Privacy Policy.

This Privacy Policy sets out the way in which we handle personal information and data.

1. Privacy Policy

This Privacy Policy covers the information Janison Education Group, which includes Janison Solutions Pty Ltd and Janison Insights Pty Ltd, collect about you when you use our products or services (collectively, the “Services”), our websites (collectively, the “Websites”), or other interactions (e.g. customer service inquiries, user conferences etc.) you may have with us.

This Policy also explains your choices surrounding how we use information about you, which include how you can object to certain uses of information about you and how you can access and update certain information about you.

Where we provide the Services under contract with an organisation, a separate agreement governs delivery, access and use of the Services (the “Service Agreement”), including the processing of any messages, files or other content submitted through Services accounts (collectively, “Customer Data”). The organisation (e.g. your employer or another entity or person) that entered into the Service Agreement (“Customer”) controls their instance of the Services and any associated Customer Data. If you have any questions about specific settings and privacy practices, please contact the Customer who has provided you access.

2. INFORMATION WE COLLECT AND RECEIVE

We may collect and receive Customer Data and other information and data (“Other Information”) in a variety of ways:

  • Customer Data. Customers or individuals granted access to our Services by a Customer (“Authorised User”) routinely submit Customer Data to us when using the Services.
  • Other Information. We also collect, generate and/or receive Other Information:
    • Usage Information.
      • Services metadata. When an Authorised User interacts with the Services, metadata is generated that provides additional context about the way Authorised Users work. For example, we log the features, content and links you interact with, and activity logs for all actions (e.g. assignment, modification, edit, copy, delete etc.) taken by Authorised Users when interacting with the Services.
      • Log data. As with most websites and technology services delivered over the internet, our servers automatically collect information when you access or use our Websites or Services and record it in log files. This log data may include the Internet Protocol (IP) address, the address of the web page visited before using the Website or Services, browser type and settings, the date and time the Services were used, information about browser configuration and plugins, language preferences and cookie data.
      • Device information. We collect information about devices accessing the Services, including type of device, what operating system is used, device settings, application IDs, unique device identifiers and system crash data. Whether we collect some or all of this Other Information often depends on the type of device used and its settings.
      • Location information. We receive information from you, your Customer and other third-parties that helps us approximate your location. We may, for example, use a business address submitted by your employer, or an IP address received from your browser or device to determine approximate location.
    • Cookie Information. We use cookies and similar technologies in our Websites and Services that help us collect Other Information. The Websites and Services may also include cookies and similar tracking technologies of third parties, which may collect Other Information about you via the Websites and Services and across other websites and online services.
    • Third Party Data. We may receive data about organisations, industries, website visitors, marketing campaigns and other matters related to our business from affiliates and subsidiaries, our partners or others that we use to make our own information better or more useful. This data may be combined with Other Information we collect and might include aggregate level data, such as which IP addresses correspond to zip codes or countries. Or it might be more specific: for example, how well an online marketing or email campaign performed.
    • Additional Information Provided to us. We receive Other Information when submitted to our Websites or if you participate in a focus group, contest, activity or event, apply for a job, request support, interact with our social media accounts or otherwise communicate with us.

Generally, no one is under a statutory or contractual obligation to provide any Customer Data or Other Information (collectively, “Information”). However, certain Information is collected automatically and, if some Information, such as basic user profile level information (e.g. name, email address), is not provided, we may be unable to provide the Services.

3. HOW WE USE INFORMATION WE COLLECT

Customer Data will be used by us in accordance with Customer’s instructions, including any applicable terms in the Service Agreement and Customer’s use of Services functionality, and as required by applicable law. We are a processor of Customer Data and Customer is the controller. Customer may, for example, use the Services to grant and remove access to the application, assign roles and configure settings, access, modify, export, share and remove Customer Data and otherwise apply its policies to the Services.

