SST Privacy Policy

This Privacy Policy sets out the basis upon which Social Skills Training Institute Pty Ltd ACN 600 644 326 and its related entities (“we”, “us” or “our”) collect, store, use and disclose personal data.

This Privacy Policy has been created in accordance with the privacy policy requirements of the jurisdictions that we operate in. These are:

  • Australia;
  • Canada;
  • Hong Kong;
  • Ireland;
  • New Zealand;
  • Singapore;
  • UK; and
  • USA.

Please note, this website contains links to other websites which are provided for your convenience.

We are only responsible for the privacy practices and security of this site. We recommend that you check the privacy and security policies and procedures of each and every other website that you visit. 

Definitions

Within this Privacy Policy:

Users refers to children, clinical or educational professionals (Professionals) and parents or guardians (Parents) who access the program.

Personal data means any data about a User who can be identified either from that data, or from that data and other information to which we have or are likely to have access.

What information do we collect? 

In order to provide our services to you, we may collect personal information about you from:

  • our website;
  • the SAS platform;
  • telephone conversations;
  • e-mails;
  • survey monkey forms;
  • zoom registration questions; and
  • written and verbal communications.

We may, by way of example, keep a record of your name, date of birth, address, email address, telephone number, health information and employment details.

We may supplement the information that you provide with other information that we receive from other Users.

Providing personal information to us is optional. However, if you chose not to provide personal information to us, we may not be able to provide our services to you.

Purposes of collection

We have developed this software to assist children to develop greater social-emotional awareness. We collect personal information for the following purposes:

  • first, to assist children to develop social-emotional awareness;
  • second, to provide us with:
    • an accurate picture of a child's emotional skills and journey; and
    • enough information to guide professional monitoring and decisions related to the child's specific needs;
  • third, to allow parents and teachers to access a child's information to understand how they can help their child develop emotional awareness; and
  • fourth, to collect the information to be used in academic research.

The lawful basis for the first three purposes is to allow us to perform our contract with you by providing the platform.

We also process this information with your consent.

Consent 

The legal basis for some of the things we do with your personal data is consent.

When we ask for your consent, we will give you all the information you need to make an informed decision beforehand.

You are always allowed to withhold, or withdraw your consent at any time.

Some of the things we do with your personal data requires your consent and so if you withdraw it, we will have to stop doing those things.

These things include processing data about your or your child’s participation in the SAS Programs, your health or the health of your child on the platform. This means if you do decide to withdraw your consent, we will not be able to provide you with the platform.

If you are consenting on behalf of your child, we will ask you to confirm that you have the authority to consent on their behalf either because:

  • you are their parent/guardian; or
  • their parent/guardian has given you the authority to consent for their child.

How will we use your personal data? 

The personal data we collect will only be used for the purpose for which it was collected or a directly related secondary purpose.

We will ask you for your consent before we use your personal data for a secondary purpose that is unrelated to the purpose we collected it for.

We will use your personal data to provide our platform and services to you, for example to:

  • set up Users with an account;
  • provide our platform to Users, including: 
  • allow children to use the interactive gaming services;
  • allow parents to access and download PDFs of their child’s information; and
  • allow clinical and educational professionals to access child’s data (that has been shared with them) and the training modules and online programs;
  • allow Users to purchase the SAS resources;
  • monitor a child’s progress whilst using the software;
  • allow Users to apply for training courses; and
  • co-ordinate and communicate with the adult Users supporting child Users;

We may also use your personal data for the secondary purposes of academic research.

Disclosure of your personal data

The personal data we collect will only be disclosed for the purpose for which it was collected or a directly related secondary purpose.

We will ask you for your consent before we disclose your personal data for a secondary purpose that is unrelated to the purpose we collected it for.

In order to provide our services to you, we need to disclose some of your personal data to third parties. These include, for example, ICT service providers. They are bound by confidentiality obligations and will only process your personal information according to our instructions.

