Effective Date: July 16, 2024

PLEASE READ OUR PRIVACY POLICY CAREFULLY BEFORE USING OUR WEBSITE OR SIGNING UP FOR OUR SERVICES. This Privacy Policy describes how we manage and process personal information when we provide math education services (the “Services”) and with visitors and users of the U.S. version of our website at https://ctcmath.com (https://ctcmath.com may be referred to individually as the “Website” or as “we” or “us”, or it may be collectively referred to as the “Websites” along with the Australian version of our website at https://mathsonline.com.au). The Websites are published and operated by Mathematics.com.au Pty Ltd, which is a limited company registered in Australia that has a registration number of ABN 23 102 420 600.

We are committed to preserving the privacy of all visitors to our Websites and users of our Services. Please read this privacy policy to understand how we collect your personal information and how we use and protect your personal information.

By using our Websites and Services, you agree to the collection, use and disclosure of your personal information under the terms of this privacy policy (the “Privacy Policy”).

If you are under the age of 18, please obtain the consent of your parent or guardian before providing us with any personal information or using our Websites or Services. Children under 13 will be required to notify their parents and help us to obtain their consent before providing any personal information or using our Websites or Services.

1. WHAT PERSONAL INFORMATION WE MAY COLLECT

We may collect certain personal information in the performance and provision of our Services, and the management of our Websites.

For example, if you register to access the Services on our Website, you may be asked to provide information such as your name, email address, residential address, telephone number, and the names of students you intend to use our Services. You do not have to use real names. Aliases or pseudonyms may be used.

In addition, if you request a login or require a password reset, you may be asked to provide a name and email address.

If you purchase Services or sign up for a trial to use our Services, you may be asked to provide your name, email address, residential address, telephone number, as well as to provide credit card information (which will not be stored on our servers).

We may also collect personal information you submit via any online forms, surveys, message boards, forums or other interactive areas that appear on our Website from time to time or in the course of providing Services to you. We may collect your name and email address if you sign up to receive our newsletters.

We may collect your name, email address, and telephone number when you register to attend an event.

We may collect personal information about you if you contact us offline, for example by telephone, email, or via mail.

We may collect personal information about your usage of our Website including specific Services.

Except for the above-listed items, we do not collect personal information.

2. UNSOLICITED PERSONAL INFORMATION

If we receive unsolicited personal information about you, we will check whether that personal information is reasonably necessary for us to provide products or services to you or otherwise reasonably necessary for us to undertake our functions or activities. If it is, we will handle this personal information the same way we do with other personal information we seek from you. If not, we will destroy or de-identify it.

3. HOW WE USE YOUR PERSONAL INFORMATION

We will use your personal information only for the purposes disclosed at the time of collection or as otherwise defined in this Privacy Policy, unless we have your consent for another use or unless such other use is required by law. The purposes we use personal information for, include the following:

1. For educational purposes;
2. To provide Services to our customers;
3. To close sales of new Services and register trials to prospective customers;
4. To process payments for our Services;
5. To manage our business relationships with customers, prospective customers, service providers, and other business contacts;
6. To communicate with you and respond to an inquiry you make to us;
7. To generate analytics for the improvement of the Website;
8. To advertise and market our Services, which may include sending you newsletters and other communications about our company and Services and may also include using your personal information to identify target audiences for our Services and to develop marketing campaigns for those target audiences which will be executed via various platforms including on or via our social media platforms and via search engines. Your personal information will not appear in any marketing campaigns that we execute for targeted audiences;
9. To analyze the personal information we collect so that we can administer, support, improve and develop our Website and the Services we offer;
10. To administer, maintain, manage, and improve our business operations;
11. To contact you for feedback on your use of our Websites or Services;
12. To defend our legal rights or comply with our legal obligations;
13. For all other necessary business purposes; and
14. And as otherwise required by law.

4. WITH WHOM WE MAY SHARE YOUR PERSONAL INFORMATION

We may pass aggregate information about the usage of our Websites and Services to third parties, but this will not include personal information that can be used to identify you.

We will disclose your personal information if we are required to by law. We may disclose your information to enforcement authorities, or to a third party in the context of actual or threatened legal proceedings. We may also disclose personal information if we believe disclosure is necessary or appropriate in connection with an investigation of suspected or actual fraudulent or illegal activity (both investigations related directly to our website or broader investigations).

