Privacy Policy

1. Background

Thanks for visiting our Privacy Policy (Policy), we are Content First Pty Ltd ACN 123 510 869 of 12/104 Barwon St, Morningside QLD 4170, Australia (Airchild, we, our, us and other similar terms). We are committed to providing quality services to you and this Policy outlines our ongoing obligations in respect of how we manage your Personal Information. It applies to the use of our websites at https://www.airchild.ai/ and https://www.contentfirst.com.au/ (Websites) along other agreements we may form with you such as service agreements and the Airchild Terms and Conditions.

When we talk about Personal Information, we mean information or an opinion about an identifiable individual (not a company), whether or not that information or opinion is true or in a material form (Personal Information).

2. Disclaimer

While your privacy is important to us, nothing in this Privacy Policy constitutes a voluntary opt-in to any privacy laws, anywhere in the world, which we are not statutorily bound to comply with.

3. Collection of Personal Information

We collect Personal Information in the ordinary course of our business, which is the provision of the Airchild software and our digital marketing services. Personal Information is collected when you:

• contact or correspond with us via email, telephone or via our Websites;
• purchase or enquire about our software and services;
• subscribe to our newsletters or complete surveys and online forms;
• seek support in relation to our software and services; or
• make customer service related enquiries.

Information will only be collected directly from you unless you authorise another person to provide the information.

3.2 Airchild customer data

Child care centres who subscribe to our Airchild software, and their customers, also enter data, containing Personal Information, into that software. While we process that data on behalf of our clients, we are not the controller or owner of that data.

If you are a customer of a Child Care Centre with an enquiry about data held in the Airchild software we ask you to contact the Child Care Centre. They have access to and control all Personal Information contained in their implementation of the Airchild Software.

3.3 What Personal Information is collected?

The types of Personal Information we collect include your name, address, telephone number, email, IP address, device identification, some social media details and any additional information you provide to us.

Where you contact us on behalf of your employer, the information you provide often contains information about your employment, position and employers contact details. In those circumstances certain employment information is collected.

While we do not actively collect the data stored in the Airchild software, our clients do collect a broad range of Personal Information about their customers, including demographic data and contact details. They also store information about their employees and suppliers. This Privacy Policy sets out details of the security mechanisms employed to the management of both the Personal Information we collect and that collected by our Airchild subscribers.

4. How Airchild uses Personal Information

4.1 Why we collect Personal Information

We collect your Personal Information for the primary purpose of providing our software and services to you. We may also use your Personal Information for secondary purposes closely related to the primary purpose, in circumstances where you would reasonably expect such use or disclosure.
Examples of when we may use your Personal Information include:

• when instructed by the Child Care Centres who request the processing of the data held in the Airchild software;
• informing you about our software and services;
• providing you with the software and services you have requested;
• administration needs in relation to providing you with our software and services, including the administration of your account;
• dealing with requests, enquiries or complaints and other customer care related activities; and
• carrying out any activity in connection with a legal, governmental or regulatory requirement imposed on us or in connection with legal proceedings, crime or fraud prevention, detection or prosecution.

4.2 Direct marketing

Where you provide us with consent to do so (e.g. if you have subscribed to our email or SMS lists or have indicated that you are interested in receiving offers or information from us), we may send you marketing communications by email and SMS about products and services that we feel may be of interest to you.
We (or an appointed third party) may also conduct surveys or market research and may seek other information from you on a periodic basis. These surveys will provide us with information that allows improvement in the type, quality and the manner in which our goods and services are offered to you.
You can opt-out of such communications if you would prefer not to receive them in the future by using the “unsubscribe” facility provided in the communication itself.

5. Cookies and browser analytics

Cookies are small text files that are placed on your computer by the websites you visit. They are processed and stored by your web browser. When you visit a website or engage with a business through social media, certain information is collected by cookies. This is generally anonymous information and it does not reveal your identity. In and of themselves, cookies are harmless and serve crucial functions. They are widely used in order to make websites work more efficiently and improve the user experience, as well as to provide information about the use of a website.

5.2 Why we use cookies

By storing and using information about your use of our website, including preferences and habits, we are able to make your visit to our website more productive. For example, some cookies remember your language or preferences so that you do not have to repeatedly make these choices.

5.3 We use the following types of cookies:

• Required cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that pass information from one web page to another and to use online forms.
• Analytical cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are able to find what they are looking for easily. We also use third party cookies, such as those provided via the Google Analytics service. The information passed back to such third party providers is anonymous.
• Marketing cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you and remember your preferences. These cookies also record your visit to our website, the pages you have visited and the links you have followed. We may use this information to make our website and communications sent to you more relevant to your interests.

