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Privacy Policy

Last updated 30 April 2025

This privacy policy applies specifically to Education Services Australia's service, ELLA.

Education Services Australia Limited (ABN 18 007 342 421), on behalf of its service ELLA (ESA, we, us or our), is committed to protecting the privacy of Personal Information. This Privacy Policy explains how ESA collects and uses your Personal Information for ELLA and the rights and options you have in this respect. In doing so, ESA complies with its obligations to protect the privacy of Personal Information under the Australian Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles (APPs).

ESA delivers a number of products and services in relation to education systems and sectors (related entities). This Privacy Policy applies to the use of your Personal Information by ELLA. Those related entities may also have their own privacy policies which set out additional detail or differences in their privacy practices. A reference in this Privacy Policy to ESA, we, us or our is also a reference to ELLA.

The general privacy policy for ESA is available here and the privacy policy of the Australian Government Department of Education, who also collect and handle your Personal Information as a result of the ELLA program is available here.

Note: if you are the parent/guardian of a child at a preschool or school that participates in ELLA, you will have been given the option to opt out of your child participating in ELLA.

For further details, please refer to the parent/guardian brochure provided to you by your preschool/school.

1. What is Personal Information? 

"Personal Information" is information or an opinion, whether true or not, and whether recorded in a material form or not, about an identified individual or an individual who is reasonably identifiable.

2. Handling of Personal Information

Note: if you are an educator at a preschool or a teacher at a school that is taking part in ELLA, you and your preschool or school have obligations to comply with relevant privacy requirements with respect to the handling of Personal Information. Your privacy obligations are explained in the ELLA program support material made available to your preschool or school.

3. What Personal Information do we collect when you use ELLA?

The Personal Information that we may collect when you use/participate in ELLA is:

  1. for preschool educators and school teachers:
    • given name and family name;
    • email address;
    • telephone number;
    • place of employment;
    • work address;
    • information from social media accounts and profiles (if you engage with us in that way); and
    • payment details, such as your credit card or bank account details;
  2. for preschool children and school students:
    • personal identifier eg given name, nickname, photo of a student, object or a pre-set image; and
    • child/student usage data.

We will endeavour to collect only the minimum amount of Personal Information necessary to administer the ELLA program.

4. How do we collect your Personal Information?

We collect Personal Information about you directly from you or from your authorised representative. The ways in which we collect Personal Information from you or your authorised representative are when:

  1. for a preschool educator or school teacher, you sign up a preschool or school to participate in ELLA, are a contact person for your preschool or school for ELLA or participate in the ELLA online community of practice; or
  2. for a child or student, your preschool educator or teacher registers you to use ELLA.

If you are the parent/guardian of a child or student, and you have provided your prior written consent to the educator or teacher of your child or student, we may collect images of your child or student which are posted to the ELLA Community of Practice by such educator or teacher.

5. Third party Personal Information provided to us

If you provide Personal Information to us about someone else (such as one of your colleagues or an image of a child or student posted to the ELLA Online Community of Practice) you must ensure that you are entitled to disclose that Personal Information to us and that, without us taking any further steps, we may collect, use and disclose that Personal Information as described in this privacy policy. In particular, you must ensure that the individual concerned is aware of and acknowledges this privacy policy and our collection statement.

6. Remaining anonymous or using a pseudonym

Where it is not impractical or unlawful, you may interact with us without identifying yourself or by using a pseudonym. However, if you do so, we may not be able to provide you with the most relevant information or provide you with access to emails or webinars.

Whilst we offer the option for a photo to be taken of a child or student when their educator or teacher registers them to use ELLA so that the child or student can identify their login on ELLA, a child or student is not obliged to have a photo of themselves in order to use ELLA. An educator or teacher can register a child or student to use ELLA by taking a photo of an object or using a pre-set generic image.

7. Collection through the ELLA website and mobile applications

Personal Information may be collected by us and by our third party service providers who assist us in operating our website at ella.edu.au (the Website).

We may use various technological methods from time to time to track the visiting patterns of individuals accessing our Website, including but not limited to the methods set out in this paragraph 7.

Click Stream Data

When you read, browse or download information from our Website, we or our internet service provider may also collect information such as the date, time and duration of a visit, the pages accessed, the IP address of your computer, and any information downloaded. This information may be used for purposes including statistical, reporting and website administration, maintenance and improvement purposes.

