Published on: 27th December, 2024
This document relates specifically to our Privacy Policy. The contents of this policy is inter alia shaped by the European Union General Data Protection Regulation (GDPR) and California Consumer Privacy Act (CCPA) which contains data protection requirements that apply since 2018. All businesses need to comply with the GDPR if they:-
Have an establishment in the region
Do not necessarily have an establishment in the region but offer goods or, and services or monitor the behaviour of individuals
These privacy laws relate to our business and as such we have aligned our business so as to conform in all our operations.
This Privacy Policy shall apply to all websites including web applications and or commercial ‘apps’ free or otherwise, owned and/or operated by Go-liberty Pty Ltd including without limitation the website on which this policy is posted and any of Go-liberty Pty Ltd sub web sites or applications and/or affiliate entities whether or not referred to directly as Go-liberty Pty Ltd or go-liberty Pty Ltd or Go-liberty or go-liberty.com, as well as mobile versions, social networking pages or any other of our applications that we exercise full control over (collectively, the “Site” or “site” or “Sites” or “sites”).
By accessing and/or using the site, you are expressly agreeing to comply with and be cognisant of this Policy.
Go-liberty Pty Ltd and any and all entities, including domains, that control, are controlled by, or are affiliated or under common control with Go-liberty, are collectively referred to herein as “we,” “us” or “our.”
You,” or “your,” refers to you, the school, boarding school, sports club, camp organisation, collective or entity – it’s members enrolled on our system and any or all other persons that you are representing or and enrolling as a user of any of our entities.
Go-liberty Pty Ltd may and will, revise or and update this policy at any time; please periodically review them, because your continued usage of the site indicates your agreement with any such changes. Any changes we make will be effective immediately upon notice, which we may provide by any means including, without limitation, posting a revised version of this policy on the Site. You can determine when this policy was last revised by referring to the “Last Updated” legend at the top or bottom of this policy. Be sure to return to this page periodically to ensure familiarity with the most current version of this policy.
Offering our product globally means we would operate within multiple data regions, countries, states or continents. Each with respective priorities and regulations. These include but limited to European General Data Protection Regulation (GDPR), California Consumer Privacy Act (CCPA), Brazil’s General Data Protection Law (LGPD), Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA), Australia’s Privacy Act 1988, South Africa’s Protection of Personal Information Act (POPIA), Kenya’s Data Protection and Privacy Act (DPPA), Information Technology Act 2000 (IT Act), Japan’s Personal Information Protection Act (PIPA), New Zealand’s Privacy Act 2020, Hong Kong’s Personal Data Privacy Ordinance (PDPO), China’s Cybersecurity Law, Taiwan’s Personal Data Protection Act (PDPA), South Korea’s Personal Information Protection Act (PIPA) Singapore’s Personal Data Protection Act (PDPA), Israel’s Protection of Privacy Law, Mexico’s Federal Law on Protection of Personal Data in Possession of Private Parties Act (LFPDP) and Argentina’s Law on Personal Data Protection (LPDP)
As preamble to this policy in simply terms the following points are embedded into our internal operations and security protocols.
Requests to the above or following points to be amended or addressed may be sent to dpo@boardingschoolsoftware.com Response will be effected in person at earliest convenience. Normally prior to 18 hours from time email is sent.
Regional regulations apply to all organisations engaged with personal information relating to people. We expect to be making regular updates to both our T&C and our Privacy Policy documents on a regular basis. We may, at our discretion elect to notify you by electronic or other means of changes to this policy. You should however not assume that this will always occur.
We do collect, hold, manipulate and store personal information including but not limited to personal biometrics, photos and other personal identifying data relating to clients, staff, the school and or students – hence forth “clients” or “you” We also have you create a username and password at various times when engaging with our services. You will likely be asked to provide us with certain personal information when you register within our web or mobile applications. The decision to provide this information is voluntary. However, if you choose not to provide the requested information, you may not be able to use the services, or the effectiveness of such services may be limited.
Go-liberty Pty Ltd is focused on making your online experience as interesting, as simple and as enjoyable as possible. We truly appreciate your presence on our various websites and applications. Most of all – at all times, we understand that you are our client and should be treated as such.
Go-liberty Pty Ltd (“us”, “we”, or “our”) operates the http://boardingschoolsoftware.com/ website, http://boardingschoolsoftware.com web applications, subsidiaries linked to it and various Go-liberty Apps, mobile applications (the “apps” or “Service/s”).
