Classe365 Direct Notice to Parents

Dear Parent,

We are committed to protecting the personal information of children whose personal data is processed through our platforms listed at the end of this notice (the “Platforms”). We would like to inform you that we, as a service provider, process certain personal data of children under the age of 13 (“child” or “children”). The processing of children’s personal data occurs when an educational organization that provides education services to your child (the “Organization”) or other entity using the Platforms for their daily operations invite you or your child to create a user account on one of our Platforms.

Under the U.S. Children’s Online Privacy Protection Act (COPPA) and other applicable privacy laws, your consent is required before we process your child’s personal data through the Platforms. We ask you to provide such consent after you review our comprehensive privacy policy available at https://www.classe365.com/classe365-privacy-policy (the “Privacy Policy”) and Children’s Privacy Policy available at https://www.classe365.com/classe365-childrens-privacy-policy/.

If you would like to receive more information about how the Organization collects and uses your child’s personal data, please contact the respective Organization directly.

What personal data do we process?

We do not require to disclose more information about children than is reasonably necessary for their use of the Platforms. The personal data processed by us through Platforms includes child’s:

• Full name;
• Address;
• Phone number;
• Email address;
• Birth date;
• Online identifiers (IP address and cookie-related data); and
• Any other information requested by the Organization or provided by you voluntarily.

For what purposes do we process personal data?

Children’s personal data is processed by us only for the purposes of:

• Providing our services through the Platforms (i.e., creating and enabling your child’s account);
• Facilitating communication between the Organizations, you, and the child;
• Conducting analytics of our business; and
• Business administration, auditing and security purposes.

We do not use children’s personal data for any other purposes.

Do we disclose children’s personal data to third parties?

We disclose children’s personal data only to the authorised third parties that perform services on behalf of us (our data processors), namely:

• Hosting service provider Amazon Web Services (https://aws.amazon.com);
• Business analytics service providers Google Analytics (https://analytics.google.com) and Semrush (https://www.semrush.com);
• Email service providers MailChimp (https://mailchimp.com), Active Campaign (https://www.activecampaign.com), and Intercom (https://www.intercom.com); and
• Software developing partner Atlassian (https://www.atlassian.com).

Such third parties are engaged to maintain the confidentiality and security of personal data. We may also reply to lawful requests from public authorities.

You can agree to the collection and use of the child’s personal data without consenting to the disclosure of the personal data to third parties, unless it is necessary for provision of the services through the Platforms.

What are your rights regarding children’s personal data?

You can review your child’s personal data, ask to have it deleted and refuse to allow any further collection or use of the child’s data. You can review, correct and delete your child’s personal data by:

• Accessing your or your child’s account. Some child’s personal data is available through the user account of the Platform that you use. The possibility to create and maintain such an account is provided by the Organization. Please note that the availability of the personal data is also defined by the Organization. You can consult your and your child’s accounts to see what information is available to you.
• Contacting the Organization. You can contact the respective Organization directly and request it to provide you with access to your child’s personal data.
• Contacting us. In the last instance, you can contact us at clientservice@classe365.com. If we have the right and capacity, we will process your request in accordance with the applicable laws. However, please note that, in some instances (e.g., if we act as a data processor and the GDPR is applicable), we may not be able to directly process your request. If it happens, we will need to contact the respective Organization that acts as a data controller under the GDPR and forward your request to it. The Organization will be responsible for processing your request.

How to consent?

You can provide your consent by clicking on the button “I CONSENT”. By clicking on the button “I CONSENT”, you are granting your consent to the processing of your child’s personal data as described in this notice and our Privacy Policy (https://www.classe365.com/classe365-privacy-policy/) and you affirm that you are a parent or legal guardian with the authority to provide such consent.

What are our contact details?

Our email address is: clientservice@classe365.com

Our postal address is: 365.Software, 22 Palm Street, St. Ives, NSW 2075, Australia

Where can you find more information?

• The more detailed description of our practices regarding collection, use, and disclosure of personal data are set forth in our privacy policy available at https://www.classe365.com/classe365-privacy-policy/. For more information on how we process children’s personal data, please refer to our Children’s Privacy Policy available at https://www.classe365.com/classe365-childrens-privacy-policy/
• For more information about COPPA, please visit https://www.consumer.ftc.gov/articles/0031-protecting-your-childs-privacy-online.

Our platforms

1. Student management platform Classe365 available at https://www.classe365.com (“Classe365”);
2. Student hiring management platform Hiree365 available at https://www.hiree365.com (“Hiree365”); and
3. Related websites, software, and services.