Privacy Policy

GDPR Data Controller and Data Processor

In short: You will find information in this document about how we process the personal data that we collect. Customers using our products are responsible for the data that they collect about you, so you may need review their Privacy Policy too

In UK & European data protection law (GDPR), a Data Controller is the entity that collects your information and makes decisions on how it is used. A good example of this is a school which is the Data Controller for information regarding its students. A Data Processor is a third party that performs duties on behalf of the Data Controller. A good example of this is a payment processor that might process school fee payments from parents on behalf of the school.

Where our products are used to process the data of UK & EU residents, Education Horizons is not a Data Controller of the data, but will typically be a Data Processor. Therefore, it’s important to review the Data Controller’s Privacy Policy in order to understand how your data will be processed.

Where we act as a Data Processor, our activities will be strictly limited to what we’re asked to do by the Data Controller. Typically, this would include activities such as onboarding new customers and helping to convert their existing data, as well as providing remote support. We are not able to respond directly to data subjects.

What personal data do we collect and why?

In short: We collect personal data to provide our products and services and operate our business.

We collect, store and process personal data provided to us by users of our products and services (who may be the relevant individual or a third party user (eg a school)). This personal data will typically include the types of personal data identified below.  

• In respect of students and parents: name, date of birth, contact details (eg, phone numbers, email address), race or ethnicity, student unique identifiers, emergency contacts, sexual orientation, religion, bank account details of parents, information about payments and billing, references, performance, and educational needs reports, recording of medical data and incidents, tuition and extracurricular accounts, incident reports involving pupils or students.

• In respect of staff of the relevant school: name, job title, date of birth, contact details, employee identifiers, national insurance number, bank account details, court orders, trade union membership, race or ethnicity, religion, pension information, tax codes, grade, occupational health information, disciplinary and grievance information, accident reports, medical and health information, right to work checks, passport details, referees, criminal record disclosures and beneficiary information.

• In respect of other customer community members such as other debtors, creditors and contractors: name, email address, address and phone number.  

If you apply for a job with us, we will collect and use your personal data which will typically include your name, phone number, email address, postal address, nationality, educational qualifications, date of birth, employment history and any such information that might appear on your CV / application or is disclosed during the recruitment process (such as remuneration information). Our employees and potential employees will also be expected to provide reference information, financial information such as bank details and tax identifiers, and sensitive information such as criminal record history, workers compensation information, race or ethnicity and health information.  

If you are one of our current or prospective business partners, we will collect and use your personal data which will typically include your name, contact details, bank and payment information, videos and photos.  

Personal data will be collected by Education Horizons in a number of circumstances, including when an individual:

• requests to download a document, product trial or video from Education Horizons;
• makes an enquiry through our website or online enquiry service;
• lodges a support request regarding an Education Horizons product or service;
• subscribes for a newsletter;
• attends, or registers to attend, a seminar or other event (such as a webinar or training event);
• enters a competition;
• applies for or enters employment with us, including short term or consulting work;  
• uses our products or services, including where such products or services are provided by a third party (eg a school); or  
• otherwise interacts with any entity within Education Horizons.

We may also collect contact details about employees of certain international schools from our market intelligence partners, such as ISC Research. If you have any questions on this, please reach out to our Privacy Officer whose details can be found in the ‘Contact Us’ section below.  

How do we use your personal data?

In short: We process your information for many purposes such as providing products and services to our customers.

Education Horizons will use your personal data for a variety of purposes. Typically, these purposes include:

• administering and providing our products and services to you and your organisation;
• sending customers informational notifications and alerts;
• responding to enquiries;
• marketing Education Horizons products and services;
• hiring and managing employees and contractors;
• managing training and events;
• evaluating and improving Education Horizons products and services
• assisting our customers with support requests, data and reporting requests, onboarding and offboarding
• securing our systems, for example, protecting against bots and attackers, and for audit logging purposes

We will only use sensitive information we collect from our staff to help with employment processes such as recruitment, sickness management, equal opportunities reporting, disciplinary proceedings, or making reasonable adjustments in the workplace.

We will only use sensitive information collected from students, teachers and parents through use of our products and services for the purpose of delivering the platform services to our customer (eg the relevant school).  

