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PRIVACY POLICY
GENERAL TERMS
INTRODUCTION
ImmerseMe Limited (we, us, our) complies with the New Zealand Privacy Act 1993, the General Data Protection Regulation of the European Union (GDPR) and other applicable privacy and data protection laws when dealing with personal information.
Personal information is information about an identifiable individual (a natural person). The term personal information in this privacy policy includes any personal data, personally identifiable information, or equivalent terms for such information under applicable laws.
This policy does not limit or exclude any of your rights under the New Zealand Privacy Act 1993, the GDPR or other applicable laws. If you would like further information on the New Zealand Privacy Act 1993, see www.privacy.org.nz. If you would like further information on the GDPR, see https://ec.europa.eu/info/law/law-topic/data-protection_en.
This policy was drafted with brevity and clarity in mind. It does not provide exhaustive detail of all aspects of our collection and use of personal information. We are happy to provide any additional information or explanation needed. Any request for further information should be sent to hello@immerseme.co.
CHANGES TO THIS POLICY
We may change this policy by uploading a revised policy onto the website. The change will apply from the date that we upload the revised policy.
This policy was last updated on 3 April 2020.
WHEN DOES THIS PRIVACY POLICY APPLY
This privacy policy sets out how we collect personal information through our website, our VR language-based learning platform, ImmerseMe, and our other related services and how we use, disclose and protect that personal information.
This privacy policy applies to personal information that we collect from:
▲ visitors to our website
▲ users of ImmerseMe, including:
‒ schools and teachers
‒ students that subscribe directly or that use ImmerseMe under a school’s or teacher’s subscription, and
‒ private adult users.
For the purposes of the GDPR, we are the data controller when storing or otherwise processing personal information uploaded and stored into ImmerseMe.
CHILDREN’S PRIVACY
ImmerseMe is primarily targeted at school students aged 10 to 18.
Students can subscribe to use ImmerseMe directly under an academic licence. If you are aged under 18, you will need to ensure that you have the consent of your parent or legal caregiver before subscribing to ImmerseMe. Your parent or legal caregiver will need to agree to our terms of use (available at https://immerseme.co/terms-of-use) as part of the subscription and account set up process. If you do not have your parent or legal caregiver’s permission, you must not subscribe to ImmerseMe or otherwise access and use ImmerseMe. You must not pretend to have your parent’s or legal caregiver’s permission if you do not have it.
Schools or teachers can also subscribe to ImmerseMe and set up profiles for that school’s or teacher’s students.
For students aged under 18 years old using ImmerseMe under a school’s or teacher’s subscription, we require the relevant subscriber (i.e. the student’s school or teacher) to obtain the necessary consents from the student’s parent or legal caregiver to allow that student to access and use ImmerseMe. We also require the subscriber to make reasonable efforts to verify that the person providing consent for a student aged under 18 years old has parental or legal responsibility over that student.
If you have reason to believe that parental consent has not been properly provided for a student aged under 18 that is using ImmerseMe, please contact us at hello@immerseme.co.
WHAT PERSONAL INFORMATION DO WE COLLECT
From or about students
Where:
▲ a student subscribes to ImmerseMe directly, or
▲ a school or teacher sets up a profile for a student under that school’s or teacher’s subscription,
we collect the following information from or about the student:
▲ first and last name (or first letter of last name minimum)
▲ academic email address (minimum)
▲ class (minimum)
▲ school (minimum)
▲ year level
▲ student ID.
We also collect the following information directly from students using ImmerseMe:
▲ content generated through use of ImmerseMe, including sound files of audio responses, text transcription of audio responses, written responses and information on the student’s progress and achievements
▲ Device and Usage Data (as described below).
Some personal information that we collect from or about students directly may be mandatory and some may be optional. We will let you know which of these applies at the time we collect the relevant personal information. While you do not have to provide us with some information we request, this might mean that our products and services may not perform as well as they should, or that we may not be able to provide some parts of ImmerseMe or all of our products or services. If you require further information about the consequences of not providing us with any information, please contact us at hello@immerseme.co.
