Revision: June 16, 2015
This document declares the undertakings by EducatorPages.com in relation to its
handling of Your Data.
EducatorPages.com undertakes to collect Your Data by means that are:
- legal; and
If you visit EducatorPages.com's web-site, your web-browser
automatically discloses, and EducatorPages.com's web-server automatically logs,
the following information: the date and time, the IP address from which you issued
the request, the type of browser and operating system you are using, the URL of
any page that referred you to the page, the URL you requested, and whether your
request was successful. This data may or may not be sufficient to identify you.
Any additional data that you provide, e.g. in a web-form, may also
be logged. This data may or may not be sufficient to identify you.
Any additional data that your web-browser automatically provides
may also be logged. This will be the case, for example, if your browser has previously
been requested to store data on your computer in 'cookies'
and submits them each time you request a web-page within a particular domain (such
as EducatorPages.com or any subdomain thereof). This data may or may not be sufficient
to identify you.
If you disclose personal data to EducatorPages.com in conjunction with an identifier
such as your name or your credit-card details, EducatorPages.com will
collect Your Data. Moreover, any data that becomes available to EducatorPages.com
through any of the means described in the preceding paragraphs may be able to be
associated with that identifier, and hence become Your Data.
Subject to the qualifications immediately below, EducatorPages.com undertakes to
collect Your Data from you and not from other parties. This undertaking
is qualified as follows:
- where EducatorPages.com reasonably considers that the protection of its financial
interests requires that it gather Your Data from other sources, or from additional
sources. This applies in particular where EducatorPages.com has a lending exposure
to you, and seeks information about your creditworthiness;
- where EducatorPages.com reasonably considers that its capability to deliver quality
services to you will be materially enhanced by gathering Your Data from other sources.
This applies in particular to consumer profile data.
Where EducatorPages.com collects Your Data from sources other than you,
- to do so only by legal means;
- to do so only with your Consent; and
- to declare to you what sources it uses, and under what circumstances.
EducatorPages.com undertakes to declare the purpose of collection
in a manner which is clear and meaningful, and to avoid vague, highly inclusive
statements such as 'to support our operations'.
EducatorPages.com undertakes to store Your Data in a manner that
ensures security against unauthorised access, alteration or deletion, at a level
commensurate with its sensitivity.
EducatorPages.com undertakes to store Your Data only in jurisdictions
where data protections are at least equivalent to those required under the OECD
EducatorPages.com undertakes to transmit Your Data in a manner
that ensures security against unauthorised access, alteration or deletion, at a
level commensurate with its sensitivity.
EducatorPages.com undertakes to implement appropriate measures to ensure security
of Your Data against inappropriate behaviour by EducatorPages.com's staff-members
and contractors. These include:
- training for staff in relation to privacy;
- access control, to limit access to Your Data to those staff and contractors who
have legitimate reasons to access it;
- particularly in the case of sensitive data, audit trails of accesses, including
the identities of staff and contractors accessing the data;
- reminders to staff and contractors from time to time about the importance of data
privacy, and the consequences of inappropriate behaviour;
- declaration of appropriately strong sanctions that are to be applied in the event
of inappropriate behaviour
- clear communication of policies and sanctions; and
- processes to audit, to investigate and to impose sanctions.
Use refers to the application of Your Data by any part of EducatorPages.com, or
any staff-member or contractor of EducatorPages.com in the course of their work.
EducatorPages.com undertakes to use Your Data only for:
- the purposes for which it was collected;
- such other purposes as are subsequently agreed between EducatorPages.com
- such additional purposes as may be required by law. In these circumstances,
EducatorPages.com will take any reasonable steps available to it to communicate
to You that the use has occurred, unless it is precluded from doing so by law; and
- such additional purposes as are authorised by law (in particular
to protect EducatorPages.com's interests, e.g. if it believes on reasonable
grounds that You have failed to fulfil your undertakings to EducatorPages.com or
have committed a breach of the criminal law).
