1. Introduction
This Policy outlines how we deal with Personal Information, which is information about an individual whose identity is apparent, or can reasonably be ascertained, from that information.
Rodomontrade Pty Ltd (ACN 130 330 611) (we, us or our) has adopted this Privacy Policy, in accordance with the Australian Privacy Principles in the Privacy Act 1988 (Cth) (APPs).
We collect Personal Information in conjunction with our services on www.wurdle.com
(Wurdle) an online tool that we provide to users for language study and vocabulary memorisation (Services).
2. How we collect Personal Information
We collect Personal Information in four main ways:
(a) actively collecting specific information relevant to providing the Services (Active Collection);
(b) collection via automated electronic means in accordance with standard business practice on the Internet (Automated Collection);
(c) passive collection, which is when you use our Services to process information (Passive Collection); and
(d) collecting Personal Information about you from third parties (Third Party Collection).
We engage in Active Collection when an individual or organisation:
(a) (Registrations) registers or subscribes for a service, list, account, membership, connection or other process whereby that individual enters his or her details to apply for, receive or access something, including a transaction; or
(b) (Contact) contacts us via any medium, including telephone, fax or email.
We engage in Passive Collection whenever users of the Services include any
personal information in any content they create or store through or on our
Services, We may also passively receive information when users have location
services switched on in relation to the Service.
We and some of the third party services providers we use (such as Google Analytics) engage in Automated Collection as follows:
(a) (Logs) when you visit our website or use the Services, our server and analytics service may log details about your visit such as your IP address, the time and duration of visit, the link from which you visited, information about your browser and operating system, and information about how you have used the Services, including what information you enter; and
(b) (Cookies) we will place cookies on your device when you visit our website.
We engage in Third Party Collection when:
(a) (Client documents and databases) clients provide us with access to their documents or databases containing Personal Information;
(b) (Social network login) you opt to login or create a profile or account using a social network such as Facebook; and
(c) (Invitations) users, including individuals or organisations subscribed to the Services, supply the name and email address of individuals in order to invite them to use the Service.
3. The kinds of Personal Information that we collect and hold
Through the processes above, we collect the following categories of Personal Information about individuals:
(a) (Content) whatever Personal Information is included in content you enter using our Services;
(b) (Identity Information) name, username, date of birth;
(c) (Contact Information) email address, social media profiles, telephone & fax number, third-party usernames, residential, business and postal addresses;
(d) (Behaviour Information) habits, movements, trends, decisions, webpage views, online activity;
(e) (Internet Data) Internet Protocol or "IP" address, referring web site addresses, browser type, operating system, domain name, access times and other data typically collected by analytics services like Google Analytics; and
(f) (Log Information) information about your usage of the Services.
The APPs categorize certain types of Personal Information as “sensitive information” (Sensitive Information).
We collect information about the languages you know and your level of proficiency, which may reveal your racial or ethnic origin.
By providing details about your language knowledge and proficiency, you consent to
our management of that information, and information that may reasonably derived
from it, in accordance with this privacy policy.
4. How we hold Personal Information
We hold and store Personal Information using:
(a) (Storage Services) third party data storage services, which are businesses that professionally manage information technology infrastructure;
(b) (Software Services) third party application providers, where we use an application for the purposes of our business and store data in association with that application on infrastructure
provided by those third party application providers;
(c) (Business Devices) devices operated by employees of our business; and
(d) (Paper Files) printed paper and third party archival storage services.
We may combine or link Personal Information about you that we collect on one
occasion with Personal Information about you that we collect on other occasions.
5. How we secure Personal Information
We will take reasonable precautions to protect Personal Information from unauthorised access. This includes appropriately securing our physical facilities and electronic networks.
We secure Personal Information that we collect with credentials, passwords, session expiry, firewalls, SSL network encryption for some transmissions, and through taking steps to ensure that third party providers holding data are reputable and have reasonable security measures in place. For more information on security, please contact us using the contact details below.
By using any part of the Services, individuals acknowledge that the security of electronic communications cannot be guaranteed. Individuals provide information, including Personal Information, to us via the Services at their own risk.
6. The purposes of collection, holding and use
We collect, hold and use Personal Information for the purpose of providing the Services, improving them and developing additional functionalities for our users.