This section informs you of our policies regarding the collection, use and disclosure of personal information you provide us, be it of staff, student data, parents data or any other individual or entity associated with you or your entity, when you engage with any of our services. By using the Site, you acknowledge that you have read, and you agree to be bound by the terms of this, our Privacy Policy.
Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms and Conditions, accessible on this same website.
Whilst we practice appropriate data security procedures and actions, pragmatically, the world wide web is an open medium where no data transmission can be considered entirely secure. You transmit data of any nature at your own risk. Go-liberty cannot and does not guarantee or warranty the security of any information or data you store, transmit to, through or from the site. Once received, information and data is stored on secure servers.
Legislation dictates regimented minimum procedures for handling personal data, responses to compromised data events and associated consequences. This places responsibility on three parties. Data Controllers, who in our instance is us; Data Processors, who are the businesses we evaluate, choose and trust to partner with to host our data securely.
As data controllers, our obligations relate to principals such as lawfulness, fairness, transparency, purpose limitation, data minimization, accuracy, meeting data subject’s rights with respect to data. We understand that data breeches may occur in which event we are obligated to report such event to relative supervisory authorities as soon as is reasonably possible, currently 72 hours. We also have an obligation to inform end users where such data breech impacts or may impact on such end users.
In accordance with legislation we nominate & appoint a DPO (Data Protection Officer.) Duties of such DPO include advising us of legislation requirements & national supervisory authorities such as information commissioners office; monitoring our compliance; advising on our data impact assessments and being point of contact for data subjects.
Our DPO can be contacted at dpo@boardingschoolsoftware.com
Our method of informing our clients will be by email to the current and most recent email address we have on file. This may be followed up by telephone conversation to discuss matters in more detail. Whilst ‘we’ may have on file data relating to clients of ‘yours’ we will not attempt to contact them in this regard as we consider it appropriate to afford you opportunity to choose time, medium and details of this disclosure. Local regulatory authority legislation may impact the timeline and details under which you need to disseminate such information.
The third party in our instance is ‘you’ our clients or consumers of our product or service we provide. Various electronic devices will be used to display selected information (data) some of this may be considered personal data and thus regulated under jurisdiction of your local regulatory authority. Please be aware that ‘you’ as users of peoples’ personal data, have responsibility to manage such data in accordance with your local regulatory authority. Please communicate with our DPO if we can assist with supporting you in our business relationship.
The security of your personal information, data, is important to us, but remember, as stated above no method of transmission over the Internet, or method of electronic or physical storage is ever 100% secure. We deploy modern multi-layered security protocols as well as selected commercial products. Robust security policies and procedures specifically designed to protect personal data against risks. Such risks may include but are not limited to unauthorised access or use, unintended or inappropriate destruction, modification, or disclosure of your data, we cannot guarantee its absolute security.
Go-liberty may provide you with notices, including those regarding updates or changes to this Privacy Policy, our Terms and Conditions and notices regarding breaches of security, by email, regular mail or postings on the Site.
You agree to indemnify, defend and hold harmless Go-liberty, its officers, directors, employees, agents, licensors, suppliers and any third party information providers to the Site from and against all losses, expenses, damages and costs, including reasonable attorney fees, resulting from any violation of this Privacy Policy and as stated in our Terms and Conditions, including negligent or wrongful conduct.
In keeping with our main core business – that is providing a service vis-à-vis a database tool for approved Boarding Schools or other institutions or organisations or individuals to use in managing students or groups of people. Entities may choose to upload or allow to be uploaded, personal information (data) onto our servers or onto personal devices belonging to the school or belonging to staff or students or parents associated with such school or entity. This will be for storage or and manipulation in such a way that we may provide a service to such Boarding Schools or other institutions or organisations or individuals.
We accept, manipulate, redistribute data back to you, staff, students, parents or educational institution or entities only in accordance with the provisions of our privacy policy, terms and conditions, our routine operating protocols or as authorised or instructed by law, or as otherwise negotiated with the Boarding Schools or other institutions or organisations or individuals.
Go-liberty will not utilise any data, photograph, biometrics or any other personal and private identifying data for anything other than its intended purposes without consent from the respective Boarding Schools, entity or individuals.
It remains your responsibility to ensure that appropriate security regimes pertaining to hardware devices is managed and in place to protect your data that is on our cloud based system and made available to you.
We automatically collect, or and, users will supply usage information, data, that does identify individuals. This is mostly essential and aligned with inherent functionality of our services. This information is however only intentionally available to Go-liberty, our immediate agents or developers, the respective registered entity – meaning school, organisation, club, individual or individuals.