EducatorPages.com undertakes to use Your Data only if it has demonstrable relevance
to the particular use to which it is being put.
EducatorPages.com undertakes to use Your Data in such a manner as to take into account
the possibility that it is not of sufficient quality for the purpose,
e.g. because it is inaccurate, out-of-date, incomplete, or out-of-context.
Disclosure refers to making Your Data available to any party other than EducatorPages.com
and You. The term disclosure may include many different conditions of data transfer,
including selling, renting, trading, sharing and giving.
EducatorPages.com undertakes to disclose Your Data only under the following circumstances:
- in the course of business being conducted between You and EducatorPages.com,
where disclosure is necessary to a contractor, such as a transport company. Where
Your Data is disclosed in this way, EducatorPages.com undertakes to exercise control
over EducatorPages.com's contractors to ensure that their actions are compliant
with these Terms;
- for the purpose of improving SPAM control within the EducatorPages.com system,
where third-party services may be used in a secure and controlled manner to detect
SPAM or otherwise malicious content posted by You or other users
- in other circumstances that are directly implied by the purpose agreed between
You and EducatorPages.com at the time of data collection or subsequently.
Where Your Data is disclosed in this way, EducatorPages.com undertakes to exercise
control over EducatorPages.com's contractors to ensure that their actions are
compliant with these Terms;
- with your consent, or at your request;
- where required by law, such as a provision of a statute, or a court
order such as a search warrant or sub poena. In these circumstances, EducatorPages.com
will take any reasonable steps available to it to communicate to You that the disclosure
has occurred, unless it is precluded from doing so by law;
- where permitted by law (e.g. the reporting of suspected breach
of the criminal law to a law enforcement agency; and in an emergency, where EducatorPages.com
believes on reasonable grounds that the disclosure of Your Data will materially
assist in the protection of the life or health of some person), provided that EducatorPages.com
will apply due diligence to ensure that the exercise of the permission is justifiable.
In all cases, EducatorPages.com undertakes to disclose only such of Your Data as
is necessary in the particular circumstances.
Data Retention and Destruction
Subject to the qualifications immediately below, EducatorPages.com undertakes:
- to retain Your Data only as long as is consistent with its purpose;
- to destroy Your Data when its purpose has expired, and to do so
in such a manner that Your Data is not subsequently capable of being recovered.
This undertaking is qualified as follows:
- Your Data may be retained in EducatorPages.com's logs, backups and audit
trails within short-term retention cycles that are devised to protect the
company's operations. In such cases, Your Data will be destroyed in accordance
with those cycles;
- Your Data may be retained beyond the expiry of its purpose if that is required
by law, such as a provision of a statute, or a court order such as a search
warrant or sub poena, or a warning by a law enforcement agency that delivery of
a court order is imminent. In these circumstances, EducatorPages.com:
- will take any reasonable steps available to it to communicate to You that Your Data
is being retained, unless it is precluded from doing so by law; and
- will only retain Your Data while that provision is current, and will then destroy
- Your Data may be retained beyond the expiry of its purpose if it is authorised
by law (in particular to protect EducatorPages.com's interests, e.g.
if it believes on reasonable grounds that You have failed to fulfil your undertakings
to EducatorPages.com or have committed a breach of the criminal law). In these circumstances,
EducatorPages.com will only retain Your Data while that situation is current, and
will then destroy Your Data.
Access by You to Your Personal Data
EducatorPages.com undertakes to provide you with access to Your
Data, subject to only such conditions and processes as are reasonable in the circumstances.
In particular, EducatorPages.com undertakes to enable access:
- without unreasonable delay; and
- without cost.
EducatorPages.com undertakes to establish and operate identity authentication
protections for access to Your Data that are appropriate to its sensitivity,
but practical. This may involve some inconvenience; for example, relatively straightforward
procedures may be involved in order to provide you with access through a channel
that you have previously registered with EducatorPages.com (such as a particular
email-address), but may impose more onerous procedures if you wish to use some other
In the event that you dispute some aspect of Your Data, EducatorPages.com undertakes
to take reasonable steps in relation to the amendment, supplementation or deletion
of Your Data.
