Privacy Policy
1.1 Wellio Pty Ltd (Wellio) respects the privacy of all individuals and, most notably, students. This privacy policy outlines Wellio’s approach to privacy and how Wellio collects, stores, uses and protects your personal information. It also sets out your rights in relation to accessing the personal information we collect and hold about you. We are bound by the National Privacy Principles in the Privacy Act 1988 (Cth).
1.2 Personal information is defined in the Privacy Act 1988 (Cth) and means information or an opinion about an individual whose identity is apparent or can be reasonably ascertained from that information or opinion.
1.3 Our website may contain links to third party websites. We are not responsible for the privacy policies of any third party websites. We recommend that you review the privacy policy of each website you visit.
2.1 Wellio only collects personal information for the purposes of supplying services to you. The personal information Wellio collects may include:
A. Information you provide us with:
We collect and store any information you knowingly provide us with when using our services, whether that be on mobile, computer or any other means. That information may include, without limitation, personal information such as your name, email address, school affiliation, question responses and any other information necessary for us to provide our services.
B. Information other users provide us with:
We may collect information other users provide us about you, which can include personal information. This is generally the case when a teacher, school or parent provides us with personal information about their students or children in order to create an account with Wellio.
C. Information collected automatically:
We collect and store certain types of usage information when you interact with our services. This information is not personal information. We collect usage information about things such as questions answered, length of your responses, order in which you select responses and the number of questions completed.
2.2 Wellio will only collect personal information from you by lawful and fair means and not in an unreasonably intrusive way.
3.1 We will use or disclose your personal information only for the primary purpose for which it was collected; or for a related secondary purpose where you would reasonably expect us to use or disclose the personal information for that secondary purpose. We may otherwise use and disclose your personal information if you have given us consent for the use or disclosure or it is required or authorised by law.
3.2 Generally, we use and disclose your personal information for the following purposes:
A. To provide a service to you
Wellio uses information to be able to provide our services to you. For example, to create a Wellio account, we may need to collect personal information such as name and email address.
B. To enhance the services we provide
Wellio uses the personal information to better the service we provide you. We collect and store relevant data when students complete lessons on our platform, so that we can provide educators and students themselves with relevant insights.
C. As testimonial
Under certain circumstances and only with consent from you, we may post your personal information on our website. This would only include your name, title and what you have said about our services. We may also collect anonymous survey data relating to how likely you are to recommend Wellio. This would be aggregated and may be published on our website as percentage figure.
D. School ownership of data
Schools will be able to download a CSV file with all student activity. This data is owned by the school and will continue to be the property of and under the control of that school.
E. Retaining data
Student accounts can only be deleted by admin accounts. When a student account is deleted, all the data is deleted with it, however, we may hold the data on our backup databases for a period of up to 90 days. After 90 days, all information from the deleted account will be removed from our database. Teachers can delete their accounts at any time. You have the right to request that our company restrict the processing of your personal data, under certain conditions.
F. Understand usage
Wellio automatically collects and stores information on our server logs from your browser, including Wellio cookie information, your IP address and pages visited. Cookies are alphanumeric identifiers that we transfer to your computer or mobile device. These are transferred, whether you are registered member or not and are used to help us gain an understanding of how our users are using our services. This enables us to tailor your own experience and create a better experience for our other users. If you wish to change your cookie settings, you can do so but this is dependent on the browser you are using, so we suggest looking at the ‘help’ section for the browser you are using. For more information on cookies, we recommend visiting Google Adsense. For more information about cookies, please visit allaboutcookies.org.
G. Types of cookies we use
We use the following types of cookies for the purposes explained below:
1. Essential Operational.
These cookies are necessary to allow us to operate Wellio as you have requested. For example, they let us recognise what type of user you are and then provide you with services accordingly.
2. Performance and Analytics.
We use these cookies to analyse how Wellio is accessed, is used, or is performing. We use this information to maintain, operate, and continually improve Wellio. We may also obtain information from our email newsletters, including whether you opened or forwarded a newsletter or clicked on any of its content. This information tells us about our newsletters' effectiveness and helps us ensure that we're delivering information that you find informative.
3. Functional.
These cookies let us operate certain functions of Wellio in line with the choices you make. These cookies mean that when you continue to use or come back to Wellio, we can provide you with our services as you have asked for them to be provided, such as knowing your username, remembering how you have customised our services, and reminding you of content you have recently viewed.
4. Third Party.
We may allow our business partners to use cookies on or outside the Wellio Service for the same purposes identified above, including collecting information about your online activities over time and across different websites. We may also use service providers acting on our behalf to use cookies for the purposes identified above.
