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Last Updated: April 4th, 2024
Gradeo is committed to processing your personal information and personal data, responsibly and in accordance with data protection principles and applicable law. We take our privacy obligations seriously. This privacy policy explains how we collect, use, share and protect information about you and your rights in relation to your personal information.
Except where specified otherwise, this privacy policy applies to Gradeo Pty Ltd (collectively referred to as “Gradeo”, “we”, “us” or “our”).
We have adopted the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth) (the Privacy Act).The APPs govern the way in which we collect, use, disclose, store, secure and dispose of your Personal Information. A copy of the Australian Privacy Principles may be obtained from the website of The Office of the Australian Information Commissioner at www.oaic.gov.au.
In this privacy policy we use the terms “Data Controller” and “Data Processor”. These terms have special meanings. “Data Controller” means the organisation or person that determines the purpose and means of the processing of personal information, for example an organisation or educational institution that is a test sponsor and uses our products and services to deliver assessments to test takers. “Data Processor” means the organisation or person that processes personal information on behalf of the Data Controller.
Except when stated otherwise, this privacy policy addresses Gradeo’s activities as a Data Controller. When acting as a Data Processor for its customers, Gradeo is contractually bound to comply with privacy obligations in legally binding contracts that address the requirements of applicable law.
Gradeo only processes personal information pursuant to a lawful basis in accordance with the requirements of applicable law. Lawful bases may include your consent, our legitimate interests and for the performance of a contract with you where products or services are provided. Where Gradeo is acting as a Data Processor, the Data Controller is responsible for ensuring personal information is provided to Gradeo in accordance with applicable law and Gradeo may only process such personal information in accordance with the instructions of the Data Controller.
This privacy policy applies to any Gradeo website which includes a link to this privacy policy, including the main public-facing website at www.gradeo.com.au
Information Collected. When you create an account on Gradeo, join our mailing list or register interest, register for or purchase services either on our main website or via a third-party payment merchant, you enter various information including name and contact details.
Gradeo also collects information at this time, including the internal protocol (IP) address used to connect your computer to Internet; login; email address; password; computer and connection information such as browser type and version, operating system, platform and purchase data. Gradeo also records information about your interaction with Gradeo systems and personnel within our customer relationship management system, such as which resources you access or download.
Gradeo uses cookies to allow you to stay logged into the website, to make the website experience more useful (such as remembering your preferences), and to gather general statistical information about site use and for marketing purposes. You can manage your cookie preferences and settings through your browser or device settings. Please note that disabling certain cookies may impact the functionality and user experience of the Gradeo website.
Children. Gradeo does not knowingly collect personal information through its websites from any person under the age of 13. We do not market our products and services to persons under the age of 13. If you become aware that a child under the age of 13 has provided personal information to our website, please contact us using the information below.
How Information Is Used. Gradeo uses the information collected via its websites for its internal business purposes (such as maintaining and improving our products and for general, reasonable administrative purposes), to correspond with you (including to provide information on our products and services and for sales and marketing purposes – unless you have opted out of receiving such correspondence in accordance with applicable laws), to gather and analyse information and monitor activity on the website and to provide you with the best product experience. For example, we may use information provided in interactions with our support personnel or using our website to improve our documentation.
Visibility of Information. The personal information you provide to Gradeo will only be visible to you, Gradeo and its affiliates, authorised contractors and subprocessors.
Collection of sensitive information
Sensitive information is defined in the Privacy Act as including information or opinion about such things as an individual’s racial or ethnic origin, political opinions, membership of a political association, religious or philosophical beliefs, membership of a trade union or other professional body, criminal record or health information.
Generally, we do not intentionally collect sensitive information about either current or prospective customers or users. However, as the nature of our services is broad and varied, there may be times when this is required. In cases where sensitive information is provided to us, we will take all reasonable steps to ensure that the necessary consent has been obtained and that the data is securely protected.
Gradeo does not sell or rent personal information (including your email address) it collects to others; however, it may disclose personally identifiable information in the following situations and where applicable in compliance with and limited by the requirements of applicable data protection laws and other commitments made by Gradeo to good privacy practice:
(a) in response to a subpoena, court order or legal process, to the extent permitted and required by law;
(b) to protect your security or the security of other persons including in response to lawful requests by public authorities, including for national security or law enforcement purposes, consistent with applicable law;
(c) in connection with a sale, joint venture or other transfer of some or all of the assets of Gradeo and/or its affiliates, provided that the acquirer commits to using personal information in a manner consistent with applicable law and this privacy policy;
(d) to companies in the Gradeo group including its affiliates, and a limited number of organizations or individuals who are working as our authorised contractors, resellers or agents and who are committed and obliged to protect your privacy in a manner consistent with this privacy policy and applicable law;
These organisations and individuals assist us in providing services to customers and prospects, including the provision of data storage services, customer relationship management, technical support and consulting or other services, and may as instructed by Gradeo to access, store, use or process personal information when providing services to us;
(e) when you request it, for instance if you have asked us to do this as part of an effort to connect you with experts who can help you.