We use Other Information in furtherance of our legitimate interests in operating our Services, Websites and business. More specifically, we use Other Information:

  • To provide, update, maintain and protect our Services, Websites and business. This includes use of Other Information to support delivery of the Services under a Service Agreement, prevent or address service errors, security or technical issues, analyse and monitor usage, trends and other activities or at an Authorised User’s request.
  • As required by applicable law, legal process or regulation.
  • To communicate with you by responding to your requests, comments and questions. If you contact us, we may use your Other Information to respond.
  • To develop and provide additional features and improvements to functionality. We try to make the Services as useful as possible for our Customers and their Authorised Users. For example, we may improve search functionality by using Other Information to help determine and rank the relevance of content, channels or expertise to an Authorised User, make Services suggestions based on historical use and predictive models, identify organisational trends and insights, to customise a Services experience or create new features or improvements or develop new products.
  • To send emails and other communications. We may send you service, technical and other administrative emails, messages and other types of communications. We may also contact you to inform you about changes in our Services, our Services offerings, and important Services-related notices, such as security and fraud notices. These communications are considered part of the Services and you may not opt out of them. In addition, we sometimes send emails about new product features, promotional communications or other news about us. These are marketing messages so you can control whether you receive them.
  • For billing, account management and other administrative matters. We may need to contact you for invoicing, account management and similar reasons and we use account data to administer accounts and keep track of billing and payments.
  • To investigate and help prevent security issues and abuse.
  • Marketing. We may use your personal information to offer you products or services we believe may interest you, but we will not do so if you tell us not to. Where you receive electronic marketing communications from us, you may opt out of receiving further marketing communications by following the opt-out instructions provided in any relevant communication.
    If Information is aggregated or de-identified so it is no longer reasonably associated with an identified or identifiable natural person, we may use it for any business purpose. To the extent Information is associated with an identified or identifiable natural person and is protected as personal data under applicable data protection law, it is referred to in this Privacy Policy as “Personal Data.”

4. HOW WE DEAL WITH THE COLLECTION OF PERSONAL INFORMATION RELATING TO CHILDREN

When children use our Services to sit an assessment, test or exam at schools, we collect information about the children for the purposes of delivery of the assessment process only. Where the child is attending a primary or high school, we will treat consent as having been given by a parent and/or guardian once the parent and/or guardian signs and returns the relevant consent form allowing the child to participate in the assessment, test or exam. Consent forms and other notices provided by the school or other institution and signed by the parent and/or guardian will be treated as consent and notice given to the child.

We are aware of our responsibility to protect the identity of, and all information relating to, children, and students in general, from disclosure and consequently do not:

  • collect any personal information or data of children other than as required for the purposes of completion of the assessment, test or exam;
  • transfer any personal information or data obtained during the delivery of ICAS exams or other assessments, tests or exams conducted in Australia or outside of Australia;
  • transfer any personal information or data obtained during the delivery of ICAS exams or other assessments, tests or exams conducted in other international regions out of the child’s jurisdiction;
  • share any personal information or data relating to children or students with any third parties;
  • retain any personal information or data acquired during the delivery of ICAS exams or other assessments, tests or exams conducted by Janison and all such information or data is deleted from all our systems immediately upon completion of our contractual reporting to the schools and institutions offering the exams.

Any concerns of a parent and/or guardian regarding personal information or data relating to a child should be addressed to our Data Protection Officer, privacy@janison.com

5. DATA RETENTION

We will retain Customer Data in accordance with a Customer’s instructions, including any applicable terms in the Service Agreement and Customer’s use of Services functionality, and as required by applicable law. We may retain Other Information pertaining to you for as long as necessary for the purposes described in this Privacy Policy. This may include keeping your Other Information after you have deactivated your account for the period of time needed for us to pursue legitimate business interests, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes and enforce our agreements.

6. HOW WE SHARE AND DISCLOSE INFORMATION WE COLLECT

This section describes how we may share and disclose Information. Customers determine their own policies and practices for the sharing and disclosure of Information, and we do not control how they or any other third parties choose to share or disclose Information.