We may also share your personal information for certain purposes with our professional advisors and representatives (eg, lawyers, accountants, auditors, corporate consultants, or business analysts) to assist us with our corporate or business functions and to develop our business.

We may disclose personal information in the event of a proposed or completed sale or transfer of all or a portion of our business or assets (including in the event of a reorganization, dissolution, or liquidation). We will make reasonable efforts to notify you by posting a notice on the Site and, sending you an email if we have your email address.

We may also disclose your personal information to service providers we engage to assist us in administering, supporting, improving, developing, and marketing our websites and managing our relationships with our customers and other persons on our mailing and contact lists (eg, assisting us to send newsletters and email updates).

Unless permitted by the previous paragraphs of this section or required by law, we will not otherwise share, sell, or distribute any of the personal information you provide to us without your consent.

5. DATA PROCESSORS

We may utilize certain third-party service providers, which may have access to personal information provided in conjunction with the Services and perform the role of a third party data processor. The name, location, business and website address of these third-party service providers is provided below, along with a description of the services they provide:

6. CATEGORIES OF INFORMATION, SOURCES, USE, DISCLOSURE

The categories of information we have collected in the past twelve (12) months are as follows:

7. COOKIES

Cookies are small text files which are transferred from our websites and stored on your computer's hard drive. They enable our website to “remember” who you are.

We use session cookies and persistent cookies to identify and track users who enter the registration areas of our websites. Session cookies are deleted when you close your browser. Persistent cookies will remain on your browser until you delete them. We do not use “spyware”, that is, web bugs or hidden identifiers or other similar devices to gain access to information, store hidden information or to trace activities of users.

Most browsers are automatically set to accept cookies but if you are using Microsoft’s Internet Explorer or Mozilla Firefox, you should be able to configure your browser to restrict cookies or block all cookies if you wish. If you disable cookies, you will still be able to login and use the registration areas of our website, products and services but you may not be able to access the full functionality.

We do not use web-based tracking technologies in our business. If we decide to employ web-based tracking technologies in the future, we will notify you of the change and provide information about the technologies we are using, how we use those technologies, how the technologies may affect you, and what you can do to modify or control them.

Currently we use the following cookies set forth in the list below for the following purposes:

8. YOUR RIGHTS

You have the following rights with regard to your personal information:

1. Right to Correct. You have the right to correct any errors in the personal information we hold about you. Please inform us about changes to your personal information as specified in Section 16 of this Privacy Policy so that we can keep our records accurate and up to date. We will try to deal with your request within 30 days of your request (or such longer period as is reasonable in the circumstances given the volume of your personal information and whether the personal information is currently in use or archived).
2. Right to Delete. You have the right to request deletion of the personal information we hold about you. If we delete your personal information as requested, your experience with the website, products and services may be diminished. If you require deletion of the personal information we hold about you, please contact us as specified in Section 16 of this Privacy Policy.
3. Right to Access. You have the right to access the personal information we hold about you. You may request access to any personal information we hold about you by contacting us as specified in Section 16 of this Privacy Policy. Whenever you are entitled to access such personal information, we will provide such personal information to you via email or post without charging you for such access. We will try to respond to your request within 30 days of your request (or such longer period as is reasonable in the circumstances given the volume of the personal information to which access has been requested and whether the personal information is currently in use or archived).
   There will be instances where we cannot grant you access to your personal information (eg, where access would interfere with the privacy of others). If we refuse your request, we will provide reasons for our decision unless doing so would be unreasonable in the circumstances. If you are not satisfied with our response, you can make a complaint in accordance with Section 13 of this Privacy Policy.
4. Right to Opt Out. You have the right to opt out of receiving any marketing material from us or any third party at any time. Please note that if you unregister from our communications, we may still send you relevant administrative or security notices from time to time. You also have the right to request that we opt you out of the sale, disclosure, or processing of certain of your personal information.
5. Right to Disclosure. Right to request that we disclose personal information or categories of personal information that we collect, use, disclose, and sell; the purposes for which the categories of information collected by us are used; the sources of information from which we collect personal information; and the specific pieces of information we have collected on you.
6. Right to Non-Discrimination: Right to non-discrimination for exercise of your rights.
7. Right to Limit Sensitive Personal Information: Right to limit the use and disclosure of sensitive personal information collected about you.

