MOODLECLOUD PRIVACY POLICY

INTRODUCTION

Moodle Pty Ltd (ABN 55 116 513 636), our successors and assignees (collectively referred to as "we", "us" and "our") endeavour to comply with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (Privacy Act).

This Privacy Policy sets out our commitment to protecting the privacy of your personal information that we collect through our services as described on our website: www.moodlecloud.com and related websites (collectively referred to as "Website") or directly from you, being the person, organisation or entity that uses our Website or services (referred to as "you" or "your").

Please read this Privacy Policy carefully and contact us if you have any questions. Our contact details are at the end of this Privacy Policy.

You providing us your personal information indicates that you have sufficient opportunity to access this Privacy Policy and that you have read and accepted it. If you do not wish to provide or give us access to your personal information, then you do not have to do so, however it may affect your use of the Website or any of our services.

This Privacy Policy may be amended, including with changes, additions and deletions, from time to time at our sole discretion. The revised Privacy Policy will take effect when it is posted on our Website. Your continued use of our Website and services following any amendments indicates that you accept the amendments. You should check this Privacy Policy regularly and prior to providing personal information to ensure you are aware of any changes and only proceed to provide personal information if you accept the new Privacy Policy.

YOUR CONSENT TO US

You consent to us collecting your personal information to provide you with our service(s) to which you are signing up, and to communicate with you via email or SMS regarding our services, promotion and for the purposes set out in this Privacy Policy.

You also consent to us providing that information to official Moodle Partners identified by us on our Website in situations including: (i) where you are referred to a Moodle Partner in case you wish to seek services from them; or (ii) as you identify yourself via means such as a referral to a specific Moodle Partner.

You consent to us collecting data regarding your use and your user's use of the Websites. We use this information to guide improvements to our services, the MoodleCloud learning platform and your MoodleCloud experience.

TYPE OF INFORMATION COLLECTED

Personal information: The type of personal information we collect may include: name, contact details including email, cell/mobile phone number, country, organisation details, payment details, IP addresses, geographical location, standard browser identification strings (including user-agent, referer, OS, and device type), preferences and opinions and any other information requested on our Website or otherwise requested by us or provided by you.

Your use of our Website: As with most online businesses, we may also collect information of about your usage of our Websites, including logs of user actions and full text actions of users are logged, data about user involvement, such as forum discussions and assignment submissions, are stored in database tables.

Your opinion and feedback: We may contact you to seek your response to questionnaires, surveys or market research to obtain your opinion and feedback. Providing this information is optional to you.

If we receive your personal information from third parties, such as Moodle Partners, we will protect it as set out in this Privacy Policy.

COLLECTION AND USE OF PERSONAL INFORMATION

We collect your personal information for purposes including:

Where we collect your personal or usage information for a specific purpose not outlined above, we may provide you with a collection notice which explains the primary purpose and any related secondary purposes for which we are collecting and using your personal information.

IF YOU DON'T PROVIDE ALL THE INFORMATION

If you do not provide some or all of the personal information requested, we may not be able to provide you with our services or to continue such service. This specifically refers to the capacity for your payment for services where applicable, and the continued provision of services.

TO WHOM WE DISCLOSE YOUR PERSONAL INFORMATION

We may disclose personal information to:

Where we disclose your personal information to other third parties including Moodle Partners for these purposes, we will request that the third party should follow this Privacy Policy regarding the use and disclosure of your personal information.

Wherever we propose to disclose your personal information to a third party not outlined above, we will provide you with a collection notice which explains the circumstances in which we might disclose your personal information.

We use data from our Website for research, development, service support and improvements, and marketing purposes. Where possible, we will de-identify personal information when used for such purposes. We endeavour to share or publish user data from our Website in an anonymous aggregated form.

COOKIES AND WEB BEACONS

When you access the Website and portal via your own secure login (Portal), we may use software embedded in our Website (such as Javascript) and place small data files (or cookies) on your computer or other device to collect information for authentication and session management, about which pages you view and how you reach them, what you do when you visit a page, the length of time you remain on the page and how we perform in providing content to you.

A cookie by itself does not tell us any personally identifiable information however, once you choose to furnish the Website with personally identifiable information, this information may be linked to the data stored in the cookie. You can set your browser to notify you when you receive a cookie and this will provide you with an opportunity to either accept or reject it in each instance.

We may use web beacons on this Site from time to time. Web beacons or clear .gifs are small pieces of code placed on a web page to monitor the visitors' behaviour and collect data about the visitors viewing a web page. For example, web beacons can be used to count the users who visit a web page or to deliver a cookie to the browser of a visitor viewing that page.

We use Google Analytics features based on Remarketing, Google Analytics Demographics and Interest Reporting. These features use first-party and third-party cookies to inform and optimise content based on your past visits to our site and assists us to collect and process data.