We also transfer personal data to academic research institutions. This personal data has identifiers removed and is subject to confidentiality and ethics oversight by the institutions in question.

Given that the platform operates on a collaborative and cooperative model, personal data will be disclosed within the platform to other Users. This includes allowing Facilitators and Parents to access information about their children. 

Security and storage of information 

We take the security and storage of your personal data seriously.

To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures, for example:

  • encryption of data at rest using up-to-date encryption standards;
  • encryption of data in transit using up-to-date encryption standards;
  • secure key storage;
  • access controls including multifactor authentication to access the cloud storage platform; and
  • active system logging.

Direct marketing 

If you consent, we may use your personal data to notify you of services, such as training courses, from time to time. You may opt out of receiving any publications, newsletters or marketing products at any time.

We do not sell, licence or distribute your personal data to any other organisation for the purpose of direct marketing.

Cross border disclosure

Our platform operates in a number of different countries.

We are based in Australia and your data is stored in Australia.

If you are outside of Australia, we have put in place appropriate safeguards to ensure that your data is protected. These are outlined in the standard contractual clauses and EULA.

If there is a problem with your personal data, we will actively assist your local data protection authority and we will also assist to resolve the problem with the Australian data protection authorities when necessary.

We take all reasonable steps to ensure that any overseas recipient who receives personal information from us does not breach any privacy laws that are in place in the jurisdictions that we operate in.

Retention of personal data

We will only retain your personal data for as long as is necessary to fulfil the purposes for which we collected it, or as required or permitted by any applicable laws.

Your right to access your personal information 

You have the right to access your personal data.

You also have the right to access information about how we process your personal data.

We also welcome any requests you have for information about our privacy and data protection policies.

If you have access to the online game environment, you will be able to access your information by downloading a PDF through the Progress Dashboard of Digital Headquarters.

Otherwise, please contact us at privacy@sst-institute.net to request access to your personal information.

We will assess any requests you make and respond as quickly as we can – in most cases this will be within 30 days. Access may be denied if one of the exceptions set out in the privacy laws in your applicable jurisdiction apply. 

Your right to correct your information 

The personal data we collect is generally provided by Users. We generally rely on the data provided by you or your child to be up to date and current.

In order to ensure that your personal data is current, complete and accurate, please update us if there are any changes to your personal data by contacting privacy@sst-institute.net.

Your right to erasure

You have a right to request that we securely destroy your personal information at any time.

Complaints

You may contact our data protection officer if you have any enquires, feedback or complaints about our personal data protection policies and procedures, or if you wish to make any request.

You may also contact your local data protection authority if you have any enquires or complaints regarding our privacy procedures. The relevant authoritative bodies for the jurisdictions which we generally operate in are:

Changes to this privacy policy 

From time to time we may change our security and privacy policies. We will notify you of any changes we make.  

Additional User rights under the GDPR

While we are based in Australia, we have an EU representative in Germany. They can be contacted info@gdpr.storageandfitch.de.

While we are based in Australia, we have a UK representative in England. They can be contacted at info@gdprauditing.com.

Alongside the right of access, rectification and erasure discussed above, the GDPR creates additional rights for Users located in the EU in relation to the processing of their personal information. These rights are as follows:

Your right to restrict processing

  • You have a right to request that we restrict the processing of your personal data if you believe one of the following circumstances apply:
  • you believe your personal information that we are storing is inaccurate;
  • you believe your data has been unlawfully processed;
  • you need us to continue to store your data to establish, exercise or defend a legal claim; or
  • you have objected to us processing your data under Article 21(1) of the GDPR and we are considering whether that is a legitimate claim.

Right to data portability

  • You have the right to obtain and reuse your own personal data for your own purposes across different services.

Right to object

  • You have the right to object to the processing of your personal data at any time. If you would like to stop or prevent us from processing your personal data, you can contact us at privacy@sst-institute.net.