Cookies

Our Website may use 'cookies' from time to time. Cookies are small text files that are transferred to a user's computer hard drive by a website for the purpose of storing information about a user's identity, browser type or website visiting patterns. Cookies may be used on our Website to monitor web traffic, for example the time of visit, pages visited and some system information about the type of computer being used. We use this information to enhance the content and services offered on our Website.

Cookies are sometimes also used to collect information about what pages you visit and the type of software you are using. If you access our Website or click-through to our Website from a link in an email we send you, a cookie may be downloaded onto your computer's hard drive.

Cookies may also be used for other purposes on our Website.

Google Analytics 

We use Google Analytics to help analyse how you use our Website. Google Analytics generates statistical and other information about website use by means of cookies, which are stored on users' computers. The information generated is used to create reports about the use of our Website. Google will store this information.

If you do not want your Website visit data reported by Google Analytics, you can install the Google Analytics opt-out browser add-on. For more details on installing and uninstalling the add-on, please visit the Google Analytics opt-out page at https://tools.google.com/dlpage/gaoptout.

Apple App Store Privacy Information Requirements

Apple has introduced a requirement for the developers of new and existing apps in its App Store to provide information about each app’s privacy practices, including the privacy practices of third party providers whose code is integrated into an app. This information appears on each app’s product page and allows users to better understand how their privacy is protected and their information is used, prior to making a decision to download an app.

Developers are required to provide yes or no answers to a series of questions provided by Apple which relate to the operation of the app. ESA does not share your personal information in responding to these questions.

8. Use of your Personal Information

We use the Personal Information we collect about you for ELLA's functions and activities, in order to operate ELLA efficiently, and to market ELLA's products and services. We may use your Personal Information for the following purposes:

  • to identify you and communicate with you;
  • to facilitate and support the functions and activities of our internal business units and related entities;
  • to collect and process payments;
  • operating ELLA, including applications, registrations, helpdesk queries, communication and webinars;
  • communicating with preschool/school contacts via bulk emails;
  • producing child/student usage data (time spent on certain activities within the ELLA apps) for educational reporting and in aggregate with other children/students for analytics output. Personal Information is removed from the child/student usage data but there is the possibility that you may be re-identified;
  • to promote ELLA products and services;
  • to provide you with information we believe may be of interest to you or that you may be interested in receiving, including advertising material, regarding us, our clients, and our business partners;
  • to manage and administer and account you may hold with us;
  • to help us research the needs of individuals who use ELLA's services to enable us to market our products and services with a better understanding of your needs and the needs of those individuals generally;
  • to protect you and us from fraud;
  • to investigate, review mitigate risks associated with, and inform you of a data or other security breach involving your Personal Information;
  • compliance with our legal obligations (such as record-keeping obligations);
  • analysing and improving our services and communications to you; • to conduct research for the purposes of improving existing ELLA products and services or creating new products or services;
  • complying with our legal and regulatory obligations and requests anywhere in the world, including reporting to and/or being audited by national and international regulatory bodies;
  • complying with court orders and/or to defend our legal rights; and
  • for any purpose related and/or ancillary to any of the above or any other purpose for which your Personal Information was provided to us.

We will not use your Personal Information for taking any automated decisions affecting you or creating profiles other than described above.

We may aggregate personal information for reporting, statistical and analysis purposes, and for business, product and service improvement purposes. This allows us to better inform ourselves and anticipate our customers' preferences and requirements, and to monitor and improve the effectiveness of our business, products and services. We may also de-identify information for inclusion in such aggregated databases or reports.

We reserve the right at all times to monitor, review, retain, and/or disclose any information as necessary to satisfy any applicable law, but we have no obligation to monitor the use of the Website or to retain the content of any user session.

You consent to us using your Personal Information in the above ways and as set out in this Privacy Policy.

We may otherwise collect, use or disclose your Personal Information where the collection, use or disclosure is:

(a) in accordance with this Privacy Policy or any agreement you enter into with us, or

(b) required or authorised by law, including without limitation the Australian Privacy Principles under the Privacy Act 1988 (Cth).

9. When do we disclose your Personal Information?

We may disclose, or provide access to, your Personal Information to third parties in connection with the purposes described in paragraph 8. Depending on the circumstances and the nature of your engagement with us, we may disclose your Personal Information to our related entities, to third parties that provide products and services to us or through us, or to other third parties.

In particular, we may disclose your Personal Information to the Australian Government Department of Education who funds the ELLA program, for the purposes described in paragraph 8.

