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This document sets out the privacy policy of Frontline Communications Pty. Limited. ABN 47 079 881 842 (referred to in this privacy policy as ‘we’, ‘us’, or ‘our’). For the purposes of applicable data protection law, (in particular, the General Data Protection Regulation (EU) 2016/679 (the “GDPR”) and the UK Data Protection Act 2018), and the California Consumer Privacy Act (the “CCPA”) your data will be controlled by us where we collect and use your personal data for our own business purposes, including website operation, account administration, subscription billing, marketing, support and customer communications.
This privacy policy applies whenever we collect your personal information and/or personal data (your personal data). This includes between you, the visitor to this website (whether directly as our customer or as personnel of our customer), and us, the owner and provider of this website, and where we are directed by a third party to process your personal data. This privacy policy applies to our use of any and all data collected by us or provided by you in relation to your use of the website, your account, any subscription, any payment or billing process, and the provision of our services to you.
We take our privacy obligations seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal data in connection with your use of our website and services. It also explains your rights in relation to your personal data and how to contact us or a relevant regulator in the event you have a complaint.
This privacy policy applies when you access or use our website, create an account, purchase or manage a subscription, make a payment, contact us, receive support, interact with our content or communications, or otherwise use our services.
This privacy policy also applies where we collect personal information from or about you in connection with our business operations, including account administration, subscription billing, customer support, marketing, analytics, service improvement and legal compliance.
We generally act as a controller of personal information where we collect and use personal information for our own business purposes, including operating our website, managing accounts, processing subscriptions and payments, providing support, sending service communications, undertaking marketing and complying with our legal obligations.
Where we process personal information on behalf of a customer or another organisation, including where that organisation provides personal information to us for use in connection with our services, we may act as a processor or service provider for that organisation.
Where we act as a processor or service provider, the relevant customer or organisation is responsible for ensuring that it has the authority, notices, consents and lawful basis required to provide the personal information to us and to instruct us to process it.
Where our services allow customers or users to upload, submit, store, send or otherwise process information through the platform, that information may include personal information about the customer, its personnel, its clients, end users or other third parties.
Customer data may include information contained in forms, emails, support requests, business records, account records, service communications and other materials submitted to or processed through the services.
We process customer data for the purpose of providing, maintaining, supporting, securing and improving the services, administering accounts and subscriptions, responding to support requests and complying with applicable laws.
You must ensure that any personal information you provide to us or make available through the services has been collected and disclosed lawfully and that all required notices, consents, authorisations and permissions have been obtained.
The information provided to us or processed through our services may include sensitive information, depending on how the services are used and the information submitted by customers or users.
You must not provide sensitive information to us unless it is necessary for the relevant purpose and you have the authority, consent or other lawful basis required to provide that information to us.
Where we collect or process sensitive information, we will handle it in accordance with this privacy policy and applicable privacy laws.
The personal data we collect for providing services to registered users will include the following:
The personal data we collect for providing services to unregistered users will include the following:
The personal data we collect for providing services to users may include the following:
The personal data we may collect for the purposes of subscription-related transactions includes the following:
The personal data we may collect for our own marketing purposes may include:
We endeavour to ensure that information we collect is complete, accurate, accessible and not subject to unauthorised access.
We may collect personal data either directly from you, or from third parties, including where you:
We may also collect personal data from you when you use or access our website or our social media pages. This may be done through use of web analytics tools, ‘cookies’ or other similar tracking technologies that allow us to track and analyse your website and services usage. For more information, please see our Cookie Policy.
If you are providing personal and/or sensitive information on behalf of someone else, you must have the consent of that person to provide their personal and/or sensitive information to us to be collected, used, and disclosed in accordance with this privacy policy.
If you are providing personal information on behalf of someone under the age of 18 (Minor), you must be that Minor’s parent or legal guardian, or have express consent from that Minor’s parent or legal guardian, and you must provide consent for the Minor’s personal information to be collected, used and disclosed in accordance with this privacy policy.
A form is provided on the website at https://clevergroups.com/privacy to submit your signed consent authority. If this consent is not provided prior to using our services, Clever Groups may withdraw access to the service if subsequent requests for consent are not fulfilled.
We do not knowingly collect information from children under the age of 18. If you have not reached the age limit, do not use the services and do not provide us with your personal information. If you are a parent or legal guardian of a Minor who has provided Clever Groups with personal information, please contact us at [email protected] to exercise your rights of access, correction, cancellation, and/or opposition.
We may use cookies, analytics tools and similar technologies to operate our website and services, understand how they are used, improve user experience, monitor performance, support security and assist with marketing.
