Last Revision: July 30, 2021
- Alto Education Pty. Ltd. is the data controller of the personal information we collect about you (i.e., the entity that determines the means and purposes of collecting, using, and disclosing the personal information).
Purpose and who we are
This Privacy Notice covers information we collect from you through our Site. Some of our Site’s functionality can be used without revealing any Personal Data, but for features or services related to our courses, Personal Data are required. In order to access certain features and benefits on our Site, you may need to submit, or we may collect, "Personal Data" (i.e., information that can be used to identify you and which may also be referred to as “personally identifiable information” or “personal information”). Personal Data can include information such as your name, email address, IP address, and device identifier, among other things. You are responsible for ensuring the accuracy of the Personal Data you submit to Alto. Inaccurate information may affect your ability to use the Site, our products or services, the information you receive when using our products, services or the Site, and our ability to contact you. For example, your email address should be kept current because that is one of the primary ways in which we communicate with you.
What you agree to by using our site
- our use of your personal information is necessary for complying with our legal obligations; or
- use of your personal information is necessary for our legitimate interests or the legitimate interests of others. Our legitimate interests are to:
- run, grow and develop our business;
- operate our Site and provide our services and products;
- select appropriately skilled and qualified suppliers;
- build relationships with partners and academic institutions;
- carry out research and statistical analysis;
- carry out marketing and business development; and
- for internal administrative and auditing purposes.
- consent, to send you certain communications or where you submit certain information to us, or where required to rely upon consent by local law.
Which legal basis applies to a specific activity will depend on the type of personal information used and the context in which it is being used.
If we rely on our (or another party’s) legitimate interests for using your personal information, we will undertake a balancing test to ensure that our (or the other party’s) legitimate interests are not out weighed by your interests or fundamental rights and freedoms which require protection of the personal information.
We may process your personal information in some cases for marketing purposes on the basis of your consent (which you may withdraw at any time as described below).
If we rely on your consent for us to use your personal information in a particular way, but you later change your mind, you may withdraw your consent by contacting us on email@example.com at any time. If you withdraw your consent, this may impact the ability for us to provide some of our services or products to you.
What information we collect
We gather two types of information about users through the Site:
- Personal Data provided directly by you or via third parties. We collect Personal Data that you provide to us when you register for a service or product, update or change your information, purchase products or services, complete a survey, sign-up for email updates, send us email messages, and/or participate in our products or services through our site or through our suppliers. We may use the Personal Data that you provide to respond to your questions, provide you the specific services or products you select, send you updates about our products and services or other Alto events, and send you email messages about Site maintenance or updates.
- Account Registration. If you register for an account on our Site, you may be required to provide us with Personal Data such as your name and email address.
- Updates. Alto may offer you the ability to receive updates via email. In order to subscribe to these Services, you may be required to provide us with Personal Data such as your name and email address.
- Forums. Alto may offer public forums from time to time (the "Forums") where you can share comments and thoughts. In order to participate in the Forums, you may be required to register with us and/or provide us with Personal Data such as your name and email address. Please keep in mind that information you post or make available in Forums will be publicly available. You should not include any personal information or other information of a personal or sensitive nature, whether relating to you or another person, in a Forum post.
- Participation in Content Offerings. Alto offers users the opportunity to participate in services and products on or through the Site. If you desire to participate in a service or product, you will be asked to provide us with certain information necessary to conduct such a service or product. This information may include, among other things, your name and email address.
If you participate in a service or a product, we may collect certain user-generated content, such as assignments you submit, peer-graded assignments, and peer grading feedback. We also collect course data, such as responses to quizzes, exams, and surveys. You should not include any Personal Data or other information of a personal or sensitive nature, whether relating to you or another person, on assignments, exams, or surveys, except for information required to participate in or submit such assignments, exams, or surveys.
- Communications with Alto. We may receive Personal Data when you send us an email message or otherwise contact us.
- Third Party Sites. We may receive Personal Data when you access or log-in to a third party site, e.g., Moodle, from our Sites. This may include the text and/or images of your Personal Data available from the third-party site.
- Partner sites. Partner sites providing service or product-related tools and services to Alto users may collect individual-level user data regarding the individual’s use of that partner site while the partner sites provide those services to Alto. The partner sites may share that data with Alto for the purpose of improving our services and products, the partner site’s services, and the individual’s education experience. These data include information such as the amount of time spent on the partner site and pages viewed.
- Third Party Payment Processing. Alto provides you with the ability to pay for our products and services using a credit card or other methods through a third-party payment processing service provider. Please note that our service provider – not Alto – collects and processes your financial information.
- Surveys. We may receive Personal Data when you provide information in response to a survey operated by us or a third-party provider.
What information we collect
- Information relating to your use of our Site. We use information relating to your use of the Site to build higher quality, more useful services, and products by performing statistical analyses of the collective characteristics and behaviour of our users, and by measuring demographics and interests regarding specific areas of our Site. We may also use this information to ensure the security of our services, products and the Site.
- Providing the Site and our services and products. We use Personal Data which you provide to us in order to allow you to access and use the Site and in order to provide any information, products, or services that you request from us.
- Technical support and security. We may use Personal Data to provide technical support to you, where required, and to ensure the security of our services, products and the Site.
- Updates. We use Personal Data collected when you sign-up for our various email or update services to send you the messages in connection with the Site or services and products. We may also archive this information and/or use it for future communications with you, where we are legally entitled to do so.
