Privacy policy

IndemniFLY Pty Ltd (ABN 60 652 206 301) (“IndemniFLY” or “we” or “our”) is committed to maintaining the privacy and security of personal information. 
This Privacy Policy explains how we collect, store and use personal information in connection with our services, our website, platform and associated software, products and programs (together, the “Website”).

If you have any questions or if you wish to receive further details, please contact us using the method set out below. 
This Privacy Policy has been developed in accordance with the General Data Protection Regulations (GDPR), the UK General Data Protection Regulation (UK GDPR), the Data Protection Act (UK), the Australian Privacy Act (including the Australian Privacy Principles), the New Zealand Privacy Act and applicable US data protection laws (including the Children's Online Privacy Protection Act (COPPA), the California Consumer Privacy Act (CCPA) and the United States Family Educational Rights and Privacy Act (FERPA) (collectively, “Data Protection Laws”).

How we collect personal information
We may collect personal information in a number of ways, including:
• When creating an account to access our Website.
• When accessing our Website or services.
• During conversations and/or correspondence with the IndemniFLY team (for example, customer service enquiries).
• To enable us to provide users with access to the Website and our services.
• To verify log-in information or to provide support services in connection with the use of the Website.
• From the Website, to follow a user’s usage, interaction and progress on the Website.

The types of personal information we collect
The types of personal information we collect may include: 
• Basic user information including your name, email address, phone number. 
• If you apply for employment with us, information needed to consider your application.
• Details of other interactions that you have with us, together with any other information that you choose to provide us, for example, through your interactions with our Website and our customer and technical support teams.

What we do with personal information
The personal information you provide to us, or collected about you, is collected for the purpose of enabling us to provide and enhance our services and to provide access to and enhance usage of the Website. This may include:
• To manage and administer our agreement with you, including relationship management, invoicing, training, implementation, performance of our agreement and the provision of support services;
• To manage enquiries, free trials and prospective purchases;
• To provide the content, functions and services offered on the Website;
• To limit access to the Website to legitimate permitted users;
• To keep you informed of our products and services that might be relevant to you;
• To send newsletters or emails about our services, including information about current events, changes, improvements, upgrades, new product development and rules;
• To gain user insights and analysis to observe your learning and behaviour and to improve the services.
• To administer and manage accounts, including password resetting, responding to questions and to monitor usage and conduct on the Website;
• To inform you about tools, features and content available on the services, and to make recommendations about content, in order to customise and enhance usage of the services;
• To let you know about developments and updates to the Website and services;
• To provide results data;
• To conduct user surveys and research and measure user satisfaction; 
• To fix bugs and problems;
• To manage, train and develop our employees and representatives; 
• If you apply for employment with us, to consider your application; 
• To amend records to remove personal information; and 
• For other everyday business purposes that involves the use of personal information.
If we have obtained your personal information through your use of the Website (for example, when you log-on to use the Website), your personal information will be securely stored by us and not used for any purpose other than for the purposes specified in this Privacy Policy and to enable continued use and enhancement of the services. 
What we will not do with personal information
We will keep your personal information confidential and not disclose or sell your personal information to any third parties, unless:
• we believe, in good faith, that we are required to share your information with a third party such as a regulator or court in order to comply with a law, regulation, legal process or court order;
• it is reasonably necessary to enforce our legal rights in relation to your access and use of our Website;
• the disclosure is to a third-party service provider that provides services for us, for example to assist us with web hosting, Website performance or customer relationship management (provided that all such disclosures are subject to the terms of this Privacy Policy); and 
• to protect the safety and security of our users and our Website.
Third party service providers which process personal information on our behalf (who may be classified as sub-processors under Data Protection Laws) are only engaged to assist us with providing and enhancing our Website and our services. These providers are only granted access to personal information to the extent required to provide their services for us, strictly in accordance with our instructions, this Privacy Policy, applicable privacy laws, our contractual obligations to customers and not for any commercial purpose. 
We will comply with our obligations under applicable Data Protection Laws when engaging sub-processors and we will ensure that all sub-processors comply with their obligations under applicable Data Protection Laws. Without limitation, we take reasonable steps to ensure that these organisations comply with technical and organisational security measures required to protect personal information. 
Direct marketing
If we have obtained your personal information through your use of the Website (for example, when you log-on to use the Website), we will not use your personal information for marketing purposes. 
If we have obtained your personal information by other ways permitted in this Privacy Policy, including if you have enquired about the services, we may use your personal information to send you information about new developments, products, services and special offers. 
You can, at any time, opt out of receiving marketing material from us by contacting us using the method set out below or, where we have sent you electronic marketing materials, by using the unsubscribe link within the communication. You agree and acknowledge that even if you opt out of receiving marketing material, we will still send you essential information that we are required to send you relating to the services we provide. 
How long we hold personal information
We retain the personal information that we collect for as long as it is needed to provide access to our Website and to provide our services. We will not knowingly retain personal information when we cease providing services to you. We will delete personal information when lawfully requested or directed to do so.
We may however retain and use personal information as necessary to comply with our legal and regulatory obligations, to resolve disputes and to enforce our agreements, and we may retain and use anonymous and aggregated information for performance reporting, analytic purposes and for product and service improvement.
You can request that personal information is deleted by contacting us in the manner specified below.
Our use of cookies and similar technologies
We may use cookies, web beacons, pixels, log files and other technologies to collect information about visitors and visits to our Website. This may include:
• An IP address to monitor traffic and volume on the Website;
• A cookie to help us store session information when users are logged into the Website and to facilitate seamless access between our different services;
• A session ID to track usage statistics on the Website; or
• Information regarding participation habits, experiences and interaction with our Website.
We may use this information to measure the effectiveness of content and how visitors use the Website, so that we can enhance and improve our services. 
If you choose to do so, you may configure your computer so that it disables “cookies” or does not accept them, however, this may impact the functionality of the Website. 

