1.        Introduction.

We are committed to protecting the privacy of end users and in particular, your employees. This Privacy Policy describes how we collect, store, use and distribute information through our Service and related support services (together, the “Service”).  Unless otherwise specified, for the purposes of this Privacy Policy, “you” and “your” refers only to the Licensee. Authorized User refers to your employees, members or any other authorized and approved user of our Service, including agents and contractors.

Certain defined terms and conditions have been further defined in the Contexture EULA and Terms of Service Agreements, which are incorporated herein by reference.  For use in this Privacy Policy:

a)         You: You are the Licensee.

b)         Authorized User: These are the approved and authorized users who access our Service through your online access through internet service providers and other communications and devices.  Our Service may authorize your employees, officers, affiliates, members and agents or contractors to use our Service collaboratively and accordingly we (subject to agreement with you and them) register and communicate with them.

c)         Contexture Marketing Purposes: Information is said to be used or collected for marketing purposes where it enables us to provide recommendations to you where we believe Contexture Products or Services will be of interest to you.

d)         Operational Purposes: Information is said to be collected for Operational Purposes where it allows us to:

i.    Make the Products you have requested from us available to you.

ii.   Bill you, deliver Product to you and get in contact with you when reasonably required.

iii.  Enforce our Agreement.

iv.  Respond to enquiries and requests.

v.   Supporting our efforts to monitor the performance of and constantly enhance our Service and deliver new Products and Features to you.

e)         Partners: Are providers of Products or Services which we believe will be of interest to our customers.

f)          Partner Marketing Purposes: From time to time in conjunction with Partners, we may send promotional announcements and/or serve web-based advertisements on their behalf, as permitted by law. Information used or collected for Partner Marketing Purposes where it enables us to provide recommendations to you relating to Partner Products or Contexture Services.

g)         Operational Service Providers: Means Contexture Affiliates, Third Party companies, agents or contractors that are engaged by us directly or indirectly to assist us in providing the Service to you. For example, Family Zone Services Providers assist us in delivering marketing and communications, providing infrastructure and IT Family Zone Services, delivered Products, processing payments, provide Customer Support, collecting debts, analyse and enhance data and so on. For the purpose of this Privacy Policy, Service Providers includes our Cyber Experts.

2.        Consent.

a)         Your Consent.  By using the Contexture Service, you consent to the collection and use of Personally Identifiable Information of your Authorized Users as described in this Privacy Policy. Except as set our herein, the Personally Identifiable Information of your Authorized Users will not be used for any other purpose without your consent.  We do not collect Personal Identifiable Information for the purpose of sale of such information in any way.  You may withdraw your consent to our processing of the Personally Identifiable Information of your Authorized Users at any time; however, we will not be able to provide you or your Authorized Users with some aspects or all of our Services.

b)         End User Consent.  Our Service provides you with the ability to access, monitor, use, or disclose data associated with your End Users. With respect to End Users that are not managed by accounts other than yours (for example staff or school managed students) you undertake to obtain and maintain all required consents from End Users to allow: (i) access, monitoring, use and disclosure of this data and for us to provide the Family Zone Services and this data.

3.        The Information We Collect and Why.

a)         Your information when we register you.  When you sign up with us we will ask for personal information to enable us to establish an account. This will include name, email address, and company name and when you subscribe to our Service we will collect additional information including but not limited to - address, payment method (such as a credit card), username and security information such as a password, PIN and secret question/answer.

As described in our Terms of Service Agreement we may also capture information about your organization including industry/membership/association details and director’s details.

b)         End-User accounts and Device registration information.  When you register Authorized Users we will ask for personal information to enable us to establish their authorized user account. This will include name and security information such as a password and password reset information. We may also capture user identifiers to assist you and us integrate our Service with your enterprise systems.