These technologies may collect information such as device information, browser information, IP address, pages viewed, time spent on pages, interactions with our website or services and similar usage information.
For more information about how cookies are used, please see our Cookie Policy.
We collect and use personal data for the following purposes:
We may use your personal information to send you marketing, promotional messages, product updates, service updates or other information that may be of interest to you, where permitted by law.
You can opt out of receiving marketing communications from us at any time by using the unsubscribe facility provided in the relevant message or by contacting us.
Even if you opt out of marketing communications, we may still send you non-marketing communications, including account, subscription, billing, payment, security, support or legal notices.
We may use artificial intelligence tools or related technologies as part of providing, supporting, securing, analysing or improving our services.
Unless we expressly tell you otherwise or obtain any required consent, we do not use customer-uploaded personal information to train, fine-tune or improve third-party artificial intelligence models.
Where artificial intelligence tools or third-party providers are used to support the services, personal information may be processed by those tools or providers for the purpose of providing the relevant functionality, support, security or service operation.
We may disclose personal information to service providers, subprocessors, contractors and professional advisers who help us operate our website, provide our services, manage accounts, process subscriptions and payments, provide customer support, host and monitor systems, send communications, conduct analytics, manage security and operate our business.
These service providers may process personal information on our behalf or as independent controllers, depending on the nature of the service they provide.
We take reasonable steps to work with service providers who can handle personal information consistently with our privacy and security obligations.
We may update our service providers and subprocessors from time to time, including where we change hosting, billing, payment, analytics, support, communications or other operational providers.
We may share your personal data in certain circumstances, as follows:
Services Where Data is Hosted
| Services | Provider | Where Data is Hosted |
|---|---|---|
| Web Hosting | Hostgator | USA |
| Web Hosting Backup | Backblaze | UK, USA, Canada and India |
| CRM, Mail, Customer Support Systems and Accounting | Zoho | United States of America, the European Economic Area (EEA), Australia and other countries where Zoho operates |
| Google Single Sign On | USA | |
| Cookie Consent and Consent Management Platform | CookieBot | Ireland, USA, Slovenia |
| Blog and Help Center | BlogHandy | USA |
| Web Page Analytics | FathomAnalytics | USA |
| Web Platform Monitoring | Sentry.io | USA |
| eCommerce Platform | LemonSqueezy | US, UK and Various |
| Subscription Billing and Payment Processing (Merchant of Record) | LemonSqueezy | US, UK and various other countries where LemonSqueezy or its service providers operate |
| Transactional Email (account, billing and security notifications) | ZeptoMail (Zoho) | India, United States of America and other countries where Zoho operates |
| Email Marketing and Newsletter Communications | Mailchimp (Intuit) | USA |
LemonSqueezy’s data protection role: As our Merchant of Record, LemonSqueezy acts in a dual capacity under the GDPR. For data it collects directly from customers (billing address, payment details, AML and fraud checks, and tax compliance information), LemonSqueezy acts as an independent Data Controller. For data we transmit to LemonSqueezy to facilitate a transaction on our behalf (such as customer email address, name, internal user ID, account handle and plan variant), LemonSqueezy acts as a Data Processor. Acceptance of LemonSqueezy’s Terms of Service constitutes a binding Data Processing Agreement (DPA). For international data transfers to the US, LemonSqueezy relies on Standard Contractual Clauses (SCCs) and participates in the Data Privacy Framework (DPF) where applicable.
We take reasonable steps to ensure your personal data is secure and protected from misuse or unauthorised access. Our information technology systems are password-protected, and we use a range of administrative and technical measures to protect these systems. However, we cannot guarantee the security of your personal data.
When we collect and process personal information, and while we retain this information, we will protect it within commercially acceptable means to prevent loss and theft, as well as unauthorised access, disclosure, copying, use, or modification. Although we will do our best to protect the personal information you provide to us, we advise that no method of electronic transmission or storage is 100% secure, and no one can guarantee absolute data security.
You are responsible for selecting any password and its overall security strength, ensuring the security of your own information within the bounds of our services, account features and subscription services. For example, ensure that any passwords associated with accessing your personal information, subscriptions, payment information and accounts are secure and confidential.
Our website may contain links to other websites. Those links are provided for convenience and may not remain current or be maintained. We are not responsible for the privacy practices of those linked websites and we suggest you review the privacy policies of those websites before using them.
You have various rights with respect to our use of your personal data:
You may, at any time, exercise any of the above rights, by contacting our email address provided below.