Directly from subscribers
We collect the following information directly from subscribers to ImmerseMe:
▲ first and last name
▲ email address
▲ other information submitted for billing purposes
▲ any other information we require or ask for to set up an account.
Some personal information that we collect from subscribers directly may be mandatory and some may be optional. We will let you know which of these applies at the time we collect the relevant personal information. While you do not have to provide us with some information we request, this might mean that our products and services may not perform as well as they should, or that we may not be able to provide some parts of ImmerseMe or all of our products or services. If you require further information about the consequences of not providing us with any information, please contact us as at hello@immerseme.co.
We use a third party service provider, Stripe, to process credit card transactions and we do not have access to your credit card information. You can see further information about how Stripe processes credit card information in their privacy policy here.
Directly from website visitors and people who contact us
We collect the following information directly from visitors to our website and people who contact us:
▲ when you request a free trial on our website, call us, email us or otherwise contact us, your name, institution, email address, phone number, job title and any other information you choose to include in your enquiry
▲ when sign up to our mailing list or other electronic alerts, your email address and any other information you provide when you ask to receive about us or our products or services.
Automatically when you use our website or ImmerseMe
We may automatically collect information about a website visitor’s or ImmerseMe user’s device and usage of the website and ImmerseMe, including through third-party tools, e.g. your IP address, operating system, browser type, time spent on certain pages of the website, pages visited, links clicked, language preferences (Device and Usage Data).
Some of this Device and Usage Data is collected through the use of cookies, web beacons and similar storage technologies. Please refer to our Cookie Policy below for further information, including information on how you can disable these technologies.
From third parties
As noted above, we collect some personal information about students from subscribers. We do not collect personal information about students from third parties other than subscribers.
If you are a subscriber, where possible, we collect personal information from you directly, however, on occasion, we may collect personal information about you from the following third-party sources:
▲ personal information that is publicly available (e.g. through LinkedIn profiles, a school’s website or public directories)
▲ personal information from third parties where you have authorised this.
We may combine the personal information about students that we collect from subscribers and personal information about subscribers that we receive from third parties with the personal information we collect directly as described above or with Device and Usage Data.
HOW WE USE PERSONAL INFORMATION
We use personal information collected from or about students and other ImmerseMe users to:
▲ provide ImmerseMe
▲ analyse and prepare progress reports on, or an assessment of, a student’s or other user’s performance
▲ allow students and other users to participate in contests
▲ to conduct research and statistical analysis (on an anonymised basis)
We use personal information collected from subscribers (including students where a student subscribes to ImmerseMe directly under an academic licence) to:
▲ verify the subscriber’s identity
▲ provide ImmerseMe to the subscriber and any students the subscriber adds to their account
▲ to bill the subscriber and to collect money that the subscriber owes us, including authorising and processing credit card transactions
▲ to respond to communications, including enquiries and complaints
▲ to conduct research and statistical analysis (on an anonymised basis)
▲ to tailor content on our website
We may also use personal information from users, subscribers, website visitors and other people with whom we deal to:
▲ improve ImmerseMe, our website and related services
▲ protect and/or enforce our legal rights and interests, including defending any claim
▲ respond to lawful requests by public authorities, including to meet law enforcement requirements, or
▲ for any other purpose authorised by the relevant individual or applicable laws.
Information collected from or about students is never used to market to students. For persons other than students we use personal information to market ImmerseMe and our related services, including contacting the individual electronically (e.g. by text or email for this purpose). You can stop receiving our marketing emails by following the unsubscribe instructions included in those emails or contacting us directly.
We may transfer personal information in the case of a sale, merger, consolidation, liquidation, reorganisation or acquisition.
DISCLOSURE OF PERSONAL INFORMATION
We may disclose personal information collected directly from or about students:
▲ to the relevant subscriber (i.e. the student’s teacher or school) to provide progress reports or assessments of that student’s performance
▲ to a student’s parent if they request progress reports or assessments of that student’s performance
▲ to any business that supports ImmerseMe, our website or related services, including any person that hosts or maintains any underlying IT system or data centre, solely for the purpose of that business providing services to us
If a student chooses to take part in our contests or competitions (e.g. our global score board), we will display the student’s avatar, school and their progress/results on the global score board. This information is disclosed to other users of ImmerseMe. Students should choose avatars, so they are not personally identifiable.
