in Australia. You agree to submit to the exclusive jurisdiction of the courts located in Australia.

 

Information Disclosed to Third Parties

This Privacy Policy addresses only our use and disclosure of information we collect from and/or about you on the Sites and Services. If you disclose information to others, the use and disclosure restrictions contained in this Privacy Policy will not apply to any third party. We do not control the privacy policies of third parties, and you are subject to the privacy policies of those third parties where applicable. The Sites may contain content or links to other websites that are not owned or controlled by us. We have no control over, do not review and are not responsible for the privacy policies of or content displayed on such other websites. When you click on such a link, you will leave our Site and go to another site. During this process, another entity may collect Personal Information or Anonymous Information from you. The Site may also contain links to other websites controlled by us but which operates under different privacy policies. Please review the privacy policy of any new site you visit.

Changes to this Privacy Policy

This Privacy Policy is subject to revision from time to time basis. We will post any revised version at http://www.keptme.com/privacypolicy. If we make any material changes to it, we will also send you notice to the last email address you provided to us. Continued use of our Services following notice of such changes will indicate your acknowledgement of such changes and agreement to be bound by the terms and conditions of such changes.

Enquiries or Complaints

If you have any questions or would like to file a complaint please contact our Privacy Office via:

  • Email: support@keptme.com
  • Post: “Privacy Department” KeptMe Pty Ltd, Suite 217, 838 Collins Street, Docklands, Victoria 3008, Australia

 

Appendix

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:

  • 1. This Privacy Policy is subject to revision from time to time basis. We will post any revised version at http://www.keptme.com/privacypolicy. If we make any material changes to it, we will also send you notice to the last email address you provided to us. Continued use of our Services following notice of such changes will indicate your acknowledgement of such changes and agreement to be bound by the terms and conditions of such changes.
  • 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.
  1. KeptMe’s full Privacy Policy sets out the process so you can access and correct any of your personal information collected by us as well as to how you can make a complaint if KeptMe has breached the Privacy Act in the handling of your personal information. Our Privacy Policy is available at http://www.keptme.com/privacypolicy. By continuing with an enquiry, purchase of our services, request to join our mailing list, or other activity through use of this website or our mobile application, indicates that you have read this collection notification and acknowledge that your personal information will be collected, used and disclosed in accordance with this collection notice and in KeptMe’s Privacy Policy and, as necessary, that you give your voluntary express consent to KeptMe collecting, using, storing, disclosing and disposing of your personal information in this manner.


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