As you or your Authorized Users connect to the Service (e.g. access points, gateways, network appliances) an authentication process will be triggered. Device and/or authorization tokens/certificates or a sign-in will allow our Service to identify the Authorized User – which is fundamental for the operation of our Service.

We require this information for Operational Purposes and Contexture Marketing purposes. It enables us to identify you, your Authorized Users and their devices and for us to support you. Without this information our Service cannot be provided.

c)         Contexture Service related information.  Our Contexture Service enables you and your Authorized Users to access and control the Content and analysis of the results provided by our Service. We necessarily need to monitor and track usage and related device information. This includes, but is not limited to:

  1. Use of the Service including search terms, categories and terms relating to the Content and related information such as device, protocol, time & date.
  2. Geo-location information derived from IP addresses or other technology.

iii.        Use of calling and messaging features of devices including support service details and related information such as user account, Licensee account, time & date.

  1. Data, text, graphics, video, messages or other materials which has been transmitted, distributed, displayed, or shared using our Contexture Service.
  2. Other End User actions or patterns of actions e.g. violation of our Contexture Service EULA and Terms of Services Agreements.
  3. Diagnostic information such as crash reports and system logs which may capture device details such as browser version, user account information, and any related identifying information associated with Service events.
  4. d) Your Access to Licensee Account Data. Please note you will be able to view Licensee Account Data associated with your Authorized Users upon request.

e)         Use of our websites, Contexture Service and customer support.  In using our websites and Contexture Service we will track information on your Authorized Users use of our Contexture Service. For the purpose of providing you with a quality service, we maintain an activity log for you and your Authorized Users use of our Contexture Service. Information collected includes:

  1. Use of our websites and customer portal.
  2. Use of the Service including updates, Content and Documentation.

iii.        Logging the operational activity of the Service such as the running of updates, connection of users etc.

  1. Subscriptions, purchasing, invoice and payment history.
  2. Orders of Services including corporate address and contact information.
  3. Correspondence with us.

f)          Feedback, suggestions, survey responses and forums.  While using our Contexture Service, you and Authorized Users will have opportunities to provide comments or other information in online feedback, survey requests and other forums of customer engagement.  This information is by its nature public and unsecured.  Further terms such as copyright relating to any information you post or otherwise provide to us are described in our Terms of Service Agreement.

g)         Information collected from Third parties.  For Operational Purposes we may collect information about you from Third Parties including from – i) our service providers, Affiliates, contractors and Partners, and ii) searches of publicly available information including online information and social networks.

h)         Sensitive Information.  Certain legal jurisdictions define Sensitive Information and prescribe rules around its capture, storage and use. For the purpose of this Privacy Policy we define Sensitive Information to mean information or an opinion about an individual’s:

  1. Racial or ethnic origin.
  2. Political opinions.

iii.        Membership of a political association.

  1. Religious beliefs or affiliations.
  2. Philosophical beliefs.
  3. Membership of a professional or trade association.

vii.       Membership of a trade union.

viii.      Sexual preferences or practices.

  1. Criminal record.

Unless permitted within your jurisdiction and either necessary for the provision of our Contexture Service or permitted by you we will not record or use Sensitive Information.

4.        USE OF AND SHARING PERSONALLY IDENTIFIABLE INFORMATION (“PII”).

  1. a) Operational Purposes. We will share your and your Authorized User PII among any of our related companies, Affiliates and organizations and to any Service Provider for Operational Purposes.
  2. b) Third-Party Marketing Purposes. We will not sell your or your Authorized User’s personal information to Third Parties. We may however (subject to your opting out) direct partner organizations to you for the purpose of offering you what we reasonably consider to be complimentary Products or Contexture Services. We will endeavor to work with reputable partners; however, you acknowledge that we do not control their privacy policies or practices.
  3. c) Marketing to Parents. We will not directly market to Authorized Users associated with your Licensee Account without permission from you, them or another valid source.
  4. d) Exceptions. We reserve the right to disclose PII if we reasonably believe that access, use, preservation or disclosure of such information is reasonably necessary to (a) satisfy any applicable law, regulation, legal process, or governmental request, (b) enforce applicable Terms of Service or our EULA Agreements, including investigation of potential violations or breaches, (c) detect, prevent, or otherwise address illegal or suspected illegal activities, security or technical issues, or (d) protect against harm to the rights, property or safety of us, our users or the public as required or permitted by law. Further, in connection with any restructuring, merger or sale, or other transferring of assets we reserve the right to transfer all customer and End-User & Device information, including PII, to the receiving party.  We will do so provided that the receiving party agrees to respect your personal information in a manner that is consistent with our Privacy Policy until such time as they properly change these terms or obtain your approval to change them.