- not to seek access for frivolous purposes, or unreasonably frequently;
- to accept that deletion of some data may not be consistent with the provision of
particular services by EducatorPages.com to you.
Information about Data-Handling Practices
EducatorPages.com undertakes to make information available to you about the manner
in which EducatorPages.com handles your data:
- in general terms, in a readily accessible manner; and
- in more specific terms, on request.
Where Your Data is disclosed to a contractor, EducatorPages.com undertakes to make
information available to you on request about the manner in which EducatorPages.com's
contractors handle your data.
EducatorPages.com undertakes to ensure that the information provided is meaningful,
and addresses your concerns.
- not to seek such information for frivolous purposes, or unreasonably frequently;
- to accept that the disclosure of excessive detail may harm the security of Your
Data and EducatorPages.com's business processes, and may harm EducatorPages.com's
Handling of Enquiries, General Concerns
If you have enquiries, general concerns, or complaints about these Terms, or about
EducatorPages.com's behaviour in relation to these Terms, you undertake:
- to communicate them in the first instance:
- to EducatorPages.com only;
- in sufficient detail;
- through a channel made available by EducatorPages.com for that purpose;
- to provide one or more channels for communications to EducatorPages.com,
which are convenient to users;
- to promptly provide a response to the communication, where necessary,
in an appropriate and meaningful manner.
You further undertake to not pursue EducatorPages.com through any Regulator
or the media:
- until and unless EducatorPages.com has had a reasonable opportunity to respond to
the initial communication; and
- while EducatorPages.com and you are conducting a meaningful dialogue about the matter.
EducatorPages.com declares that its undertakings in these Terms are intended to
create legal obligations, and that those obligations are intended
to be enforceable under appropriate laws in appropriate jurisdictions.
These include laws relating to data protection, privacy, fair trading, corporations
and criminal laws.
You undertake to seek enforcement only in a jurisdiction that is
relevant to the transactions that have taken place between You and EducatorPages.com,
in particular the jurisdiction in which you live or in which you performed the relevant
acts, and the jurisdiction in which EducatorPages.com is domiciled or performed
the relevant acts.
If you wish to discover the relevant laws in any particular jurisdiction,
EducatorPages.com draws your attention to the following resources:
Changes to These Privacy Undertakings
- not to unilaterally make any material change to these Terms in a manner that reduces
the protections for Your Data;
- to take all practicable steps to prevent any company that acquires this company
or any of its relevant assets from materially changing the Terms applicable to Your
Data in a manner that reduces the protections for Your Data;
- where it is considering making changes to these Terms, or creating more specific
Terms relating to specific services, to consult with appropriate representative
and advocacy organisations;
- where it makes changes to these Terms, to ensure that the differences between successive
versions are readily accessible;
- to maintain all prior versions of these Terms in such a manner that they are dated,
and readily accessible.
EducatorPages.com means the EducatorPages.com web site and any
current or future software applications designed to work with the data and controls
stored as part of the EducatorPages.com system.
Your Data means data that is capable of being associated with you,
whether or not it includes an explicit identifier such as your name or customer
number. In particular, it encompasses all data that EducatorPages.com is capable
of correlating with you, using such means as server-logs and cookie-contents.
Your Data does not refer to data that can no longer be associated with you.
This includes aggregated data that does not and cannot identify the individuals
whose data are included in the aggregation.
Consent means your concurrence with an action to be taken by EducatorPages.com.
Consent may be express or implicit, but in either case must be informed and freely-given.
This document is a licensed adaptation of the Privacy Statement Template published by Xamax Consultancy
Pty Ltd. The Template has been adapted to the extent necessary to customise it to
the context in which EducatorPages.com operates.