We make every effort to extend all of the above-stated rights to all consumers, regardless of their location of residence.

However, given the nature of our services and business, we may be subject to certain exemptions from these rights and unable to extend them to you in all cases.

For example, the nature of our services is to provide a software platform and related software services to subscribers and authorized users. Therefore, in certain cases, we may not be able to act on your request because we are a “service provider” rather than a business directly providing the services to you. Also, in certain cases, we may not be able to act on your request due to the nature of the information your request pertains to and/or the nature of the services we are providing to our subscribers.

If you submit a request regarding the exercise of your privacy rights and we are unable to act for one of the reasons listed above or another reason, we will advise you accordingly and provide the reason for our denial. We will not discriminate against you because you exercise your rights.

For any such request, you will be required to submit three pieces of information including but not limited to your name, address, and home number. We will use this information to search our systems and determine if we have information about you. If we are able to locate information about you, we will fulfill your request. If we are not able to match all three pieces of information you submit, we may provide you with a report that includes the categories of information we collect, use, disclose and sell.

If you are an authorized agent, you will be required to submit your name, address, and phone number, as well as the name, address, and phone number of the person on whose behalf you are making a request. If we are able to locate the information about the person on whose behalf you are making the request, we will fulfill your request. As an authorized agent, you will also be required to complete a form certifying you have the right to make this request on behalf of the third party.

You can make or submit a request related to the exercise of your privacy rights by contacting our Chief Privacy Officer at (310) 281-2229 or by sending an email to info@ctcmath.com. You also may make a request in writing to the mailing address provided in Section 16 below.

9. SHARING PERSONAL INFORMATION WITH LAW ENFORCEMENT

Please be advised that we may be required to share personal information in response to lawful requests by public authorities, including but not limited to national security or law enforcement requirements.

10. SECURITY AND RETENTION OF PERSONAL INFORMATION

All personal information that we collect will be transferred to and stored securely in Sydney and Melbourne Australia on our host servers with Amazon Web Services. Our data is fully managed by AC3 (Australian Centre for Advanced Computing and Communication Pty Ltd), a trusted government partner, and fully complies with the Australian Privacy Act 1988 (Cth) (Privacy Act), including the 13 Australian Privacy Principles (APPs) (including the prohibition on transferring personal information outside Australia). Access to these servers is limited to the application, and by our software developers. Customers will be given at least one year's notice of any relocation of our cloud infrastructure. Our data servers are supported and monitored on a 24/7 basis and are compliant with ISO27001 and ISO9001.

We will keep your personal information secure by taking appropriate technical and organizational measures against its unauthorized or unlawful processing and against its accidental loss, destruction, or damage.

All data transferred within the application is protected by SSL. SSL is a technology that makes your data illegible in transit. If anyone were to intercept communication between our servers and your computer, they would not be able to easily decipher what was being passed back and forth.

We will retain your personal information for as long as we need it for the purposes set out in this privacy policy, or as otherwise required by law.

Our data retention practice is to retain personal information for the length of the customer relationship and for a period of five (5) years after we cease to provide services to such customer, except to the extent we are required to keep the data longer for any reason, in which case we will retain the applicable data for the period in which it is necessary to be retained for the purpose in which it was collected, or until we are no longer required by law to maintain it, to the extent applicable. In the case of all other data that does not constitute personal information, we will retain such customer data for the length of the customer relationship and for a period one hundred eighty (180) days after our services are terminated, at which point such customer data will be purged.

11. HOW WE PROTECT THE PERSONAL INFORMATION OF CHILDREN

1. Our Services are Not Directed to Children

   Our Services are not directed to children but to parents and teachers of children. Thus, in accordance with the requirements set forth in 16 CFR Part 312:

   1. Our Website does not incorporate subject matter, visual content, use of animated characters or child-oriented activities and incentives, music or other audio content, child models, child celebrities or celebrities appealing to children, or advertising directed to children.
   2. Our Website and Services do not collect personal information directly from users of a third-party website or online service directed to children.
   3. Our Website and Services do not collect personal information from any visitor prior to collecting age information.
   4. Our Website and Services prevent the collection, use, or disclosure of personal information from visitors who identify themselves as under age 13 without first complying with the notice and parental rights requirements.
2. Notice and Parental Rights Requirements

   We provide direct prior notice to parents of our personal information practices and obtain their prior verifiable consent prior to collecting personal information from their children in accordance with the requirements of the Children’s Online Privacy Protection Act (“COPPA”). If you are a parent, you have the right to review the child’s personal information provided to use, and to have that information deleted. You also have the right to refuse to permit its further collection or use. To make a COPPA-based request, you should direct your communications to our Chief Privacy Officer at info@ctcmath.com, or (310) 281-2229. Please title any such request “COPPA Privacy Request” in order to better direct us to respond.