Google Analytics informs us of how visitors use our Website based on your browsing habits, so that we can improve our Website to make it easier for you to find the information you are seeking. Google also receives this information as you browse our Website and other websites on the Google Display Network using Remarketing. To find out how Google uses data when you use third party websites or applications, please see www.google.com/policies/privacy/partners/ or any other URL Google may use from time to time.

UNSUBSCRIBING OR OPTING OUT OF DIRECT MARKETING COMMUNICATIONS

When you sign up for any of our services, you can choose to opt in to our marketing and promotional messages.

Where we use your personal information to send you marketing and promotional information by email, we will provide you with an opportunity to opt-out of receiving such information. By electing not to opt-out, we will assume we have your implied consent to continue to receive similar information and communications in the future. We will always ensure that our opt-out notices are clear, conspicuous and easy to take up.

You may choose to restrict the collection or use of your personal information. If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time through the unsubscribe link on any marketing email communications you receive.

STORAGE AND SECURITY OF YOUR PERSONAL INFORMATION

We use data hosting facilities to provide the Website and our services. As a result, your personal information and data usage may be transferred to, stored at, managed through any of our data centres including centres in USA, Australia, Germany and Ireland. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard the information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure. Where possible, we will take reasonable measures to de-identify your personal information. We do not store hard copy personal information, or store personal information outside our cloud servers and integrated platforms.

Although you can update your billing details via the Website, we do not store your payment details, such as credit card or debit card details. These are stored in the secure PCI compliant payment gateway used by our service providers.

We endeavour to take reasonable steps in appropriate circumstances to ensure that any overseas third party service providers we engage do not breach the Australian Privacy Principles, including through contractual arrangements. Moodle Partners are located worldwide, and you are linked with a Moodle Partner with the closest country location to the country you identify in your personal information. As Moodle Partners are independent third parties and we do not have any control over how Moodle Partners collect, use or disclose your personal information. You are responsible for reviewing and ensuring you are comfortable with their privacy policy before engaging their services.

No information transmitted over the Internet can be guaranteed to be secure. We cannot guarantee the security of any information that you transmit to us, or receive from us. The transmission and exchange of information is carried out at your own risk. Although we take reasonable steps to protect the privacy and security of that information to prevent unauthorised disclosure, we cannot assure you that personal information that we collect will not be disclosed in a manner that is inconsistent with this Privacy Policy.

CHOICE AND CONSENT

Providing us with your personal information is optional to you. You can choose not to provide personal information. When you provide us with your personal information, including if you consent to the collection of personal information that is subject to a collection notice, you consent to this Privacy Policy and to us using, disclosing, transferring, holding or receiving your personal information for these purposes.

YOUR PROVISION OF THIRD PARTY INFORMATION

If you provide us with third party personal information, including information from your users, you warrant to us that you have the third party's consent to providing this information.

ACCESS TO YOUR PERSONAL INFORMATION

The personal information we hold about you, including your current linked Moodle Partner, is generally available only to you on your own Portal, other than in the event of temporary technical issues. For personal information that is not available via your Portal, you may request details of such personal information that we hold about you, in certain circumstances as set out in the Privacy Act. An administrative fee may be payable for the provision of information. We may refuse to provide you with information that we hold about you, in certain circumstances as set out in the Privacy Act.

UPDATING OR CORRECTING YOUR PERSONAL INFORMATION

Your Portal displays personal information available to us. For information we hold about you that cannot be updated by logging into the Portal and you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us by email. We rely in part upon customers advising us when their personal information changes. We will respond to any request within a reasonable time. We will endeavour to promptly correct any information found to be inaccurate, incomplete or out of date.

LINKS TO OTHER WEBSITES

Our Website may contain links to other websites of interest, including links to Moodle Partners. We do not have any control over those websites. We are not responsible for or liable for the protection and privacy of any information which you provide whilst visiting such websites, and other than Moodle Partners, such websites are not governed by this Privacy Policy.

COMPLAINTS

If you have any queries in relation to our Privacy Policy if you believe that we have breached the Australian Privacy Principles and would like to make a complaint, please contact us at support@moodlecloud.com or via our webform at https://moodle.com/contact/. We endeavour to respond to complaints and queries within fourteen days of receipt. If you are dissatisfied with our response or if you would like more information about privacy generally, please contact the Office of the Australian Information Commissioner (see www.oaic.gov.au).

Contact

For any questions or notice, please contact our Privacy Officer at:

Moodle Pty Ltd (ABN 55 116 513 363)
Level 2, 18 Richardson Street
West Perth WA 6005
Australia
Email: support@moodlecloud.com

Last update: 25 May 2016