This application also allows us to collect personal, non-personal & generic information regarding how users access and use Services (Usage Data). For example, when you download and use Services, we may automatically collect information on the type of device you use, operating system version, and the device identifier which may be serial number, UDID or another identifier.
Additionally, each time you use the Site, we may automatically collect information regarding the type of web browser you use, your operating system, your Internet Service Provider, your IP address, our pages you view, the time and duration of your visits to our site or sites. We use this information to analyse trends, administer the Site and to enhance and update the Services. We may ask you for access or track any location based information from your mobile device at any time while downloading or using our mobile applications or services. Your permission to our access to and tracking of your location-based information is purely voluntary, and, accordingly, you may freely opt-in of or opt-out of and determine the level of specificity of the same.
As a general policy, we use Personal Information and Message Data for internal purposes only. This would be to facilitate your registered institutions internal management regimes, processes and communication. Furthermore, it may be used to provide registered users with services and to notify you of new products or to otherwise communicate with you. We do not sell, share or rent personal information or message data about you with third parties other than as disclosed within this Privacy Policy.
From time to time, we may establish business relationships with other businesses that we believe are trustworthy and who have confirmed that their privacy practices are consistent with ours. For example, we may contract with Service Providers to provide certain services, such as hosting and maintenance, customer relationship management, send out push notifications, and data storage and management. We would as far as practically possible, provide our service providers with only the information necessary for them to perform these services on our behalf. Each Service Provider must agree to use reasonable security procedures and practices, appropriate to the nature of the information involved, in order to protect your personal information and data from unauthorised access, use or disclosure. Service Providers are prohibited from using personal information or message data in any other manner than as specified or contained to a secure encrypted platform.
We may use and disclose to third parties such as Google Analytics, but not limited to such, certain Usage Data. This data would not identify individual users, regarding the Site and Services.
This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from. We do not link the information we store within the analytics software to any personally identifiable information you submit within our services or mobile applications.
We utilise a third-party hosting provider that hosts the information platform for our services as well as our sites. They are only allowed to access the personal information that is necessary for them to perform their duties and may not use it for any other purpose.
If Go-liberty Pty Ltd is merged, acquired, or sold, or in the event of a legitimate transfer of some or all of our assets, we may disclose or transfer personal information, usage data and message data in connection with such transaction.
Upon such transaction, Go-liberty, it’s directors or/ and officers may be relieved of any further obligation under this policy.
Go-liberty Pty Ltd will cooperate with government and law enforcement officials to enforce and comply with the law, where required. We may therefore disclose personal information, usage data, message data, and any other information about users where requested by enforcement authorities and where we deem it reasonable or necessary to:
In keeping within our core business which is that of student data manipulation as a management tool, we only provide access to users (managers /staff) who have been approved and recommended or added by such institution, school or entity to which the manager is connected or appointed. Institution (school) Administration Managers can and do manage their own users (managers/staff) to appoint, add or delete such users and grant managed access to student data from their own entity, institution (school) portal. School Management are responsible for adding their own staff to the system and as such remain responsible for the associated child and data protection mechanisms. Similarly, management should regularly check on the system to ensure that managers / staff on the system have been approved and vetted according to your institution and regulatory authority procedures.
Since we enter into this agreement / business arrangement with you, our negotiations are with you and we provide a service to you, our responsibility in terms of the service and security thereof is to you. This in no way diminishes our responsibility or commitment to provide the service we offer coupled with the security and privacy regimes we practice. Informing parents and carerers of our operations and practices remains the responsibility and prerogative of you, the school, organisation, entity or individual. We will upon request from you, consider and endeavor to provide to you, any and all reasonable or legislated documentation or procedures relating to the handling of data and personal information.
We strive to maintain your personal data within your respective data region. This practice aligns with our commitment to data privacy and complies with applicable data localisation requirements. However, please note that data localisation may change in response to evolving regulations or technical considerations. We rely on trusted service providers and hosting providers to ensure that your data remains within the specified region.
The English language version of each of these documents is the version that governs your use of the site and in the event of any conflict between the English language version and a translated version, the English language version will ultimately control. A date or version appropriate printed version of this policy and of any notices given in electronic form shall be admissible in judicial or administrative proceedings based upon or relating to this policy to the same extent and subject to the same conditions as other business documents and records originally generated and maintained in printed form.