GDPR – Lawful basis

Put simply, under the GDPR, a company must have a valid lawful basis wherever they process personal data. This means that for each processing activity, the company must determine at least one lawful basis to use.

At Education Horizons, we typically rely on one of the following lawful bases:

• Legitimate interests: where the processing is necessary for your legitimate interests or the legitimate interests of a third party, unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests.
• Contract: where the processing is necessary for a contract a company has with an individual, or because they have asked the company to take specific steps before entering into a contract
• Legal obligation: where the processing is necessary for a company to comply with the law
• Vital interests: where the processing is necessary to protect someone’s life
• Consent: where the individual has given clear consent for a company to process their personal data for a specific purpose. Note that consent is only used in limited circumstances and you have the right withdraw your consent at any time.

Direct Marketing

We do not use personal information collected in connection with customers’ use of our products for marketing purposes. If we have collected your personal information because you are a representative of one of our current or prospective partners or customers, we may send you marketing emails. You can opt-out at any time by following the unsubscribe link contained in the relevant electronic communication, or by contacting our Privacy Officer at privacy@educationhorizons.com.

Who do we disclose your personal data to?

In short: We may share your information amongst Education Horizons entities for the purposes outlined above and with our service partners who help us supply our products and services.

We may share personal data between members of the Education Horizons group (including to majority shareholder Potentia Capital Pty Ltd), for the purposes described in this policy.

As Education Horizons is part of an international group of companies, some personal data (for example, lead prospects, employee or candidate information) may be transferred outside of the source country, for example from Australia to the UK and vice-versa. The circumstances where this is necessary include processing customer sales opportunities and employment processing and hiring.

Personal data may also be disclosed outside Australia to our cloud service partners who help us supply our products and services (see the ‘Sub-Processors’ section below for further details).

Cloud Services

Education Horizons uses cloud services such as Amazon Web Services and Microsoft to store and process personal data. We also use cloud providers to protect our products and services. For example, we utilise security products and Captcha services to prevent and detect malicious activities.

Sometimes this information may be stored outside of your home country (see the locations in which this data may be disclosed under ‘Sub-Processors’ below).

Sub-Processors

As well as cloud service providers, Education Horizons make use of other companies and services to help us operate our business. Collectively, we refer to these companies and cloud service providers as sub-processors. From time-to-time we will change sub-processors and may be required to let you know. When we do, we will contact you via email detailing the change.

The key cloud-based services and other sub-processors that Education Horizons uses to process personal data can be found here

Education Horizons will not disclose personal data to third parties for marketing purposes without the relevant individual’s consent.

Under no circumstances will Education Horizons sell (or otherwise receive payment for licensing or disclosure of) your personal data.

Business Transfers

As we continue to develop our business, we may buy or sell business units or subsidiary companies. We may use and disclose personal data to support any such transactions, including disclosing personal data with other members of the Education Horizons group and other transaction parties, where appropriate.

myEdOnline

The myEdOnline product is designed to foster communities of practice within the Education industry. A teacher’s personal data, for example their name and photo, will be visible to other users of myEdOnline if they decide to share content outside of their organisation.

Website Data Collection

In short: We make use of cookies and other tracking technologies to collect and store your information. You can control non-essential cookies and opt-out of Google Analytics.

For information on our use of cookies, please review our Cookie Policy, accessible from any of our websites.

When you visit an Education Horizons website or use a product or service hosted by Education Horizons, the following information will normally be collected about you:

• the unique identifier from an Education Horizons cookie (necessary cookies only unless others are consented to);
• the date and time of your visit;  
• the pages, documents and files you requested and when;
• the address of the resource which provided the link followed, if any, to an Education Horizons website;
• the type of browser and, in some cases, the operating system used.

If you later decide to register with us, the above information will be matched with your registered information to enable a more personalised profile. This information is only available to a limited number of Education Horizons staff.

Google Analytics and Web Beacons

Another tool we use to help us improve our sites and understand how they are used is Google Analytics. For more information on how Google Analytics collects and processes data, please see https://policies.google.com/technologies/partner-sites.