Although you have these rights, please understand that these rights are not absolute. There may be instances where we may not be able to comply with your request or objection based on our legitimate interests, or in accordance with the legal restrictions governing these rights. If your information needs to be updated, you can request that certain changes be made by logging into your Account or subscription account, where available. For any other requests, you can also contact us via email at [email protected].
We try to respond to all legitimate requests within one month and will contact you if we need additional information from you in order to honour your request. Occasionally it may take us longer than a month, taking into account the complexity and number of requests we receive.
We retain personal information for as long as reasonably necessary for the purposes for which it was collected, including to provide our services, manage accounts and subscriptions, process billing and payments, provide support, comply with legal and accounting obligations, resolve disputes, prevent fraud and enforce our agreements.
Where personal information is no longer required, we will take reasonable steps to delete, destroy or de-identify it, subject to any legal, accounting, billing, backup, security or dispute resolution requirements.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, billing, payment, fraud prevention, dispute resolution, or reporting requirements. We will securely destroy or de-identify your personal data in accordance with applicable laws and regulations.
If you would like further information about our specific retention periods for your personal data, please contact us using our email address provided below.
We keep your personal information only for as long as we need to. This time period may depend on what we are using your information for, in accordance with this privacy policy. For example, if you have provided us with personal information as part of creating or managing an account or subscription with us, we may retain this information for the duration your account exists on our system and for a reasonable period afterwards where required for billing, tax, accounting, dispute resolution, security or legal purposes. If your personal information is no longer required for this purpose, we will delete it or make it anonymous by removing all details that identify you.
If necessary, we may retain your personal information for our compliance with a legal, accounting, billing, payment, fraud prevention, dispute resolution, or reporting obligation or for archiving purposes in the public interest, scientific, or historical research purposes, or statistical purposes.
Our current website’s database stores the last access time of your account. If we identify accounts that have been inactive for a significant period, such as six years, we may contact you to notify you of our intention to delete your data in accordance with Article 13(2) of the GDPR. You will be given a specified period (e.g., 30 days) to respond before we proceed with deleting your data if we do not hear from you.
To provide our services, operate subscriptions, process payments, manage accounts and use our service providers, we may transfer the personal data we collect to countries outside of the UK or EEA which do not provide the same level of data protection as the country in which you reside and are not recognised by the European Commission as providing an adequate level of data protection.
When we do this, we will make sure that it is protected to the same extent as in the EEA and UK as we will put in place appropriate safeguards to protect your personal data, which may include standard contractual clauses.
Where the disclosure of your personal information is solely subject to Australian privacy laws, you acknowledge that some third parties, including hosting, billing, payment, analytics, support and other service providers, may not be regulated by the Privacy Act and the Australian Privacy Principles in the Privacy Act. You acknowledge that if any such third party engages in any act or practice that contravenes the Australian Privacy Principles, it would not be accountable under the Privacy Act, and you will not be able to seek redress under the Privacy Act.
Where you purchase, renew, manage or pay for a subscription, we may disclose your personal information, including your name, email address, billing address, subscription details and transaction details, to our third-party subscription billing and payment processing provider or merchant of record, including LemonSqueezy. LemonSqueezy is based in the United States and may process or store your personal information in the United States and other countries in accordance with its own privacy terms.
We take reasonable steps to work with third-party billing and payment providers who can handle personal information consistently with applicable privacy and security obligations. However, overseas recipients may not be subject to the Australian Privacy Act or the Australian Privacy Principles, and privacy protections in those countries may differ from those that apply in Australia.
For more information, please contact us at our email address provided below.
Some personal information we collect is stored on servers located in the USA and, for the most part, we do not disclose or transfer personal information overseas, except as described in this privacy policy, including where we use service providers for hosting, backups, analytics, account management, customer support, subscription billing and payment processing.
However, the cloud service providers we engage to provide us USA-based servers may operate overseas disaster recovery sites or have personnel overseas who may access the personal information we hold to assist us in managing our servers. Our current backup provider, Backblaze, is based in the USA, and retains backup data on their service in physical storage located in the USA.
We also may use analytics to track web traffic information, which is operated by Fathom Analytics and stores information across multiple countries. We may also use third-party providers to process account, subscription, billing and payment information, and those providers may process or store personal information in the locations described in this privacy policy or their own privacy terms.
Additionally, we collect and store personal information in our financial system (Zoho Books), feedback from the website or support provided to us (which may include personal information) in Zoho Desk, and for transactional, subscription billing, account administration, support, and/or marketing purposes in Zoho CRM. Zoho’s services are headquartered in India; however, its privacy policy states that by accessing or using their products and services or otherwise providing personal information or service data to them, you understand that the processing, transfer, and storage of your personal information or service data occur within the United States of America, the European Economic Area (EEA), and other countries where Zoho operates. Such transfers are subject to appropriate data protection agreements, such as a group company agreement based on the EU Commission’s model contractual clauses for data processing activities to which GDPR applies. You can write to [email protected] to obtain a copy of the agreements on the basis of which Zoho transfers your data within its group and with the third parties it engages.