If you are a subscriber, we may disclose your personal information to:
▲ another company within our group
▲ any business that supports our services and products, including any person that hosts or maintains any underlying IT system or data centre that we use to provide ImmerseMe or our website or that we use to process payments.
We may also disclose personal information to:
▲ our professional advisers e.g. accountants, lawyers or auditors
▲ a person who can require us to supply personal information (e.g. a regulatory authority or law enforcement agency)
▲ any other person with the relevant individual’s consent
▲ any other company in the case of a sale, merger, consolidation, liquidation, reorganisation or acquisition
▲ any other person authorised by applicable laws.
We may share information about website visitors’ use of our website with our trusted analytics partners through the use of cookies, web beacons, and similar storage technologies. Please refer to our Cookie Policy below for further information.
Within ImmerseMe, we use cookies solely to provide ImmerseMe to the user. We do not share personal information about ImmerseMe users’ use of ImmerseMe collected through cookies with any third parties.
INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION
A business that supports our website, products and services may be located outside of New Zealand (the country where we are incorporated) and also outside of the country where the relevant individual is located. This means that the personal information we collect may be transferred to, and stored in, a country outside of New Zealand and the country where the individual is located.
If an individual is located in the European Economic Area (EEA), that individual’s personal information may be transferred outside of the EEA. Under the GDPR, the transfer of personal information to a country outside the EEA may take place where the European Commission has decided that the country ensures an adequate level of protection. In the absence of an adequacy decision, we may transfer personal information if other appropriate safeguards are in place.
Where we transfer personal information outside the EEA, it will only be transferred to countries that have been identified as providing adequate protection for EEA data, or to a third-party where approved transfer mechanisms are in place to protect your personal information (e.g. to organisations in the United States under the EU-U.S. Privacy Shield framework or by entering into the European Commission’s Standard Contractual Clauses). For further information, please contact us at hello@immerseme.co.
Some of the personal information we collect is processed in New Zealand. New Zealand is recognised by the European Commission as a country that has an adequate level of data protection and we rely on this decision in transferring personal information to New Zealand.
PROTECTING PERSONAL INFORMATION
We will take steps required by applicable laws to keep personal information safe from loss, unauthorised activity, or other misuse. Where required, we implement appropriate technical and organisational measures to ensure a level of security appropriate to risks inherent in processing personal information.
ImmerseMe users play an important role in keeping personal information secure by maintaining the confidentiality of any password and accounts used in relation to ImmerseMe. You should not disclose your password to third parties (if applicable). Please notify us immediately if there is any unauthorised use of your account or any other breach of security.
ACCESSING AND CORRECTING PERSONAL INFORMATION
Subject to certain grounds for refusal under applicable law, you have the right to access your personal information that we hold and to request a correction to your personal information. Before you exercise this right, we will need evidence to confirm that you are the individual to whom the personal information relates.
If you are the parent or legal guardian of a child under 18 years old, you can exercise these rights on behalf of your child if:
▲ the child has authorised you to do so
▲ the child is not legally competent under applicable law to exercise these rights him or herself, or
▲ where it is evident that this is in the best interests of the child.
Where you request correction, if we think the correction is reasonable and we are reasonably able to change the personal information, we will make the correction. In all other cases, we will take reasonable steps to note on the personal information that you requested the correction.
If you want to exercise either of the above rights (either on your own behalf or on behalf of your child), email us at hello@immerseme.co. Your email should provide evidence of who you are and set out the details of your request (e.g. the personal information or the correction that you are requesting).
Subject to applicable law, we may charge you our reasonable costs of providing to you copies of your personal information or correcting that information.
In addition to the rights to access and correct your personal information, if you are based in the EEA, you have the additional rights set out in the GDPR Additional Terms section of this privacy policy below.
