Privacy Policy
Summary
Below is the Cura Privacy Policy. We strongly encourage you to read the whole document. However, we’ve summarised it if you want to quickly get the gist of how we protect your privacy:
Cura’s privacy procedures are in line with the Australian Privacy Principles (APPs) as set out in the Privacy Act 1988 (Cth) (Privacy Act).
We collect and store a range of data about you, both directly (for example, when you provide it to us via a website) and indirectly (for example, records on how you interacted with the platform, like whether you clicked a button or not).
We don’t use your data for any purpose other than to provide you with the Cura service, or to provide you with pertinent updates.
We take all reasonable steps to ensure the security and integrity of your Personal Information.
We don’t access Personal Information we store on your behalf without your consent.
In the unlikely event of a data breach which is likely to result in serious harm, we will notify you and the Australian Information Commissioner (Commissioner).
We may, from time to time, review and update this Privacy Policy, including for the purposes of taking into account new laws, regulations and technology. All Personal Information held by us will be governed by our most recent Privacy Policy. This can be accessed through our website (https://www.curaeducation.com/) or through the Cura platform (https://platform.curaeducation.com/). Our most recent Privacy Policy will apply to our collection, use and disclosure of Personal Information.
What information we collect
Cura collects several types of personal information about people who interact with us, both offline and online. Under the Privacy Act, personal information is information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information is true or not, and whether recorded in a material form or not (Personal Information).
Contacting us
If you write to us via email or one of our contact forms, for example when asking for assistance or making a sales enquiry, we’ll keep a record of that correspondence for future reference. The same applies to when you fill out one of our surveys or feedback forms.
Interacting with Cura
This Privacy Policy together with Cura’s usage terms and conditions (Cura Terms of Use) govern how we use, collect, or disclose Personal Information provided on and to Cura. By using Cura you agree to the terms and conditions contained in this Privacy Policy and the Cura Terms of Use. Both the Privacy Policy and the Cura Terms of Use are available on Cura’s website and on the Cura platform.
Upon account activation, we request that you provide your school name as well as your email address, full name and password. We may also request the contact details of a number of staff at your school, such as of your accounts department and I.T. support staff. We ask for this information so that we can personalize your account, better assist you using Cura, and communicate to you about important Cura updates.
Information we collect on your behalf
Cura provides a flexible interface for schools to collect a range of information, such as files, text, photos, videos and much more, from their students. As we are not specifically aware of the nature of this information, we treat it as Personal Information.
Anonymous student accounts
Cura doesn’t require your students’ real names to operate, though we believe it makes life easier for teachers! You have the option of entering pseudonyms for your students instead of their real names if you wish. Some customers provide their students with aliased numeric or random email addresses for use with online services, avoiding the need to store identifying information about them.
Please remember that if you provide Personal Information about other individuals to us, you must ensure that you have informed those individuals that you are providing their Personal Information to us and that you have obtained their consent and advised them of our Privacy Policy.
Indirect collection of information
Aside from the information you directly provide, we may also collect Personal Information about how teachers and students interact with us, which we refer to as ‘metadata’. For example, we collect and store information about when you click certain buttons or how far you scroll on a page – something that is increasingly common with modern websites.
Collection of metadata is undertaken for two reasons:
To learn more about how our users interact with Cura, as part of our continued efforts to improve user experience.
To calculate interesting information about learners, such as the time taken to complete a particular question within an activity.
Links to external websites
If you follow any links to third party external websites from Cura, the Privacy Policy and the Cura Terms of Use will not apply to those websites which may have their own policies relating to privacy and data collection and website usage. If you choose to access any linked website or to provide any Personal Information on such websites you should review their policies and terms of use to learn more about how they may use your Personal Information. We are not responsible for and will not be liable for the operations or policies of any third party external website.
Unsolicited information
In some circumstances we may receive Personal Information that we have not requested. If this occurs, we will comply with our obligations under the Privacy Act. You acknowledge that we may de-identify and/or destroy this information unless we are required to keep it by law.
Use and disclosure of your personal information
Your privacy is of utmost importance to us and we spend a great deal of time and effort ensuring that your data is kept safe and secure.
The Personal Information you provide us is yours. We don’t claim any ownership of it whatsoever. We do not use this Personal Information for any purpose other than to provide you with the Cura service, which may include the following:
to provide you with information, products or services you have requested;
to provide you with an account, including evaluating and processing your application for a account;
to manage your account;
to promote and market our products and services to you, including to communicate with you via email newsletters;
to personalize and customize your experiences on Cura;
to help us research the needs of our customers;
to conduct research for the purposes of improving existing products or services or creating new products or services;
to provide you with ongoing information about us and our activities;
to allow us to provide third party information and offers in which we believe you may be interested;
to use aggregated or de-identified information for the purposes of data analysis, research and reporting;
to comply with regulatory or other legal requirements;
for purposes related to the recruitment and employment of our personnel and providing internal services to our staff; and
for any other use required or permitted by law or any other purpose communicated to you at the time that the Personal Information was collected or for which you provided your consent.
We may use your Personal Information for a secondary purpose if that secondary purpose is related to the purposes listed above, if we have your consent or if otherwise provided for under the Privacy Act.
Generally, we will only collect and use your Personal Information in accordance with this Privacy Policy. In the event that we collect or use Personal Information in ways other than as stated in this Privacy Policy, we will ensure that we do so in accordance with the Privacy Act.
We do not use your Personal Information to build a profile on you to sell to others, or to target advertising to you now or in the future. If you choose to close your account with Cura we will no longer use your Personal Information. Except as otherwise may be required in this Privacy Policy, we will not access the Personal Information you have provided us unless you ask us to (usually in connection with a support enquiry) or if we’ve got reason to believe we need to do so to investigate or prevent a violation of our Cura Terms of Use.
