Privacy Policy

The website operated by us is https://exploreimagineland.com/

Explore Imagineland (EIML) respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you.

This privacy notice is implementing the requirements of the General Data Protection Regulation (GDPR) (the law which protects and controls the use of personal data) and adopts the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth) (the Privacy Act). The APPs and GDPR govern the way in which we collect, use, disclose, store, secure and dispose of your Personal Information.

This Privacy Notice is provided in a layered format, so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.

This privacy notice is required to describe what data we may have access to of yours when using our services, including accessing https://exploreimagineland.com and what we then do with that data.

  1. IMPORTANT INFORMATION AND WHO WE ARE
  2. THE DATA WE COLLECT ABOUT YOU
  3. HOW IS YOUR PERSONAL DATA COLLECTED
  4. HOW WE USE YOUR PERSONAL DATA
  5. DISCLOSURES OF YOUR PERSONAL DATA
  6. INTERNATIONAL TRANSFERS
  7. DATA SECURITY
  8. DATA RETENTION
  9. YOUR LEGAL RIGHTS
  10. GLOSSARY
  1. IMPORTANT INFORMATION AND WHO WE ARE
    1. Purpose of this privacy notice

      This privacy notice aims to provide information on how EIML collects and processes your personal data, which we receive either directly from you (as an individual, parent, or carer) or from a family member who subscribes to our services.

      We permit children (defined as individuals under the age of 16) to use our services. However, registration must be completed with the consent of a parent or carer, and it must be managed by the parent or carer on behalf of the child.

      It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

      This privacy notice is required to describe what data we may have access to. We do not collect any personal details of the child. Any data provided is solely submitted by the parent or carer when they set up an account.

      Please take some time to read this important policy. Occasionally, we may issue additional processing notices, and we will ensure these are as clear and understandable as possible.

    2. Controller

      EIML is the sole data controller responsible for your personal data. While we may share your data with third parties as necessary to provide our services or as required by law, we remain fully responsible for how your personal data is handled.

      We have appointed a Data Protection Officer (DPO) who oversees questions related to this privacy notice. If you have any inquiries about this notice or requests to exercise your legal rights, please contact the DPO using the details provided below.

      As the data controller, we determine what data is collected and recorded, how we use it, and what happens to it. We are committed to ensuring the security and confidentiality of your personal data.

    3. Contact details

      Name or title of DPO: Data Protection officer: Explore Imagineland

      Email address: support@exploreimaineland.com

      You have the right to make a complaint at any time to the Information Commissioner's Office (ICO). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

      If you would like to contact the ICO, the details are as follows:

    4. Changes to the privacy notice and your duty to inform us of changes

      This version was last updated on 09 October 2024 and historic versions archived here can be obtained by contacting us.

      It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

      We may sometimes update this policy as we keep up to date with the law and guidance. The date shown above is the date this version was first issued.

    5. Third-party links

      Our website and applications may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website or service you visit.

      Sometimes you may be able to click links to other websites, when using ours. Whilst we will usually only link to sites and things we like and are comfortable with ourselves, we can't control how they use your data. Please do have a read of the privacy notice of any website or service you use, whether linked to by us or not.

  2. THE DATA WE COLLECT ABOUT YOU

    Personal data, or personal information, is any information that can identify an individual. This does not include anonymous data where the identity has been removed.

    This privacy notice addresses 'personal data and information,' which includes any data that could identify a person, even if identification requires combining it with other information.

    Personal data does not include data that cannot identify someone. For example, 'boy, age 14' could refer to many individuals.

    We collect, use, and store various types of personal data about you, organised into categories. These categories help us explain how we use each type of data later in this notice.

    1. Category of Personal Data
      1. Identity Data includes name and age (which we are required to check).
      2. Contact Data includes email address.
      3. Financial Data includes bank account and payment card details.
      4. Transaction Data includes details about payments to and from you and details of products and services you have purchased from us.
      5. Profile Data includes a username and password, feedback and survey
      6. Technical Data Data includes internet protocol (IP) address of your device, your login data, browser type and version, temporary or persistence unique
      7. Device Identifiers mobile operating system type, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website and/or application.
      8. Usage Data includes information about how you use our website and services including number of visits, length of consultations, interaction with the website pages (i.e. clicking page links). We do not use geolocation or tracking.
      9. Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
    2. If You Fail to Provide Personal Data

      When we are legally required or obligated by the terms of our contract to collect personal data, failure to provide this data may impact the functionality of our website for you. In such cases, we may need to cancel a product or service you have with us. We will notify you if this occurs.

  3. HOW IS YOUR PERSONAL DATA COLLECTED?
    1. We may collect your personal data in a number of ways, including:
      1. Directly from you (the parent or carer) unless it is unreasonable or impracticable to do so; or
      2. From another subscribing parent or carer who sets up an account on your behalf.
  4. HOW WE USE YOUR PERSONAL DATA

    We only use your data if we can and are allowed to by laws. We have set out the most common reasons we need to use your data below:

    1. Where we need to perform the contract we are about to enter into or have entered into with you.
    2. If we have agreed for you to access our services, then we need to know who you are. We only collect what we need, and will never ask for more than necessary.
    3. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
    4. Sometimes there are reasons that we have that mean we need to use your data. This could be to allow us to improve and make our services better. This is what we call a 'legitimate interest'. We will always weigh up your interests against ours, and will not use your data if we think it will impact you or take away any key rights.
    5. Where we need to comply with a legal or regulatory obligation.

