Privacy Policy
Reading Kilometres Pty Ltd ACN 669 883 676 (we/our/us) provides a reading literacy application and website known as Reading Kilometres (Platform) located at
<www.readingkms.com> (Site).
We consider your privacy to be important and we take our responsibility to protect it seriously. We understand that you are concerned about your privacy, along with the confidentiality and security of any personal information provided to us.
This Privacy Policy describes how we collect, use, process, and disclose (Process) your data (which includes any information you provide that may be able to identify you personally) in conjunction with your access to and use of all of the services, websites and platforms that we offer (referred to collectively as our Services).
Your rights regarding the data that we Process are set out in this Policy. We process your data in accordance with the Australian Privacy Act 1988 (Cth). If you are accessing our Site, our Platform or receiving Services from a location outside of Australia or the EU, your personal information will be processed in Australia and in accordance with this Policy, unless we are required to comply with privacy laws specific to your jurisdiction.
If for any reason you need to contact us in relation to your data, our contact details are:
Attention: Privacy Officer, Reading Kilometres
If you are based in the European Union, or your data is otherwise protected by European Union General Data Protection Regulation (GDPR), you may contact us directly using the above contact information, or alternatively may contact our EU Representative:
Name: Mr. R. Venner
Email: EU_privacy@readingkms.com
We collect data in the following circumstances:
Where you have requested access to the Platform or that we provide you with our Services, we need to Process your data to:
enter into our agreement with you;
deliver to you our Services;
create an account on the Platform.
We may also Process your data (even where it is not related to us entering into an agreement or contract with you) where we consider:
you will not be detrimentally impacted;
you would reasonably expect us to engage in such Processing; and
it is necessary to fulfil our legitimate interests.
This may include, for example, processing your data to improve our Services, or to enable our third-party service providers (including Google) to provide us with services.
There are certain situations in which we may be required to Process your data to comply with a law or Court order.
In certain circumstances we may request that you specifically consent to our Processing of your data. Where we do so, we will provide an explanation of the nature of the Processing to which you are consenting. If we have requested your consent, you can withdraw your consent at any time by contacting us using the contact information set out in section 0.
We collect data in a variety of ways from those interacting with us, including:
through our Site;
through our Platform and account creation process;
from other interactions with us, whether by telephone, email, ordinary mail or any other electronic or online means;
through any other business activities or events; and/or
where you otherwise voluntarily provide us with your data (for example, where you respond to a survey or feedback request).
We collect the following data from our users in the account creation process:
Personal information such as full name, email address and date of birth;
account details including your username, school / family / primary account name, and password;
opinions and feedback provided relating to our Services and how users use our Services;
activity data including information about reading habits;
data logs, which may include information such as your internet protocol address, browser type, browser version, clickstream data, referring URLs, the pages of our Site or parts of our Platform that you visit, the time spent on any pages of our Site or parts in our Platform and other log related information relating to your use of our Services; and
all other information that you provide to us voluntarily and directly, including in any enquiry made to us.
Account payment information including credit card details are collected directly and stored by our third-party payment processing provider. These details are not collected and stored by us.
Whenever you visit our Site or enter our Platform, our servers automatically record information for statistical purposes about your usage, such as:
the type of browser and device used;
the referring URL;
the IP address;
the number and type of pages viewed;
the date and time of visits; and
the exit URL.
If at the time of visiting our Site or the Platform you were logged in to your account, this information is linked to your data for quality assurance and customer service.
We may utilise "cookies" through our Site which enable us to monitor traffic patterns and to serve you more efficiently if you revisit our Site. A cookie does not identify you personally, but it does identify your computer. You can set your browser to disable cookies or to notify you when you receive a cookie and provide you with an opportunity to either accept or reject it in each instance. If you disable cookies, you may not be able to access certain areas or features on our Site.
Web beacons (also known as clear gifs, pixel tags or web bugs) are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of web users or to access cookies.
Unlike cookies which are stored on the user’s computer hard drive, web beacons are embedded invisibly on web pages (or in e-mail). Web beacons may be used to deliver or communicate with cookies, to count users who have visited certain pages and to understand usage patterns.
Like many sites, we use web beacons to collect information which is done in accordance with this Policy.
Due to the audience of our Services being families and schools, we will collect and use basic information as identified in clause 5.1 belonging to children under 18. If a parent or guardian becomes aware that his or her child has provided us with data without their knowledge, that parent or guardian may contact us to have this data removed.
Generally, we only use data for providing, evaluating, improving, personalising and developing our Services. More specifically we use data to:
enable you to interact with and use our Site and Platform;
perform internal research and statistical analysis;
promote and market our Services and Platform;
improve our Services, the Platform or the Site;
deal with your enquiries; and
prosecute and defend any allegations of wrongdoing or unlawfulness.
Typically, we will only Process data for the reasons set out in clause 6.1 . However, in some circumstances, we may use data for reasons other than those specifically identified above. We will only do so where:
you would reasonably expect us to use or disclose the data;
you have consented to our Processing of your data for some other purpose; or
the use or disclosure of the data is required or authorised by law, the order of a regulatory authority, or a court or tribunal.
Where data is being used for direct promotional or marketing purposes, whether provided by us or an associated entity or a third party, we will obtain your consent. You may at any time decline to receive further offers by opting out.