In addition to the above mentioned, the following provisions apply specifically for residents of the USA.
Clever Groups is intended for users of all ages and their families, and it may collect information from children, at the direction of a parent or guardian registered with us. Below we summarize potential instances of collection and outline how and when we will provide parental notice and/or seek parental consent. In any instance that we collect personal information from a child, it will only be at the direction of a parent or guardian, and we will retain that information only so long as reasonably necessary to fulfill the activity request of that parent or guardian and ensure the security of our users and our services, or as required by law. In the event we discover we have collected information from a child in a manner inconsistent with COPPA’s requirements, we will either delete the information or immediately seek the guardian or parent’s consent for that collection.
A parent or guardian must register with Clever Groups before any child is allowed to use the website. If they intend to direct children to use Clever Groups, they should obtain parental or guardian consent prior and register this with Clever Groups using the online forms at https://clevergroups.com/privacy. This is a condition of access.
At the direction of that registered parent or guardian, children can register with Clever Groups to submit their name and a list of other people from a team chosen by that parent or guardian. A child may choose to use the registration process to enter this information or remain anonymous. We may ask the child to provide certain information for notification and security purposes, the child’s first and second name, the child’s account username, and password. Please note that children can choose whether to share their information with us, but certain features cannot function without it. As a result, children may not be able to access certain features if required information or consent has not been provided. We will not require a child to provide more information than is reasonably necessary in order to participate in an online activity. A child’s use of Clever Groups is not required but is more efficient for their parent or guardian if they choose to do so.
About the collection of parent email address: Consistent with the requirements of COPPA, on any child-targeted site or application, or in any instance where we ask for age and determine the user is age 12 or under, we will ask for a parent or guardian email address before we collect any personal information from the child. If you believe your child is participating in an activity that collects personal information and you or another parent/guardian have NOT received an email providing notice or seeking your consent, please feel free to contact us at [email protected]. We will not use parent emails provided for parental consent purposes to market to the parent, unless the parent has expressly opted in to email marketing or has separately participated in an activity that allows for such email contact.
We seek verifiable parental consent by email for the collection of personal information from children prior to their use of Clever Groups. Children’s use of Clever Groups is optional and only at the direction of their parent or guardian. Clever Groups allows children to create or manipulate names and save it. That information is only made available to the parent or guardian who requested the entry of the personal information and is never made available publicly.
We seek verifiable parental consent by email or online signed forms for the collection of personal information from parents or guardians of Children’s names and preferences. Please see our parental or guardian consent forms at https://clevergroups.com/privacy.
Email Consent. In the event Clever Groups wishes to collect personal information from a child, COPPA requires that we first seek a parent or guardian’s consent by email. In the email we will explain what information we are collecting, how we plan to use it, how the parent can provide consent, and how the parent can revoke consent. If we do not receive parental consent within a reasonable time, we will delete the parent contact information and any other information collected from the child in connection with that activity.
Teacher consent in lieu of a parent. With regard to school-based activities, COPPA allows teachers and school administrators to act in the stead of parents to provide consent for the collection of personal information from children. Schools should always notify parents about these activities. Please see our parental or guardian consent forms at https://clevergroups.com/privacy.
For more information on parental rights with respect to a child’s educational record under the Family Educational Rights and Privacy Act (FERPA), please visit the FERPA site.
On occasion, in order to respond to a question or request from a child, Clever Groups may need to ask for the child’s online contact information, such as an email address. Clever Groups will delete this information immediately after responding to the question or request.
In connection with certain activities or services, we may collect the child’s online contact information, such as an email address, in order for them to use the site only. In such instances we will retain the child’s online contact information to honor the request and for no other purpose such as marketing. Two email examples would be an email verification email and password reset email. Whenever we collect a child’s online contact information for ongoing communications only after receiving a parent or guardian’s email address who will be immediately notified about the collection and use of the child’s information.
Clever Groups collects geolocation information in the form of Country and IP address via automated means that is not specific enough to locate the user.