5.        THIRD PARTY SERVICES.

Our Contexture Service may be provided through platforms, and contain content and links to sites operated by Third Parties whose policies regarding the handling of information may differ from ours.  While we endeavour to associate with reputable companies, we cannot be responsible for the information handling practices of these other websites and platforms. These websites and platforms have separate and independent privacy statements, notices and terms, which we recommend you read carefully.

In using the Service and related Content and Documentation, you may encounter Third Party applications (e.g. cookies, widgets and utilities). These technologies may import, capture or monitor data related to your account and activity and otherwise gather data from you. These applications are provided solely as a convenience to you. We are not responsible for them and your use or acceptance of them is at your own risk.

While using the Service and related Content and Documentation, you or your Authorized Users will access websites and applications owned or operated by Third Parties. We are not responsible for their privacy policies and practices.

6.        FACILITIES AND DATA TRANSFER.

The Internet is a global environment and our Family Zone Services are deployed globally.

We undertake that our facilities and processes to store and process Customer Data will adhere to reasonable security standards.

We endeavour to store and process Customer Data in the county within which you are located (Locally), from time to time however this will not always be possible.

By using our Family Zone Services, you acknowledge and agree to the transfer of your information outside your country of residence to any country (including the United States) where we have facilities or engage third parties (including but not limited to payment processors, cloud service or other IT providers and other companies that provide Family Zone Services to us). You acknowledge that the countries to which we may transfer information may not have as comprehensive a level of data protection as in your country.

7.        COMMUNICATING WITH YOU.

By using any of our Contexture Service, including our website and user interfaces, or providing information to us through any means, you agree that we can communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Service and related Support services.

8.        SECURITY PROCEDURES.

a)         Our Security Procedures.   We take information security seriously and use reasonable administrative, technical, physical and managerial measures to protect your personal information from unauthorized access. For example:

  1. We utilize Secure Sockets Layering to encrypt communication between us.
  2. We do not store your payment information, instead we use a Third Party payment provider to store your payment data encrypted through PCI-DSS.

iii.       We require you to provide a unique username and set a password and other security measures from time to time such as PINs and secret questions/answers.

  1. We hold passwords encrypted and cannot re-issue these (instead you must enter a new password).

b)         Your Security Procedures.   We urge you to be diligent in securing your computing networks, devices, usernames and passwords.  Should other parties obtain access to these or guess them (because they are too simple) then you may be compromised.

For convenience we make certain technologies available to you to make it easier to log in to your account or be authenticated to access the network or internet.  For example, cookies, remember-me and single-sign-on type technologies. If you use these then we urge you to implement device PINs and to log off your device when you’re not using it.

If you intend to sell or return a device that you have used with us, you should log-out and clear the cache, all browsing info and cookies before doing so.

You are responsible for maintaining the confidentiality of your account access information and for restricting access to your computer or device through which you access your Contexture account.   For further information on Responsibility for Use of the Service, please refer to the EULA.

9.        DATA BREACHES.

We are committed to transparency with respect to serious data breaches. We undertake to comply with the United States Federal and State data security and breach notification requirements from legislation and regulations in these jurisdictions, as they may be changed, updated and amended, and in particular, the Gramm-Leach-Bliley Privacy Act of 1999 (also known as Financial Services Modernization Act of 1999).