You can opt-out of Google Analytics by installing the Google Analytics Opt-out Browser Add-on, available here: https://tools.google.com/dlpage/gaoptout.

We also sometimes use ‘web beacons’. Web beacons are tiny transparent graphical images, that are sometimes embedded in our notification and marketing emails. They allow us to understand when an email has been opened and help us gauge the effectiveness of our customer communications. You can block web beacons by preventing pictures from automatically downloading in your email client. This is normally found in the settings.

Data Retention and Security

Our staff are trained in how to keep your information safe and secure. We use physical, electronic and other security measures to protect the security, confidentiality and integrity of the personal data we hold and use.

At Education Horizons, we are committed to only keeping personal data for as long as is necessary. Once data has come to the end of its useful purpose or lawful retention period, we take reasonable steps to securely erase or anonymise the data.

Your rights

Anonymity and pseudonymity

When you interact with us, you have the option of not identifying yourself (anonymity; or being anonymous), as well as the option to use a false name (a pseudonym). We are happy to help you unless its impractical to do so without knowing who you really are. We also will have to identify you if the law or a court order requires us to.

Can I correct and have access to my personal data?

Education Horizons takes reasonable steps to ensure that the personal data it stores is accurate, complete and up to date. You have the right to ask us to correct your information, which we will happily facilitate at no cost to yourself.

You also have the right to request access to your personal data held by Education Horizons. We will aim to provide you with an appropriate means of accessing your data, normally by a secure email or registered post. In some jurisdictions such as Australia, we reserve the right to charge reasonable costs in providing the requested information to you. However, we will not charge for simply making the request.

Sometimes it’s not possible to give you access to the personal data we hold. An example of where this might happen is where granting access may impact the privacy of others or if the information may cause significant harm or distress. We will give you written reasons for any refusal.

To make an access or correct request, please contact us on the details under ‘Contact Us’ below.

Your rights under GDPR

UK & EU residents have the following additional rights:

1. The right to be informed – that’s why we have this document. We will also provide you information at the point that we collect data from you.
2. The right to rectification – You are able to ask us to correct your data, as per the section above.
3. The right to erasure – You have the right to ask us to delete your data under certain circumstances, unless we have a valid and lawful reason to keep it.
4. The right to restrict processing – You are able to ask us to limit any further use of your data
5. The right to data portability – You have the right to ask us to provide you with access to your data in a common, machine readable format such as a CSV file.
6. The right to object – You can object to us processing your data if you wish, for example if you don’t want your information to be used for direct marketing.

To exercise any of these rights, please contact our Privacy Officer at privacy@educationhorizons.com.

Other jurisdictions

Our main offices are in Australia and the UK. We do have customers globally, and if you would like to talk to us about compliance or your rights under any other jurisdiction, please get in contact with privacy@educationhorizons.com.

Contact us

Education Horizons has a Privacy Officer who oversees company activities to ensure that personal data is handled lawfully and in line with legal obligations wherever we operate. You can contact the Privacy Officer using the details below.

• By Post: Education Horizons Ltd, Suite 1.01, 109 Burwood Rd, Hawthorn, VIC, 3122, Australia
• By telephone: (03) 8594 3400 (Monday to Friday, 8.30am to 4.30pm AEST)
• By email: privacy@educationhorizons.com.au

Education Horizons also has a representative in Europe who can be contacted directly at privacy-eu@educationhorizons.com.

Complaints

To raise a privacy complaint, please submit a written description of your concern to our Privacy Officer at privacy@educationhorizons.com. We will review your complaint and provide a response within 30 days.

If you have spoken to us but would still like to take the matter further, then you have the right to make a complaint to the relevant supervisory authority, as per the below:

• Australia: Office of the Australian Information Commissioner (OAIC)
• Website: https://www.oaic.gov.au/privacy/privacy-complaints/
• Phone: 1300 363 992
• UK: Information Commissioner’s Office (ICO)
• Website: https://ico.org.uk/make-a-complaint/
• Phone: 0303 123 1113

Changes to this notice

We may change this Privacy Policy periodically as needed. Any updated versions of this notice will be posted on our website.

This notice was last updated on 23rd April 2024.