We may disclose your personal information to our related bodies corporate and third parties for the purposes set out above at clause 3. The third parties to whom we may disclose your personal information include:
professional advisors and consultants (such as lawyers, accountants, and auditors);
website hosts;
third-party payment processing platforms such as Stripe;
third-party software platforms integrated to the Platform; and
our mailing and communication service providers, in relation to your name and contact details.
We use our best endeavours to ensure that we only disclose personal information to third-party service providers that have implemented appropriate systems and processes to protect your personal information.
In addition to personal information, you consent to disclosing credit and payment information to our third-party payment processing platforms. You acknowledge and agree that each third- party platform will use and disclose your personal information or credit and payment information in accordance with their individual privacy policies.
We will only disclose personal information, other than as mentioned above, where we are legally required or compelled by a law enforcement or government agency to do so.
Certain services we provide are open to other account holders to view. Any information you create or post in these locations will not be private. We urge you to exercise caution when deciding to disclose your personal information in a public space. You agree to assume all responsibility for all personal information that you have made public on our Site or Platform.
Where you your account is a user account of a primary account holder (for example a school or family member), any information you share in the formation of your account will be shared with your primary account holder.
We may disclose personal information to outsourced information technology service providers, including cloud computing providers and data storage providers, based overseas.
We will take reasonable steps to ensure such overseas recipients do not breach the APP or are subject to laws or a scheme substantially similar to the APP.
We may use Google Analytics to track usage of our Site. Google Analytics is a web analysis service provided by Google. Google utilises the data collected to track and examine the use of the Site, to prepare reports on the Site’s activities and share them with other Google services.
Google may use the data collected to contextualise and personalise the ads of its own advertising network. Personal data collected by Google includes cookie and usage data, which is processed in the USA. You can find Google's privacy policy here: http://www.google.com.au/policies/privacy/.
Other than as stated above we will only disclose your personal information to an overseas recipient if:
you consent to the transfer; or
the disclosure of the information is required or authorised by or under an Australian law, other applicable law or a court/tribunal order.
Where you are based in the European Union or your data is otherwise collected in accordance with the GDPR, you acknowledge that there may be instances where your data is transferred outside of the European Union and to countries which have not been the subject of an “adequacy decision” pursuant to the GDPR. Such transfers are necessary for our legitimate business purposes and in order for us to perform our Services.
We use industry best practices to protect data that we deal with from:
misuse, interference and loss; and
unauthorised access, modification or disclosure.
All staff and third-party providers with access to data, including third-party data storage providers, are required to comply with appropriate information security industry standards.
Although we provide security measures, there is always risk associated with the transmission of information via the internet.
You acknowledge that we cannot guarantee the security of any data transmission, and as such all data transmissions are entirely at your risk. Once we have received your data, we will take reasonable steps to use procedures and security features to try to prevent unauthorised access, modification or disclosure.
Our Site, promotional material and Platform may contain links to other sites that are not operated by us. If you click on a third party link, you will be directed to that third party's site. We strongly advise you to review the privacy policy of every site you visit.
We have no control over, and assume no responsibility for, the content, privacy policies, or practices of any third party sites, products or services whatsoever, including those of our clients.
We enter into legal contracts with each of our clients which contractually require them to adhere to applicable privacy laws and self-regulatory advertising codes. Ultimately, the collection, processing, use and disclosure of your information by our clients is managed by our client’s under their own privacy policies.
We encourage you to read the terms and policies of all third-party sites, apps or services that you visit or interact with.
We will provide you with access to your personal information held by us unless:
giving access would be unlawful; or
denying access is required under the Privacy Act or any other applicable law.
If you would like access to your personal information aside from your account information, you must contact us in writing making such a request. Following receipt of your request, we will contact you and either provide you with the information you have sought, or an explanation detailing why we will not provide you with the information.
We endeavour to keep all personal information we hold accurate, up to date and complete. If at any time you wish to correct any of your personal information and you have an account you may do so freely at any time via your account profile following your log on.
If you wish to amend personal information that we hold that is not editable under your account, please contact us to request amendment. If we elect not to correct your information, we will notify you, within a reasonable time, detailing the reason for our refusal, the mechanisms available for you to complain about our refusal and such other matters required by the Privacy Act.
If you wish to have your personal information deleted, please let us know and we will take all reasonable steps to delete it, unless we need to keep it for legal reasons.
If you are located outside Australia and choose to provide your personal information to us, your personal information will be processed in Australia and in accordance with this Policy.
We strive to ensure our compliance with this Policy and to regularly review our practices against it.
If at any time you have a complaint against us regarding our Policy, including a breach of the Privacy Act, we invite you to make a complaint by contacting us directly. All complaints made will be dealt with in confidence.
If you are based in the European Union and have a complaint regarding your data, you may also contact our European Representative using the contact information contained in clause 2.2 of this Privacy Policy.
Within 30 days of receipt of your complaint we endeavour to notify you in writing as to what action we propose to take in relation to your complaint and will provide you with details of what further action you can take if you are not satisfied with our response.
You may also make a complaint to the Office of the Australian Information Commissioner (OAIC) about the handling of your personal information. Information on making a privacy complaint can be found on their website at http://www.oaic.gov.au/privacy/making-a-privacy-complaint .
We reserve the right to vary this Privacy Policy from time to time to ensure that we remain up to date with market expectations, the law and technological advances. Any variations to this Privacy Policy will be published on our Site.
It is your responsibility to check our Privacy Policy periodically to ensure you are aware of any changes made to it.