The Data Controller is responsible for ensuring that transmittal of personal information collected from you as part of the assessment process is in accordance with applicable data protection laws. Gradeo acts in accordance with the Gradeo Customer’s instructions in respect of such personal information.
As a Data Processor of any personal information collected from you as part of the assessment process, Gradeo may only disclose personal information to others as authorised by the applicable Gradeo Customer in accordance with applicable laws.
Gradeo retains your personal information for as long as is necessary to provide its services which includes prudent, limited duration archive retention, for compliance with legal obligations, to enforce our rights under agreements and as permitted under applicable data protection law. Retention periods will therefore reasonably vary based upon the nature of the personal information involved.
Where personal information is stored within our services by Gradeo Customers or their end user customers, the Data Controller determines and is responsible for the length of time during which personal information is retained. Gradeo acts in accordance with the Data Controller’s instructions and may not retain personal information contrary to these instructions.
Gradeo may from time to time use assessment or website personal information collected for purposes of maintenance and operation of services provided to you, including for internal quality assurance purposes, for instance to ensure that new releases of software behave as expected.
Gradeo has a formal data security policy that keeps track of any such data and carries out internal exercises to ensure that it is not misused.
Gradeo may statistically aggregate data in non-person specific form, and subject to applicable law use this data for operations management, quality control, security and marketing purposes and to improve the quality of our future products and services, and subject to applicable law pass this to Gradeo Customers and their end user customers. Such activities on any personal information provided for assessment purposes may only be carried out with the instructions of the Gradeo Customer, for which Gradeo acts as a Data Processor.
By using our site or services, you give consent for such use. Except where our use does not require consent under applicable law, you may withdraw your consent to such use at any time by contacting us as described in this privacy policy. The right to object to processing of your personal information under the GDPR applies even when we process your personal information on a basis other than your consent, such as based on our legitimate interests or to perform a contract with you.
To prevent unauthorised access, maintain data accuracy, ensure the appropriate use of information and protect against the loss, misuse or alteration of information under our control, we have put in place appropriate physical, technical and administrative controls to protect personal information we collect through our website. Gradeo maintains a formal data security policy that is regularly reviewed and audited and on which all employees are trained.
Where Gradeo acts as Data Processor, we comply with written contractual obligations agreed with Gradeo Customers, including having in place appropriate technical and organiSational measures that are designed to protect personal information.
Our websites and assessments taken using our services may contain links to other websites on the Internet that are not operated by Gradeo. For the avoidance of doubt, this privacy policy covers only the Gradeo sites and servers and not other websites or systems, even if linked to fromGradeo’s websites.
This policy may change from time to time to reflect changes to our business, however, the latest version of this policy can be accessed on our website. We will amend the revision date at the top of this page to indicate when we have made changes.
Gradeo is committed to working with individuals to obtain a fair resolution to any complaints or disputes about privacy and personal information.
You may request a copy of the Persona lInformation we hold about you or request that we update or correct it. In some rare cases, we may refuse access to certain information, for example, due to commercial sensitivity or legal reasons. In such a case we will write to you explaining our decision.
You may also request that we delete your Personal Information, in which case we will take reasonable steps to identify and permanently remove it from our systems unless it is required for legal or compliance needs.
Any questions, complaints or concerns about this privacy policy should be sent to Gradeo’s privacy team at privacy@gradeo.com.au
We will not charge any fee for your requests. Please allow up to 28 calendar days for us to process your request.
In order to protect your Personal Information we may require identification from you before processing your request.
If you have any questions or concerns about this privacy policy or how we have handled your personal information, please contact Gradeo’s privacy team at privacy@gradeo.com.au.
We will endeavour to investigate and respond to your complaint within 28 days. If this is not possible, we will contact you with a revised timeline for our full response.
If you are not satisfied with how we have handled your complaint, you can contact the Office of the Australian Information Commissioner (OAIC):
Office of the Australian Information Commissioner
GPO Box 5218
Sydney NSW 2001
1300 363 992
enquiries@oaic.gov.au