INTERNET USE
While we take reasonable steps to maintain secure internet connections, if you provide us with personal information over the internet, the provision of that information is at your own risk.
If you follow a link on our website to another site, the owner of that site will have its own privacy policy relating to your personal information. We suggest you review that website’s privacy policy before you provide personal information to or through that site.
DATA RETENTION POLICY
The personal information that we collect and process will not be kept longer than necessary for the purposes for which it is collected, or for the duration required for compliance with applicable law, whichever is longer.
CONTACTING US
If you have any question about this privacy policy, our privacy practices, or if you would like to request access to, or correction of, your or your child’s personal information, you can contact us at hello@immerseme.co.
The name and contact details of our European representative for the purposes of the GDPR are:
Name: Karl Fitzpatrick
Email address: karl.fitzpatrick@outlook.com
Phone number: +358407285539
GDPR ADDITIONAL TERMS
LAWFUL BASIS FOR PROCESSING PERSONAL INFORMATION
Our lawful basis for processing (as that term is defined in the GDPR) personal information that we collect, use and disclose depends on the personal information collected and the context in which we collect it.
Generally, we collect personal information where we have or believe we have the individual’s consent, where processing is necessary for the performance of a contract to which the individual is party or in order to take steps at the individual’s request prior to entering into a contract or where processing is necessary for the purposes of our legitimate interests (except where such interests are overridden by the individual’s interests or fundamental rights and freedoms).
Where we process personal information based on consent, the individual or the individual’s parent or legal guardian (as set out below) may withdraw consent at any time.
Despite the above, we may process personal information where such processing is necessary for compliance with applicable laws.
If you have any question about the legal basis on which we process personal information or need further information, please contact us at hello@immerseme.co.
YOUR RIGHTS UNDER THE GDPR
Your rights in relation to your personal information under the GDPR include:
▲ right of access - if you ask us, we will confirm whether we are processing your personal information and provide you with a copy of that personal information
▲ right to rectification - if the personal information we hold about you is inaccurate or incomplete, you have the right to have it rectified or completed. We will take reasonable steps to ensure inaccurate personal information is rectified. If we have shared your personal information with any third parties, we will tell them about the rectification where possible
▲ right to erasure - we delete your personal information when it is no longer needed for the purposes for which you provided it. You may request that we delete your personal information and we will do so if deletion does not contravene any applicable law. If we have shared your personal data with any third-party, we will take reasonable steps to inform those third parties to delete your personal information
▲ right to withdraw consent - if the basis of our processing of your personal information is consent, you can withdraw that consent at any time
▲ right to restrict processing - you may request that we restrict or block the processing of your personal information in certain circumstances. If we have shared your personal information with any third-party, we will tell them about this request where possible
▲ right to object to processing - you may request that we stop processing your personal information at any time and we will do so to the extent required by the GDPR
▲ rights related to automated decision-making, including profiling – you have a right to not be subject to a decision-based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you, except where such automated decision-making is necessary for entering into, or the performance of, a contract with you, is authorised by applicable laws or is based on your explicit consent. We do not undertake automated individual decision-making
▲ right to data portability - you may obtain your personal information from us that you have consented to give us or that is necessary to perform a contract with you. We will provide this personal information in a commonly used, machine-readable and interoperable format to enable data portability to another data controller. Where technically feasible, and at your request, we will transmit your personal information directly to another data controller
▲ the right to complain to a supervisory authority - you can report any concern you have about our privacy practices to the relevant data protection supervisory authority.
Where personal information is processed for the purposes of direct marketing, you have the right to object to such processing, including profiling related to direct marketing.
If you are the parent or legal guardian of a child under 18 years old, you can exercise the above rights on behalf of your child if:
▲ the child has authorised you to do so
▲ the child is not legally competent under applicable law to exercise these rights him or herself, or
▲ where it is evident that this is in the best interests of the child.
If you would like to exercise any of your above rights or exercise the above rights on behalf of your child, please contact us at hello@immerseme.co. If you are not satisfied by the way we deal with your query, you may refer your query to your local data protection authority.