We may also disclose your Personal Information to:

  1. your nominated representatives;
  2. ESA's related entities, internal divisions, business units or departments;
  3. other organisations or individuals who assist us in providing products and services to you;
  4. professional service providers and advisors who perform functions on our behalf, such as lawyers;
  5. representatives, agents or contractors who are appointed by us in the ordinary operation of our business to assist us in providing goods or services or administering our business (such as for data storage or processing, printing, mailing, marketing, planning and product or service development); and
  6. Government, regulatory authorities and other organisations as required or authorised by law.

We may also disclose your Personal Information to our Website host or software application providers in certain limited circumstances, for example when our Website experiences a technical problem or to ensure that it operates in an effective and secure manner.

10. Interstate and overseas disclosures

Some of your Personal Information may be disclosed, transferred, stored, processed or used overseas by us, or by third party service providers. This may happen if:

  1. our offices or related entities are overseas
  2. we outsource certain activities overseas
  3. transactions, information, services or products have an overseas connection, or
  4. our computer systems including IT servers are located overseas.

You consent to the collection, use, storage, and processing of your Personal Information outside of Australia as set out in this Privacy Policy.

In particular, your Personal Information may be disclosed to third parties in the US, EEA and UK, and such other countries in which those parties or their, or our, computer systems may be located from time to time, where it may be used for the purposes described in this Privacy Policy. Where such parties are located overseas, you may have rights to enforce such parties' compliance with applicable data protection laws, but you might not have recourse against those parties under the Australian Privacy Act in relation to how those parties treat your personal information.

11. Other uses and disclosures

We may collect, use and disclose your Personal Information for other purposes not listed in this Privacy Policy. If we do so, we will make it known to you at the time we collect or use your Personal Information.

12. Marketing

You consent to us using your Personal Information for sending you information, including promotional material and surveys about us or our products and services, as well as the products and services of our related entities and third parties, now and in the future. You also consent to us sending you such information by means of direct mail, email.

If you do not want to receive marketing information from us, you can unsubscribe in any of the following ways:

  1. clicking on the 'Unsubscribe' or subscription preferences link in a direct marketing email that you have received from us; or
  2. contacting us using the contact details specified in paragraph 16.

13. Accessing, correcting and deleting Personal Information

ESA endeavours to ensure that the Personal Information that it holds is accurate, up-to-date, complete and relevant. If you want to know what, if any, Personal Information ESA hold about you, or wish to correct any Personal Information ESA may hold about you, you may access this information by contacting ESA using the contact details specified in paragraph 16.

ESA may allow access to, make your requested changes to or delete your personal information unless otherwise required or permitted by law. ESA will notify you of the basis for any denial of access to your personal information.

When personal information is no longer required, ESA takes reasonable steps to de-identify, securely destroy or delete such personal information.

14. Security of your personal information

ESA takes reasonable steps to protect the personal information that it holds against misuse, interference, loss, unauthorised access, modification or disclosure by utilising up-to-date electronic and physical security controls that comply with relevant industry standards and guidelines.

If you do not wish to use the internet to transmit personal information you can mail or telephone ESA using the contact details specified in paragraph 16.

You should also note that if you link to a non-ELLA web page, a different privacy and security statement is likely to apply.  

15. How we deal with complaints about Privacy

If you feel that we have not respected your privacy or that we have conducted ourselves inconsistently with this Privacy Policy, please contact our Privacy Officer in any of the ways specified in paragraph 16 and advise us as soon as possible. We will investigate your queries and privacy complaints within a reasonable period of time depending on the complexity of the complaint.

It would assist us to respond to your complaint promptly if it is made in writing. Please detail information relevant to your complaint.

We will notify you of the outcome of our investigation.

16. What to do if you have a question, problem or complaint, or want to contact us about our use of your Personal Information or this Privacy Policy

If you have any questions, comments, concerns or complaints about our privacy practices, you can contact us by:

  • Telephone: +61 3 9207 9600;
  • Post: Post Office Box 177, Carlton South, Victoria, Australia 3053; or
  • Email: [email protected]

17. Changes to this Privacy Policy

We may make changes to this privacy policy from time to time to take account of new laws and technology or changes to our operation and practices. Therefore, we recommend that you regularly check this privacy policy. You may obtain a paper copy of this privacy policy by contacting ESA via the contact details provided above.

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