Under the general requirements of these data security and breach regulations, where a data breach occurs which is likely to result in serious harm to any individual’s personal information, then we will notify the relevant affected individuals (and other parties as required by law) and advise:

  1. Our identity and contact details.
  2. A description of the data breach

iii.  The kinds of information concerned; and

  1. Recommendations about the steps the individual should take in response to the data breach.

10.      TRACKING TECKNOLOGY.

We use Tracking Technologies. These may include:

a)         Cookies: These are small pieces of data that are stored on your computer, mobile phone or other device.

b)         Pixels: These are small blocks of code on web pages that do things like allow another server to measure viewing of a webpage and often are used in connection with cookies.

c)         Local Storage: Like pixels and cookies but hold more data.

We may choose to use other Tracking Technologies, which perform similar functions such as Web Beacons, Clear Gifs and Plugins (e.g., HTML5, Indexed DB, WebSQL and Silverlight storage). Like cookies, some of these technologies may store small amounts of data on your device.

We use these technologies to do things like:

  1. d) Make our Websites and Service easier or faster to use;
  2. e) Enable features and store information about you (including on your device or in your browser cache);
  3. f) Deliver, understand and improve Contexture and potential Partner Marketing;
  4. g) Monitor and understand the use of the Service and our Products; and
  5. h) Protect you, other third parties and us.

You should refer to your browser or device's help material to learn what controls you can often use to remove or block cookies or other similar technologies or block or remove other data stored on your computer or device (such as by using the various settings in your browser). If you do this, it may affect the performance of your use of our Service.

11.      RIGHT TO ACCESS, UPDATE OR CORRECT YOUR INFORMATION.

The applicable laws of your country may give you the right to contact us to update, correct and request removal of inaccurate personal information we have about you or your Authorized Users.

You can review the account registration information you have provided to us and make any desired changes to the information, or to the settings for your Contexture account, at any time by logging in to “Your Account” on the Contexture website and editing the information on your profile page or your Authorized User’s profile page(s).

If you close your Contexture account, we will not automatically remove your name or other personally identifiable information from our database.  You may request to have your PII removed in accordance with certain regulations that give you this right in your country, however, in order to maintain our compliance with these regulations and requirements we may need to retain certain information in order to identify who you are relative to this request and your erasure or account deletion.

If you have a question regarding our privacy practices or want to exercise your rights regarding your personal information, please contact us through our website at www.contexture.ai .

12.      DATA RETENTION.

We will keep Personally Identifiable Information only for as long as it remains necessary for the identified purpose or as required by law, which may extend beyond the termination of our relationship with you.

We may retain certain data as necessary to prevent fraud or future abuse, or for legitimate business purposes, such as analysis of aggregated, non-personally-identifiable data, account recovery, or if required by law.

Please note that if you request that Personally Identifiable Information be removed from our databases, it may not be possible to completely delete all Personally Identifiable Information due to technological and legal constraints (such as if their Personally Identifiable Information appears in another student’s Data).

All retained Personally Identifiable Information will remain subject to the terms of this Privacy Policy.

Notwithstanding the foregoing, Personally Identifiable Information belonging to students will be deleted in all cases (to the extent that it is reasonably and commercially possible to do so) when it is no longer needed for the purpose for which it was collected.

Our standard policy is to store Cyber Safety Data for 30 days. After that time related records are aggregated and anonymized. We MAY offer you the option to extend this storage period. For the purpose of quality assurance or due to technical limitations we may capture temporal Cyber Safety Data when End Users have set to be “not tracked”. We will however purge such data as soon as practical.

13.      CHANGES TO THIS POLICY.

We may, from time to time, make changes to this Privacy Policy. Such revisions shall be effective immediately, provided however for existing members, such revisions shall unless otherwise stated, be effective 30 days after posting.