    All service providers need to work within the law. Sometimes we may be required to do certain things or provide certain information.

    1. Purposes for which we will use your personal data

      We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so.

      The table below tells you what we do with your data, and which categories of data we use. It also sets out what law we rely on when doing these things. This is called the 'lawful basis'.

      Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

      2. Purpose/Activity Type of data Lawful basis
      To provide access to our goods and services and for updates about our goods and services and register you as a user. (a) Identity

      (b) Contact      		 (a) Performance of a contract with you

      (b) Necessary for our legitimate interests
      To process and deliver your order including:

      (a) Manage payments, fees and charges

      (b) Collect and recover money owed to us      		 (a) Identity

      (b) Contact

      (c) Financial

      (d) Transaction

      (e) Marketing and Communications      		 (a) Performance of a contract with you

      (b) Necessary for our legitimate interests (to recover debts due to us)
      To administer and manage accounts, responding to questions raised by subscribing schools, to contact the subscribing schools about any problems with their account or conduct on the website.
      		(a) Identity

      (b) Contact      		 (a) Performance of a contract with you

      (b) Necessary for our legitimate interests
      a. Notifying you about changes to our terms or privacy policy.
      To internally review and evaluate the quality of services (a) Identity

      (b) Contact      		 (a) Necessary for our legitimate interests (to improve and better the services provided)
      To manage our relationship with you which will include:
      (a) Notifying you about changes to our terms or privacy policy      		 (a) Identity

      (b) Contact

      (c) Profile      		 (a) Performance of a contract with you

      (b) Necessary to comply with a legal obligation
      To enable you complete a survey or provide feedback.

      We may use External Third Parties for the processing of data to assist in sending emails and other correspondence.      		 (a) Identity

      (b) Contact

      (c) Profile

      (d) Usage

      (e) Marketing and Communications      		 (a) Performance of a contract with you

      (b) Necessary for our legitimate interests (to study how customers use our
      products/services, to develop them and grow our business)
      To administer and protect our business and website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).

      We may use External Third Parties for the hosting of data, applications, website and technical support of the same.      		 (a) Identity

      (b) Contact

      (c) Technical      		 (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

      (b) Necessary to comply with a legal obligation
      To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you.

      We may use External Third Parties for the processing of data to assist in sending emails and other correspondence.      		 (a) Identity

      (b) Contact

      (c) Profile

      (d) Usage

      (e) Marketing and Communications

      (f) Technical

      		(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

      (b) Necessary to comply with a legal obligation
      To use data analytics to improve our website and applications, products/services, marketing, customer relationships and experiences and to ensure our website and applications display and operate properly on your devices. (a) Technical
      (b) Usage      		 Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website and applications updated and relevant, to develop our business and to inform our marketing strategy).
      To make suggestions and recommendations to you about services that may be of interest to you

      We may use External Third Parties for the processing of data to assist in sending emails and other correspondence.       		(a) Identity

      (b) Contact

      (c) Technical

      (d) Usage

      (e) Profile

      		Necessary for our legitimate interests (to develop our products/services and grow our business)
    2. Marketing

      We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

      As with most businesses, from time to time we may want to contact you about things we think you will be interested in. This is known as 'marketing'. We want to give you control about what you do and don't receive. We have described the different types of marketing below, and how you can ask us not to send you these. We never share your information with third parties to market to you.

    3. Pramatianal offers from us

      We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). You will receive marketing communications from us if you have requested information from us, or received services from us, or if you provided us with your details when signed up or registered in the application or website and, in each case, you have not opted out of receiving that marketing.

    4. Third-party marketing

      We will not shars, sell or trade your perinnal data with any third-party company for markating purposes

    5. Opting out

      You can ask us to stop sending you marketing messages at any time by contacting us at support@exploreimaineland.com

    6. Cookies

      You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information, please see our 'Cookie Policy' at https://exploreimagineland.com/cookies/ Sadly not the tasty kind, cookies are small files that are stored on your device each time you visit us. It helps us understand how you use our service, and helps us improve it. We have a 'cookie policy' that describes these in more detail and what happens if you don't agree to have them on your device.

    7. Change of purpose and other lawful disclosures

      We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at support@exploreimaineland.com

      If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, where this is required or permitted by law. EIML shall always identify a valid basis for disclosure of data including the following examples:

      1. Where data is required to be disclosed, for example, as compelled by the Children's Acts 1989 and 2004 for the protection of a child such disclosure shall be on the basis of:
        1. For the performance of a task carried out in the public interest or in the exercise of official authority and:
        2. It is necessary for the purposes of carrying out the obligations and exercising the specific rights of the controller or of the data subject in the field of social protection law in so far as it is authorized by Union or Member State law.
      2. Where data is required to be disclosed to a government body such as the Office of the Australian Information Commissioner to comply with APP's mandatory data breach notification scheme.