IMMERSEME Cookie policy
INTRODUCTION
We use cookies on our website and as part of ImmerseMe, and receive information collected through cookies. This cookie policy explains how we use cookies and how you can opt-out of cookies.
By continuing to use our website and related services, you indicate your agreement for us to use the cookies described below.
We use the term cookies in this cookie policy to mean cookies or similar technologies such as web beacons, clear GIFs, and pixel tags.
WHAT ARE COOKIES
Cookies are text files containing small amounts of information which are downloaded to your browsing device, e.g. a computer or smartphone, when you visit a website. Cookies can be recognised by the website that downloaded them, or other websites that use the same cookies. This helps websites know if the browsing device has visited them before.
Cookies do lots of things, like collecting information relating to your use of a website or your device, letting you navigate between pages effectively, remembering your preferences, and generally improving your browsing experience.
Cookies can be persistent or session cookies. Session cookies are temporary and only stay on your browser until you stop browsing. Persistent cookies stay on your device until they expire or are deleted.
The cookies used on our website may be first party cookies (i.e. set by us) or third-party cookies. Third-party cookies are cookies set on our website by a company other than us. The third-party companies that place cookies on our website will have their own privacy policies.
WHAT TYPES OF COOKIES DO WE USE
The types of cookies used by us, and most websites, can generally be categorised as follows.
Strictly necessary cookies
These cookies are essential for the full functionality of our website and related services. They enable you to navigate around our website and services and use their features e.g. accessing secure areas and to enable services you have specifically asked for. If you opt out of these cookies, you may not be able to access all the functions of our website and some services that you have asked for.
These cookies do not track where else you have been on the Internet and do not remember your preferences beyond your current visit. These cookies are generally first party session cookies which will expire when you close your browsing session. These cookies do not collect information that could be used for marketing purposes.
Functionality cookies
These cookies allow the website and related services to remember choices you make and provide enhanced, more personal features. For example, these cookies allow us to remember the settings you have applied to the website (e.g. font size, preferences or colours), identify whether you are a returning website visitor and present you with a personalised version of the website, or eliminate the need for you to re-enter your login details. The information these cookies collect is generally anonymous and they do not track your browsing activity on other websites. These cookies may be first or third-party, session or persistent cookies.
Performance cookies
These cookies collect information about how you use our website and related services e.g. which pages are the most visited and if you receive any error messages from any pages. This information helps us improve the way the website and services work and helps us manage the performance and design of the website. These cookies do not gather information that identifies you. All information these cookies collect is aggregated and anonymous. These cookies may be first or third-party, session or persistent cookies.
THIRD PARTY COOKIES
We use Google Analytics to collect information about visitors to our website. Google Analytics collects information related to your device, browser, IP address, network location and website activities to measure and report statistics about your interactions on our website. We use this information to help us manage the performance and design of our website and to improve our website.
For further information on how Google uses your personal information when you use our website and how to opt out of Google’s use of cookies, see here. In addition to this link, you can opt out as described in the “How to control or opt out of cookies” section below.
HOW TO CONTROL OR OPT OUT OF COOKIES
You can control and/or delete cookies as you wish. You can delete all cookies that are already on your computer and you can set most browsers to prevent them from being placed. If you do this, however, you may have to manually adjust some preferences every time you visit our website and attempt use our services, you may not be able to access certain parts of our website or services, and some functionalities may not work.
You can find out more information about how to change your browser cookie settings at http://www.aboutcookies.org.uk.
To learn more about how to control cookie settings through your browser:
▲ click here to learn more about the Private Browsing setting and managing cookie settings in Firefox
▲ click here to learn more about Incognito and managing cookie settings in Chrome
▲ click here to learn more about InPrivate and managing cookie settings in Internet Explorer
▲ click here to learn more about Private Browsing and managing cookie settings in Safari.
THIRD PARTY WEBSITE COOKIES
If you follow a link on our website to another site, the owner of that site will have its own cookies. We suggest you review that website’s cookie policy before you visit that website.