For Passively Collected Personal Information, the collection, holding and use of information happens simply by virtue of users using the Services. The purpose of the Services is to allow users to enter, manage and learn vocabulary, and some of the data you enter in connection with vocabulary learning may include Personal Information.
For Actively Collected and Automatically Collected Personal Information, our handling of Personal Information includes holding and using the Personal Information so that we can:
(a) (Functionality) provide functionality such as secure access within the Services;
(b) (Communicate) communicate with individuals for the purpose of providing the Services, including notifications, support; communications about our Services; marketing and promotions; and competitions, surveys and questionnaires;
(c) (Transact) transact with individuals for the purpose of providing the Services; and
(d) (Business Development and UX) assess the progress and success of our Services, develop business opportunities, and enhance user experience of our Services.
We tend not to use information collected via automated means in order to identify specific individuals. Rather, it is generally used for data analysis. For example, we may use cookies and log information to ascertain the number of unique visitors to our website, whether or not those visitors are repeat visitors, and the source of the visits.
We may use information about your language proficiency to analyse the usage and effectiveness of the Services.
7. How and when we share or disclose Personal Information
The Services allow individuals and organisations teaching foreign languages to subscribe as instructors and monitor the progress of students using the Services. Such individuals and organisations, along with any other user to whom they have granted permission, will be able to access and view information about students’ usage and progress, as well as the students’ names and email addresses.
The Services also have an invitation function. Users enter a name and email address to invite a person to use the Services. If that address matches an existing account, the name of that invited user is displayed to the person who made the invitation to confirm they have invited the right person. If the invitor is part of an organisation, then other members of that organisation who have access to the organisation account may also see the name and email addresses of invitees.
When we use the services of companies that we work with to provide our Services, this may involve providing some degree of access to Personal Information. Such third party services may include web hosting, software as a service, IT support, data analytics and online payment. We will only share Personal Information with these third parties to the extent reasonably necessary to perform their functions.
By using any part of the Services, individuals acknowledge that we are not responsible for the privacy or security practices of any third party (including third parties that we are permitted to disclose or transfer Personal Information to in accordance with this Privacy Policy or any applicable laws). The collection and use of Personal Information by such third parties may be subject to separate privacy and security policies. For more information on the third party service providers we use, and their privacy policies, please contact us using the details listed below.
For information on disclosures to overseas recipients, see below.
8. Contacting us to access, change or delete Personal Information
Users may edit content and profile and account details within the Services.
However, you can also contact us using the details below to arrange access or correction to and, where appropriate, deletion of your personal information.
Position Title: Director
Email: [email protected]
Postal Address:
PO Box 1002,
Surry Hills,
NSW 2010
We may charge a reasonable fee for such access or correction.
We reserve the right to refuse access or correction where there are reasonable grounds for doing so, for example if providing access would be unlawful or would compromise the privacy of another person.
9. Complaints process
(a) If you have a complaint relating to an alleged breach of the APPs, you should contact us using the details listed in the previous section of this Privacy Policy.
(b) When you notify us of a complaint about our handling of your Personal Information, we will deal with the complaint by responding to it in writing within a reasonable period (usually 10 business days from the day we receive your email).
(c) We will endeavour to work with you to resolve the complaint entirely within 30 days, although that period may be longer if it is reasonable to take longer given the nature of your complaint.
(d) If you are unsatisfied with our response, you may make refer the complaint to the Office of the Australian Information Commissioner (http://www.oaic.gov.au/).
10. Disclosure of Personal Information to overseas recipients
(a) Our use of third party service providers may result in the processing of your Personal Information overseas. You may not have the same rights in relation to the handling of your Personal Information by overseas recipients as you would under Australian privacy law.
(b) By providing us with Personal Information, you consent to the transfer of your Personal Information to recipients outside Australia.
(c) If you consent to such transfer, we will not be accountable for overseas recipients’ handling of your Personal Information. In any event, we take reasonable steps to ensure that the Personal Information that has been transferred will not be held, used or disclosed by the recipient of the information inconsistently with the APPs.
11. Amendment
We may amend the Privacy Policy at our sole discretion. If you continue to use the Services after receiving notice from us of such an amendment to the Privacy Policy, you agree to be bound by the Privacy Policy as amended.