      In short, we will only use your data for what we have said we will. Sometimes we may need to make a slightly different use of the data, which we will do as long as we are pretty comfortable that it is similar to the reason we originally collected the data for, and the legal basis for doing so. We are always happy to discuss our reasoning for this.

      Sometimes we may be made by law to disclose your information without telling you. This is usually in very rare or serious cases. Before we do so, we will make sure there is a proper legal reason for us to be made to hand it over.

  5. DISCLOSURES OF YOUR PERSONAL DATA

    We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above

    1. Extermal Third Parties

      Third parties to whom we may choose to sati, transfer, or marge parts of our business or our assets. Alternatively, we may sosok to acquire ather businesses ar marge with them. If a change happens to aur business, then the new swners may ane your personal data in the same way as set out in this privacy netice.

      We require all third parties to respect the security of your personal data and to treat if in accordance with the law. We do not allow our third party service providers to senar personal data for their own purposes and only permit them to process your personal data for specifiell purposes and in accordance with our instructions.

      This section acknowledges that we sometimes need to share your personal data with third parties to help us carry aut certain things thor instance, making payments) These third parties aren't allowed to use your information for any other reason If we were to sell the business, then the new owners may have access to your data, but they will comply with this notice

  6. INTERNATIONAL TRANSFERS

    Our website is hosted in Australia and data is retained on our site by our host WP Engine.

    We do not anticipate transferring your personal data outside of Australia, but data (including personal data) may be transferred outside of Australia to the European Economic Area (EEA) as part of the hosting process for our website.

    We are committed to protecting your personal data from being accidentally lost, destroyed, used, accessed in an unauthorized way, altered, or disclosed.

    In particular:

    1. Personal data stored will only pertain to the parent or carer who has signed up, as we do not collect any data related to children, including their names or details.
    2. We have implemented appropriate security measures to safeguard your personal data. Explore Imagineland uses SSL encryption to securely transfer information between your device and our servers. Additionally, all data is encrypted 'at rest', meaning any data stored on our systems is encrypted.
    3. Access to your personal data is restricted to those employees, agents, contractors, and other third parties who have a business need to know. These parties will only process your personal data based on our instructions and are bound by a duty of confidentiality.

    We also have procedures in place to handle any suspected personal data breaches and will notify you, along with any applicable regulatory authorities, of any breaches where legally required.

    Please note that, although we work hard to protect your data, no internet transmission is entirely secure. We cannot guarantee the security of your data while it is being transmitted to our site. Any transmission is at your own risk. Once we receive your information, we will use the security measures mentioned above to prevent unauthorized access.

  7. DATA SECURITY

    We work hard to keep your personal data safe and protected from being lost, misused, or accessed without permission.

    In particular

    1. We use SSL encryption to securely transfer information between your device and our servers, and all stored data is also encrypted.
    2. Only authorized team members with a valid reason can access your data, and they are bound by confidentiality rules.
    3. We have procedures in place to handle any data breaches and will notify you if required.

    That said, the internet isn’t 100% secure. While we do our best to protect your data, we can’t guarantee total safety during online transmission. Please be cautious and only share information when necessary.

  8. DATA RETENTION
    1. How long will you use my personal data for?

      We retain the personal data we collect for as long as it is necessary to provide access to the website and manage your account. Since we do not collect data related to children, the information retained pertains only to the parent or carer who has signed up.

      To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

      In some circumstances you can ask us to delete your data. Furthermore, we shall be required to delete your data following the instructions of a subscribing school to do so.

      In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

      We only hold on to data for as long as we really think we need to. For example, so we can keep track of your account and so you can continue to use the services, we will keep hold of your data for as long as you have an active account.

  9. YOUR LEGAL RIGHTS

    Under certain circumstances, you have rights under data protection laws in relation to your personal data. We have summarised below key legal rights that you have. It is your data, so it is important you understand what control you have over it. We think these are quite straightforward to understand, but please contact us if you have any questions or anything is not clear.

    1. You have the right to:
      1. Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
      2. Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
      3. Request arasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
      4. Furthermore, we shall be required to delete your data following the instructions of a subscribing school to do so.
      5. Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
      6. Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
      7. Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
      8. Withdraw content at any Time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent. Further information on these rights can be found on the ICO website. https://ico.org.uk

      If you wish to exercise any of the rights set out above, please contact our DPO, whose details can be found at the top of this notice (section 1).

    2. No fee usually required

      You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

    3. What we may need from you

      We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

    4. Time limit to respond

      We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

  10. GLOSSARY
    LAWFUL RASIS
    • Lagitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting support@exploreimaineland.com
    • Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract. With regards to EIML, this is the terms you agree to upon subscribing to our services.
    • Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
    THIRD PARTIES
    • External Third Parties
      • Service providers acting as processors who provide IT and system administration services.
      • Marketing service providers (including email list providers) who act as processors for our engagement correspondence and marketing with users.
Date of Last Revision: 05 December 2024
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