  • Customer’s Instructions. We will solely share and disclose Customer Data in accordance with a Customer’s instructions, including any applicable terms in the Service Agreement and Customer’s use of Services functionality, and in compliance with applicable law and legal process.
  • Customer Access. Owners, administrators, Authorised Users and other Customer representatives and personnel may be able to access, modify or restrict access to Other Information. This may include, for example, an Authorised User’s email address which could be made visible to other Authorised Users within the Customer or restricted to specific roles (e.g. manager or company admin) or security profiles.
  • Third Party Service Providers and Partners. We may engage third party companies or individuals as service providers or business partners to process Other Information and support our business. These third parties may, for example, provide virtual computing and storage services.
  • During a Change to our Business. If we engage in a merger, acquisition, bankruptcy, dissolution, reorganisation, sale of some or all of our assets or stock, financing, public offering of securities, acquisition of all or a portion of our business, a similar transaction or proceeding, or steps in contemplation of such activities (e.g. due diligence), some or all Other Information may be shared or transferred, subject to standard confidentiality arrangements.
  • Aggregated or De-identified Data. We may disclose or use aggregated or de-identified Other Information for any purpose. For example, we may share aggregated or de-identified Other Information with prospects or partners for business or research purposes, or as part of new product offerings or features provided to Customers which provide anonymised benchmark metrics for comparative performance between Customers.
  • To Comply with Laws. If we receive a request for information, we may disclose Other Information if we reasonably believe disclosure is in accordance with or required by any applicable law, regulation or legal process. This may include the Notifiable Data Breaches (NDB) scheme contained within the Australian Privacy Act, and data breach notification provisions contained within the European Economic Area General Data Protection Regulation (GDPR). For example, where Personal or Sensitive Information is lost or subject to unauthorised access or disclosure and will likely result in serious harm to an individual / risk to the rights and freedoms of natural persons, we will take appropriate response action in accordance with applicable law.
  • To enforce our rights, prevent fraud and for safety. To protect and defend the rights, property or safety of Janison Education Group or third parties, including enforcing contracts or policies, or in connection with investigating and preventing fraud or security issues.
  • With Consent. We may share Other Information with third parties when we have consent to do so.

7. HOW WE STORE AND SECURE INFORMATION WE COLLECT

We take security of data very seriously and use industry standard technical and organisational measures to secure the information we store. We take all reasonable steps to ensure that all Customer Data and Other Information is secure and protected from misuse, loss and unauthorised access and modification.

While we implement safeguards designed to protect your information, no security system is impenetrable and due to the inherent nature of the internet, we cannot guarantee that information, during transmission through the internet or while stored on our systems or otherwise in our care, is absolutely safe from intrusion by others.

To learn more about current practices and policies regarding security and confidentiality of the Services, please refer to your Service Agreement, contact your account manager or contact us at privacy@janison.com

8. HOW TO ACCESS AND CONTROL YOUR INFORMATION

Individuals located in certain countries, including the European Economic Area, have certain statutory rights in relation to their personal data. Subject to any exemptions provided by law, you may have the right to request access to Information, as well as to seek to update, delete or correct this Information. You can usually do this using the settings and tools provided in your Authorised User account.

Customers determine their own policies to control the level of access Authorised Users have to directly update or correct information contained within our application. In circumstances where Authorised Users do not have permissions to make updates or corrections directly, they may contact the Customer to request the update, correction, or removal of Personal Data under their control. Our personnel have limited ability to access Customer Data. If you wish to make your request directly to us, please provide the name of our Customer who submitted your data on our solution. We will refer your request to that Customer and will support them as needed in responding to your request within a reasonable timeframe.

To the extent that our processing of your Personal Data is subject to the General Data Protection Regulation, we rely on its legitimate interests, described above, to process your data. We may also process Other Information that constitutes your Personal Data for direct marketing purposes, and you have a right to object to our use of your Personal Data for this purpose at any time.

9. DISCLOSURE TO OVERSEAS RECIPIENTS

We collect information globally and may transfer, process and store your information outside of your country of residence, to wherever we, our business partners, our resellers or our third-party service providers operate for the purpose of providing you the Services. Whenever we transfer your information, we take steps to protect it. The countries in which these recipients may be located will vary from time to time, but may include France, Singapore, India, Canada, Germany, New Zealand, the United Kingdom, the United States of America and other countries we provide services or engages subcontractors.

In the event of any contractual restrictions on the sharing of personal information and data either in Australia or overseas, we will ensure that no such information will be shared for any purpose other than in accordance with our contractual obligations.

10. CHANGES TO OUR PRIVACY POLICY

We may change this Policy from time to time. Laws, regulations and industry standards evolve, which may make those changes necessary, or we may make changes to our business. We will post the changes to this Policy on our website and encourage you to review our Privacy Policy to stay informed. If we make changes that materially alter your privacy rights, we will provide additional notice, such as via email or through the Services. If you disagree with the changes to this Privacy Policy, Customers may speak with their account manager or contact us at privacy@janison.com

11. CONTACTING US

Your information is controlled by Janison Education Group. If you have questions or concerns about how your information is handled, please direct your inquiry to our data protection officer at privacy@janison.com