Access to data within a school
We provide extensive controls to allow schools to manage who can access the information stored on behalf of that school. Such information includes instructions, questions, student work, student results, comments teachers have entered about students, and so on. Accordingly, your Personal Information may be accessible to other users at your school.
Access to data between schools
Cura is designed to keep each school’s data completely isolated. We do not disclose school-specific data (such as content, student work, student results etc.) across schools even if, as a Cura user, you are a member of more than one. However, if you accept an invitation to join another school’s Cura account we will disclose your full name and email address to that school.
Direct marketing
From time to time we may use your Personal Information to provide you with direct marketing materials if you would reasonably expect us to or if you consent to receive direct marketing materials. We will seek your consent to provide you with direct marketing materials if we have obtained your Personal Information from a third party. Direct marketing material may include promotional material about us or important updates about our services. We try and keep these to a minimum, while still providing you with the information you need or would probably want to know. We always give you the ability to unsubscribe from product update emails.
We never send email marketing to student email addresses.
Service providers
We may also disclose your Personal Information to a Cura host or service providers in certain limited circumstances, for example when Cura experiences a technical problem or to ensure that it operates in an effective and secure manner. To the extent that we do share your Personal Information with a service provider, we would only do so if that party has agreed to comply with our privacy standards as described in this Privacy Policy.
We may also share non-personal, de-identified and aggregated information for research or promotional purposes in connection with providing requested information or services to you, or for the purpose of improving our services. We will not sell your Personal Information to third parties for marketing purposes.
Legal disclosure of your data
We won’t provide law enforcement authorities with access to your Personal Information unless required by law, is otherwise permitted by the Privacy Act, or is with your consent. We’ll always let you know if an authority does make such a request, unless we’re legally prevented from doing so.
How and where we store your information
Your data is securely stored within jurisdiction-specific Amazon Web Services facilities. These are state-of-the-art datacentre that have been independently accredited for information security. As you would expect, the physical security of servers and other infrastructure is tightly controlled according to industry best practice.
In addition to a strong security focus, this datacentre has also been designed to be resilient to failure, featuring multiple separate power supply systems, independent network links and a range of other measures to ensure servers are always available.
On some occasions, your Personal Information may be disclosed outside of Australia to an entity in a foreign country, including entities in which we have an ownership interest or to third party service providers (Overseas Entities). The countries in which these Overseas Entities are located include the United States of America.
It is possible that the Overseas Entities may be subject to foreign laws that do not provide the same level of protection of information as in Australia. We take reasonable steps to ensure that the Overseas Entities do not breach the APPs and that they are obliged to protect the privacy and security of your Personal Information and use it only for the purpose for which it is disclosed.
Security
Cura employs industry best practice to secure your data and prevent access by unauthorised parties. For example:
All network communication between Cura and your web browser is encrypted.
Passwords are only stored in an encrypted form.
A sophisticated access control system is built into the core of Cura that manages the security of each piece of data you provide us, ensuring that only those who have been nominated can access it.
Only specific Cura staff members are able to gain access to the data we store on your behalf.
We log all actions performed on Cura by user and IP address allowing us to track down unauthorised access for as long as our logs are kept.
NDB scheme
Part IIIC of the Privacy Act established the Notifiable Data Breaches Scheme (NDB scheme) in Australia. The NDB scheme sets out obligations for notifying affected individuals and the Commissioner about a data breach which is likely to result in serious harm.
Where serious harm to affected individuals is likely, we will notify those individuals and the Commissioner in accordance with our legal obligations. You may contact our Privacy Officer (details set out below) should you require additional information.
Deleting Personal Information from Cura
We will keep your Personal Information only for as long as required for our business purposes and otherwise as required by Australian law. Where we no longer need to keep your Personal Information, we will take reasonable steps to destroy or de-identify your Personal Information.
You may request the deletion of your Personal Information from Cura upon account closure. Personal Information will be destroyed or de-identified from our live systems as soon as practical, though may persist for a reasonable period of time in backups. Note that this Personal Information removal includes all Personal Information you or your teachers and students have uploaded or provided to Cura that we’ve managed on your behalf, but not our account-keeping records on you, which we’ll keep for future reference.
Updating and correcting your Personal Information
We will take reasonable steps to ensure that the Personal Information that we hold is accurate, up-to-date and complete. You can update your Personal Information at any time by contacting us. We welcome any changes to your Personal Information so as to keep our records up to date.
Requesting your Personal Information
You are entitled to access Personal Information that we hold about you. If you request access to your Personal Information, we will grant your request unless providing you with access would unreasonably impact upon the privacy of others or is not otherwise permitted under the APPs or at law. If we refuse your request to access your Personal Information, we will provide you with written reasons for the refusal.
A request for access can be made to support@curaeducation.com.
How you can contact us, find out more information or make a complaint
If you feel that your privacy has not been respected or that we have conducted ourselves inconsistently with this Privacy Policy, the APPs, a registered APP Code and/or the Privacy Act in respect of your Personal Information, or for any other queries, problems, complaints or communication in relation to this Privacy Policy, please address them to the Privacy Officer at support@curaeducation.com. We’ll be in touch as soon as practical to address your concerns.
Cura Education Pty. Ltd ACN Level 7, 180 Flinders St Melbourne VIC 3000 Australia
You can find out more information about the Privacy Act and the APPs from the Office of the Australian Information Commissioner. The Information Commissioner may be contacted at www.oaic.gov.au or by email at enquiries@oaic.gov.au.