- Forums. You should not post any personally identifiable information or other information of a personal or sensitive nature, whether relating to you or another person, within a Forum post. If you choose to post personally identifiable information, such personally identifiable information may be collected during your use of the Forums. We may publish this information via extensions of our platform that use third-party services, like mobile applications. We reserve the right to reuse Forum posts that contain personally identifiable information in future versions of our services and products, and to enhance future services and products. We may archive this information and/or use it for future communications with you and/or your designee(s), and/or provide it to suppliers, business partners, or the instructor(s) associated with the courses you have taken. We may also use or publish posts submitted on the Forums without using personally identifiable information.
- Participation in Content Offerings. We use the Personal Data that we collect from you when you participate in a Content Offering through the Site for processing purposes, including but not limited to tracking attendance, progress, and completion of the Content Offerings. We may also share your Personal Data and your performance in a given Content Offering with the instructor or instructors who taught it, with teaching assistants or other individuals designated by the instructor or instructors to assist with the creation, modification, or operation of the Content Offering, and with the Content Provider(s) with which they are affiliated. We may also use the information generated when taking a Content Offering or using the Services for predictive analysis of your performance in the Content Offerings. Also, we may archive this information and/or use it for future communications with you, where we are legally entitled to do so.
- Communications with Alto business partners. We may share your Personal Data with business partners of Alto so that they may share information about their products and services that may be of interest to you where they are legally entitled to do so.
- Research. We may share general course data (including quiz or assignment submissions, grades, and forum discussions), information about your activity on our Site, and demographic data from surveys operated by us with our partners so that our partners may use the data for research related to online education.
- Disclosure to Alto operations and maintenance contractors. We use various service providers, vendors, and contractors (collectively, "Contractors") to assist us in providing our services and products to you. Our Contractors may have limited access to your Personal Data in the course of providing their products or services to us, so that we in turn can provide our services or products to you. These Contractors may include vendors and suppliers that provide us with technology, services, and/or content related to the operation and maintenance of the Site or our products and services. Access to your Personal Data by these Contractors is limited to the information reasonably necessary for the Contractor to perform its limited function for us.
- Disclosure to Acquirers. Alto may disclose and/or transfer your Personal Data to an acquirer, assignee or other successor entity in connection with a sale, merger, or reorganization of all or substantially all of the equity, business, or assets of Alto to which your Personal Data relate.
- e-Readers. If we receive any Personal Data related to the extent to which you use designated e-Readers or other devices to access Alto materials, we may archive it, and use it for research, business, or other purposes.
Retention of personally identifiable information
We keep your Personal Data for no longer than necessary for the purposes for which the Personal Data are collected and processed. The length of time we retain Personal Data for depends on the purposes for which we collect and use it and/or as required to comply with applicable laws and to establish, exercise, or defend our legal rights.
Confidentiality & security of personally identifiable information
Updating or deleting your personal data
You have certain rights in relation to your Personal Data. You can access your Personal Data and confirm that it remains correct and up-to-date, choose whether or not you wish to receive material from us or some of our partners, and request that we delete or provide you with a copy of your personal data by contacting us on firstname.lastname@example.org.
If you would like further information in relation to your rights or would like to exercise any of them, you may also contact us via email@example.com.
If you reside or are located in the EEA, United Kingdom, Switzerland, or other region that offers similar protections, you have the right to request that we:
- provide access to any Personal Data we hold about you;
- prevent the processing of your Personal Data for direct-marketing purposes;
- update any Personal Data which is out of date or incorrect;
- delete any Personal Data which we are holding about you;
- restrict the way that we process your Personal Data;
- provide your Personal Data to a third party provider of services; or
- provide you with a copy of any Personal Data which we hold about you.
We try to answer every request promptly where possible, and provide our response within the time period stated by applicable law. Keep in mind, however, that when deleting your Personal Data there may be residual information that will remain within our databases, access logs, and other records, which may or may not contain your Personal Data. Please also note that certain Personal Data may be exempt from such requests in certain circumstances, which may include if we need to retain your Personal Data to comply with a legal obligation. When you email us with a request, we may ask that you provide us with information necessary to confirm your identity.
Questions, suggestions, and complaints
If you have any privacy-related questions, suggestions, unresolved problems, or complaints, you may contact us via firstname.lastname@example.org.
If you reside or are located in the EEA, United Kingdom, Switzerland, or other region that offers similar protections, you may also make a complaint to our supervisory body for data protection matters (namely the UK Information Commissioner's Office or Dutch Autoriteit Persoonsgegevens) or seek a remedy through local courts if you believe that your rights have been breached.
International privacy practices
Our Sites are operated and managed on servers located and operated by globally distributed services. In order to provide our products and services to you, you may be sending your Personal Data outside of the country where you reside or are located. Accordingly, if you reside or are located outside of Australia, your Personal Data may be transferred outside of the country where you reside or are located, including to countries that may not or do not provide the same level of protection for your Personal Data. We are committed to protecting the privacy and confidentiality of Personal Data when it is transferred.
No information from children under 13
Alto strongly believes in protecting the privacy of children. Any use or access by anyone under the age of 13 is prohibited. Inline with this belief, we do not knowingly collect or maintain Personal Data on our Site, products or services from persons under 13 years of age, and no part of our Site is directed to persons under 13 years of age. If you are under 13years of age, then please do not use or access this Site at any time or in any manner. We will take appropriate steps to delete any Personal Data of persons less than 13 years of age that has been collected on our Site, products or services without verified parental consent upon learning of the existence of such Personal Data.