3. Our Data Retention and Deletion Requirements are COPPA Compliant

   We comply with the data retention and deletion requirements set forth in 16 CFR Part 312 Section 10, and only retain the personal information collected online from a child as long as is reasonably necessary to fulfill the purpose for which the information was collected. Also, we delete the information using reasonable measures to protect against unauthorized access to or use of the information in connection with its deletion.

4. What Personal Information We May Collect from Children.

   If we were to collect the personal information of children under the age of 13, we may collect the following:

   Types of Personal Information Collected from Children	How the Personal Information is Collected	How the Personal Information will be Used	Third Party Businesses to Whom You will Disclose Personal Information
   Name	Directly from customer	Provide Services Manage Educational Purpose	Service Providers
   Email Address	Directly from child	Provide Services Manage Educational Purpose	Service Providers

12. OUR AGE APPROPRIATE DESIGN MEASURES

We have taken appropriate measures to ensure that the default privacy settings for our Service are configured to ensure a high level of privacy protection for any child accessing the Service, as well as to ensure that we only use the personal information of any child for the reason in which is was collected, except to the extent that there is a compelling reason that an alternative use is in the best interests of the applicable child or children generally. We are also making efforts to ensure that the terms of our privacy policy are available in clear, age-appropriate language that can be understood by any child accessing the Service. For any tracking we conduct on our Websites, we display an obvious signal to alert any children accessing the Services that their activity is being monitored and by whom it is being monitored. Notwithstanding the foregoing, we do not intentionally track or monitor children in real time, except to timestamp student activities when a child views lessons or answers questions. We are also taking steps to complete a data protection impact assessment on or before July 1, 2024 with respect to any online service, product or features that may be accessed by any child under the age of 13.

13. MAKING A COMPLAINT

If you think we have acted in violation of any applicable law or regulation, or you wish to make a complaint about the way your personal information has been handled, you can contact us as provided in Section 16 below. Please include your name, email address and/or telephone number and clearly outline the complaint. We will acknowledge your complaint and respond to you regarding your complaint within a reasonable period of time. We will cooperate with the appropriate regulatory authorities to resolve any complaints regarding personal information that cannot be resolved via our internal complaints procedure.

14. LINKS

If you follow a link from any of our websites to another site, this Privacy Policy will no longer apply, and you will be subject to the Privacy Policy and other terms and conditions while visiting that website. We are not responsible for the information handling practices of third-party sites.

15. CHANGES TO OUR PRIVACY POLICY

We will from time-to-time update and make changes to this Privacy Policy at any time in our sole discretion and without prior notice. If we make any material amendments, we will advise you of those changes by notifying you in a prominent place on our Website, and/or by sending a writing to you. You should check back with us from time to time in order to confirm that there have been no significant changes.

Please note that the use of information that we gather is subject to the Privacy Policy then in effect at the time of use.

16. CONTACT US

For further information about this Privacy Policy, or our privacy practices, or to access or correct your personal information, or to make a complaint, please contact us using the details set out below:

Chief Privacy Officer
info@ctcmath.com
(310) 281-2229

17. MAKING ALTERNATIVE FORMAT REQUESTS

If you have a physical disability you have the right to request this privacy policy in an alternative format. To make a request for an alternative format, please submit your request to our email address at privacy@ctcmath.com or call us at (310) 281-2229. We also accept requests made in writing to the mailing address provided in Section 16 above.

18. CORPORATE INFORMATION

Mathematics.com.au Pty Ltd is a company with a registered office located in Australia. Our corporate headquarters are located at Suite 7, 4-10 Hillcrest Road, Pennant Hills, NSW 2120 Australia.

19. EFFECTIVE DATE

The effective date of this privacy policy is July 16, 2024.