By signing up to our Website, you consent to the collection of the personal information for the purposes specified in this Privacy Policy. 
Storage and security
We will take all reasonable steps to keep personal information in a secure environment in accordance with the requirements of applicable Data Protection Laws. We have implemented technical, administrative and physical security measures that are designed to protect personal information from unauthorised access, disclosure, use and modification. If you reasonably believe that there has been unauthorised use or disclosure of personal information, please contact us using the method set out below.
Changes to our Privacy Policy
We may vary the terms of this Privacy Policy from time to time, in which case we will update the link to the Privacy Policy on our Website. You should check this Privacy Policy regularly so that you are aware of any variations made to this Privacy Policy. If we make material variations to our Privacy Policy, we’ll provide you with notice as appropriate under the circumstances. You will be deemed to have consented to such variations by your continued use of the Platform following such changes being made.
Access to information we hold about you
We will take reasonable steps to ensure that all personal information we hold is accurate, up-to-date and relevant. A person may request access to, review of, corrections of, or erasure of personal information held by us, or complain or object to the use of personal information by us. You can contact us using the methods set out below. We will respond to your request as quickly as possible and in accordance with applicable Data Protection Laws.
How to contact us
All requests to access, update and delete personal information as well as questions and concerns about your personal information and this Privacy Policy should be directed to the following contact: 
Specific information for residents of the European Union and the UK
We are committed to compliance with our obligations under the applicable Data Protection Laws in the EU and the UK. 
Data Controller
In most cases LearnWorlds will be a data processor for the purposes of applicable Data Protection Laws and IndemniFLY will be the data controller. 
Basis for processing
Depending on the context and the purpose of our processing activities we generally process personal information on the basis of consent, or the legitimate interests pursued by IndemniFLY and LearnWorlds in delivering learning resources. Our legitimate interests are further detailed in the section entitled “What we do with personal information” above. 
Transfer of personal information
Personal information we collect may be transferred and stored on servers located in Australia, the United States, or other countries in which the privacy or data protection laws differ from those of the European Union and the UK. We ensure that suitable safeguards exist in relation to transfers of personal information to recipients outside of the EU and the UK, including through the use of the Standard Contract Clauses approved by the European Commission and further recognised by the UK Government for data transfers from the UK under the UK GDPR.
Contact us
If you have questions about the use of personal information in relation to the GDPR or the UK GDPR, you can contact us using the method set out above in this Privacy Policy.
Specific information for residents in the United States
IndemniFLY only uses personal information for educational training purposes as a “service provider”, as instructed by you and in accordance with the terms of our agreement with you. 
No sale of personal information
IndemniFLY does not sell the personal information to third parties and ensures that its service providers do not sell that personal information to third parties.
No collection of personal information of children without consent
We do not knowingly permit children under the age of 13 to create an account or provide us with personal information without us first obtaining verifiable consent. 
We will not require you to provide us with more information than is reasonably necessary to use our Platform. 
If you believe we have collected information from a child under the age of 13 without obtaining consent, please contact us using the method set out above in this Privacy Policy.
Right to know, access and delete personal information
California residents have certain rights to request access to or deletion of their personal information in accordance with the CCPA. You can do this by contacting us using the method set out above in this Privacy Policy. We may require you to take certain steps to verify your identity. 
California residents also have the right to opt out of the sale of their personal information. IndemniFLY does not provide this option as we do not sell your personal information. 
Contact us
You may contact us using the method set out above in this Privacy Policy.
You will not be discriminated against for exercising your rights under the CCPA or other applicable Data Protection Laws.
Created with