H. Assist with fixing bugs and customer issues We use a variety of third-party services to help with bug detection, understand usage and monitor server performance. Such services include Hot Jar and Sentry and we may share certain information with these providers to assist in identifying and fixing bugs, customer support and improving our services. Except for the purposes provided in this Privacy Policy, Wellio will not disclose the information we collect from you to third parties without your express written permission, or where we believe, in good faith, that the law requires us to disclose the information.
I. Marketing and or potential investors
Students will always remain anonymous. To assist in running more effective marketing campaigns or raising capital, we may share aggregated information with marketing professionals or potential investors. We store session information on our website, such as the pages you viewed, for the purposes of re-marketing to potential customers. This information remains anonymous and we will never knowingly advertise to existing school users in this manner. We may market to potential clients if you have opted in to receive marketing, you can opt out at a later date. You have the right at any time to stop our company from contacting you for marketing purposes.
J. We may share data when legally required or to protect Wellio or others
Wellio may disclose personal information when required by law. We may also disclose information, in good faith, to protect Wellio from third party allegations or to protect the property or safety of our users.
Data and information security is a priority for Wellio and we have gone to great lengths to ensure our systems are secure and your information is protected. We take steps to protect the personal information we hold against loss, unauthorised access, use, modification or disclosure and against other misuses. This includes the use of services from respected cyber security professionals. When no longer required, personal information is destroyed in a secure manner or deleted.
4.1 Protecting your personal information
Your personal information on your Wellio account is protected by a password set by you for your privacy and security. Selecting and protecting a more secure password will help prevent the threat of unauthorised access.
On top of this, we also have in place a number of physical and technical security measures to help prevent the threat of an attack on our own services. Whenever you enter sensitive information on our website, we encrypt the transmission of that information using a secure socket layer (SSL). We endeavour to protect all your information in order to keep this private, however, no transmission of information through web services can be guaranteed to be 100% secure. Given this, we cannot guarantee the security of your information and any information you do provide Wellio which is done so at your own risk. In a case where your information may be compromised, you will be notified electronically.
Wellio provides customers with the choice to have their data hosted in a supported country of their choice.
Where the Australian Privacy Act applies to your Personal Information, we will only disclose it to recipients outside Australia where we have taken reasonable steps to ensure that the overseas recipient does not breach the Australian Privacy Principles in relation to your Personal Information - unless we have your consent, or an exception under the Australian Privacy Principles applies.
5.1 What personal information can I update and or view?
Wellio acknowledges an individual’s right to access and update their personal data. You can access and update much of this personal information in your account settings online. If you are after other personal information that is not accessible to you, you can contact us and we will look into this matter. There may be cases where we are unable to release certain personal information to you and in such cases, you will be given the reasons as to why. If you feel certain personal information is not correct and you are unable to update it, you can contact us and we will investigate such cases.
We may make changes to this Privacy Policy from time to time for any reason. In such cases where changes diminish the privacy rights of our users, we will notify users via email. Please ensure the email attached to your Wellio account is valid and you are able to receive email, otherwise, you will not receive information on such updates.
If you feel we have not been compliant with this Privacy Policy or are unhappy with the way we handle personal information, you can contact us at any time and we will respond within a reasonable period of time. Every complaint is taken seriously and we will do our best to resolve such issues. In cases where we are unable to do so, there are additional steps you can take if you wish to escalate the matter and we will advise you on this. Contact us at support@wellioeducation.com
We are committed to compliance with our obligations under the applicable Data Protection Laws in the EU and the UK.
8.1 Data Processor
Wellio will be a data processor for the purposes of applicable Data Protection Laws and the Customer will be the data controller.
This means Wellio only uses the personal information as instructed by the Customer and for the purpose of providing the Platform and our Services in accordance with the terms of our agreement with the Customer. We may also enter into a data processing agreement with Customers for the processing of student personal information.
8.2 Basis for processing
Depending on the context and the purpose of our processing activities we generally process personal information on the basis of consent, or the legitimate interests pursued by Wellio and our Customers in delivering learning resources for schools, institutions, teachers, parents and students. Our legitimate interests are further detailed in the section entitled "Using and Disclosing Personal Information" above.
8.3 Transfer of personal information
Personal information we collect may be transferred and stored on servers located in Australia, or other countries in which the privacy or data protection laws differ from those of the European Union and the UK. We ensure that suitable safeguards exist in relation to transfers of personal information to recipients outside of the EU and the UK, including by using:
8.4 Contact us
If you are a representative of an Customer and you have questions about the use of personal information in relation to the GDPR or the UK GDPR, you can contact us using the method set out above in this Privacy Policy.
If you are a student and you have questions about the use of your personal information in relation to the GDPR or the UK GDPR, you should ask your teachers first. You can also contact us using the method set out above in this Privacy Policy.