When Children interact with us, certain information may automatically be collected, to make Clever Groups more interesting and useful to Children and for various purposes related to our business. Examples include the type of computer operating system, the child’s IP address or mobile device identifier, the web browser, the frequency with which the child visits various parts of our sites or applications, and information regarding the online or mobile service provider. This information is collected using technologies such as cookies, flash cookies, web beacons, and other unique identifiers (see our Cookies Policy). This information may be collected by Clever Groups or by a third party. This data is principally used for internal purposes only, in order to:
In the event we collect (or allow others to collect) such information from Children on our sites and applications for other purposes, we will notify parents or guardians and obtain consent prior to such collection.
Additional privacy rights may apply depending on where you are located, including under laws applying in Australia, New Zealand, the United Kingdom, the European Economic Area, California or other parts of the United States.
Where a regional privacy law applies to our handling of your personal information, we will handle your personal information in accordance with that law to the extent required.
If there is any inconsistency between this privacy policy and a mandatory requirement under an applicable privacy law, the mandatory legal requirement will prevail to the extent of the inconsistency.
In addition to the above mentioned, the following provisions apply specifically for residents of California, USA.
The California Privacy Laws provide users who reside in California with specific rights regarding their personal information. This section describes the customers’ rights and explains how to exercise those rights, subject to exceptions under the law.
You have the right to request to know what personal information we have collected about you, including:
You have the right to request that we delete any of your personal information that we collect, subject to certain exceptions. Once we receive your request and verify your identity, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.
You have the right to request correction of inaccurate personal information that we maintain about you or update the information we have on file.
You have the right to opt out of the sale or sharing of personal information. Clever Groups does not sell or share personal information as defined by the CCPA, including personal information of minors under the age of 16. We may disclose personal information to service providers and contractors for business purposes, including to operate accounts, process subscriptions and payments, provide support and deliver our services.
You have the right to be protected from discrimination for exercising your rights. We will not discriminate against you for exercising your right.
Clever Groups does not use sensitive personal information in any manner that requires offering a right to limit its use.
You may submit your request by completing the Data Deletion form below or by sending an email to [email protected]. We will compare the information you submit to us with the information we have in our records to ensure your request meets the definition of “verifiable consumer request” under the California Privacy Laws. We will then respond to your request in accordance with the requirements.
Clever Groups endeavours to respond to a request within forty-five (45) days of its receipt. If Clever Groups requires more time (up to 90 days), you will be informed of the reason and extension period in writing. Any disclosures provided will only cover the twelve (12) month period preceding the receipt of the verifiable request. If applicable, the response will also explain the reasons for which Clever Groups cannot comply with a request. For data portability requests, Clever Groups will select a format to provide the Personal Information that is readily usable and should allow transmission of the information from one entity to another entity without hindrance. Clever Groups does not charge a fee to process or respond to the verifiable request unless it is excessive, repetitive, or manifestly unfounded. If Clever Groups determines that the request warrants a fee, we will inform why Clever Groups made that decision and provide a cost estimate before completing the request.
Clever Groups does not knowingly collect or disclose the personal information of children under the age of 16. As stated above, Clever Groups also do not sell or share personal information, including personal information of children under the age of 16. If you intend to encourage anyone under 16 to use this site, you must inform us by completing the parental or guardian consent form at clevergroups.com/privacy.
For further information about our privacy policy or practices, or to access or correct your personal data, or make a complaint, please contact us using the details set out below:
Email: [email protected]
Web: https://clevergroups.com/privacy
We reserve the right to change, modify, or revise this privacy policy at any time in order to comply with any applicable laws, to reflect changes in our processes, or for any other reason.
We will notify Registrants, account holders, subscribers when we update this Privacy Policy by publishing a notification on this website. We also communicate important changes in our Privacy Policy to Registered Users and customers during their subscription term.
By accessing our learning Sites or websites, creating an account, purchasing a subscription or using our services, you acknowledge the terms under which we process your information as set out in this Privacy Policy, including how we notify you of amendments to this Privacy Policy.
We may change this privacy policy from time to time by posting an updated copy on our website and we encourage you to check our website regularly to ensure that you are aware of our most current privacy policy.
Where we make any significant changes, we will endeavour to notify you by email or through your account, where appropriate.
Please use the following forms to provide consent per the section above about providing information for someone else.
Individual Consent School. Use this online form if a legitimate guardian or authorised adult, in relation to use with a school, to provide consent for one Minor to use Clever Groups.
Group Consent School. Use this online form if a legitimate guardian or authorised adult, in relation to use with a school, to provide consent for multiple Minors to use Clever Groups.
Individual Consent General. Use this online form if a legitimate guardian or authorised adult, if not attached to a school, to provide consent for one Minor to use Clever Groups.
Group Consent General. Use this online form if a legitimate guardian or authorised adult, if not attached to a school, to provide consent for multiple Minors to use Clever Groups.
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