5.4 How can I remove cookies

Your web browser can choose whether or not to accept cookies. Most web browser software is initially set up to accept them. If you do not want your browser to use cookies, you can manage and control their use through your browser, including removing cookies by deleting them from your “browser history” (cache) when you leave the site. However, if you choose to reject cookies some parts of our website may not work properly.

6. Data retention and security

6.1 Security mechanisms we employ

Generally, we store your Personal Information using secure servers protected from unauthorised access, modification and disclosure. However, like most businesses, we hold some information on our staff’s computers (such as emails from you) and where necessary as hard copy files (such as printed invoices).

Our systems are located in Australia and in the United States of America. They are managed by us and our trusted service providers. Personal Information that we store or transmit is protected by security and access controls, including username and password authentication, multi-factor authentication, and data encryption (such as SSL) where appropriate.

In our dealings with third party service providers we take care to work with subcontractors and service providers who we believe maintain an acceptable standard of data security compliance.

6.2 How long we keep your Personal Information

We retain your Personal Information for as long as is necessary to provide our software and services to you, as required for our internal business operations, and to comply with our legal obligations.

If we hold Personal Information about you, and we do not need that information for any purpose, we will take reasonable steps to destroy or de-identify that information, in accordance with the Australian Privacy Principles (APP) and the European Union General Data Protection Regulation (GDPR), unless we are prevented from doing so by law.

Under Australian law, financial records, such as those relating to financial transactions, must be retained for 7 years after the transactions associated with those records are completed.

If you no longer want us to use your Personal Information, you can request that we erase it and, where you have an account with us, close your account. Where possible we will do so in accordance with the APPs and GDPR. However, where you request the erasure of your Personal Information we will retain information from deleted accounts as necessary for our legitimate business interests, to comply with the law, prevent fraud, collect fees, resolve disputes, troubleshoot problems, assist with investigations or requests by government, a court of law, or law enforcement authorities, enforce our contracts with you and take other actions permitted by law. Any information we retain will be handled in accordance with this Policy.

7 Disclosure of your Personal Information

7.1 Who we share your Personal Information with?

Your Personal Information may be disclosed to:

• our employees, a related company and our professional advisers (lawyers, accountants, financial advisers, etc.);
• regulators and government authorities in connection with our compliance procedures and obligations, including law enforcement agencies to assist in the investigation and prevention of criminal activities;
• a purchaser or prospective purchaser of all or part of our assets or our business, and their professional advisers, in connection with the purchase;
• a third party, in order to enforce or defend our rights, or to address financial or reputational risks;
• a rights holder in relation to an allegation of intellectual property infringement;
• third party contractors, suppliers and service providers with whom we have a business association, including:
  • payment gateway providers, such as PayPal Holdings Inc. and Stripe Inc.;
  • administration service providers; and
  • information technology service providers, including cloud application providers.

We will not disclose your Personal Information other than in accordance with this Policy without your consent.

7.2 Offshore transfers

Typically, the data we store in relation to the digital marketing services we provide remains in Australia, unless you ask us to send it offshore. However, the data stored in the Airchild software is stored on cloud servers in the United States of America, and may be accessed there by our service provider.

Our engagement of other service providers, such as those who operate cloud services, may have international data centres and disaster recovery sites. Consequently, these providers may have access to your information offshore. We rely solely on reputable organisations for such cloud services.

8. Anonymity and use of pseudonyms

If you contact us with a general enquiry, we may interact with you anonymously or through the use of pseudonyms. However, you are required to provide true and accurate details when requesting the supply of goods or provision of services. You agree you will provide accurate information if we require it.

9. Access to Personal Information and corrections

We endeavour to only hold Personal Information that is accurate, complete and up-to-date. You have the right to make a request to access Personal Information which we hold about you and to request corrections of any errors in that data. To make an access or correction request, contact us using the contact details provided at the end of this Policy.

If you have an Airchild account with us, you can access some of the Personal Information that we collect about you in that software. By logging into your account, you can update or correct certain information.

In order to protect your Personal Information, when you contact us, we may require identification from you before releasing the requested information or making the correction.

10. Additional rights for EU residents and citizens

For the purposes of the GDPR, we are a ‘data controller’ of Personal Information. If you’re a citizen or resident of the European Economic Area, the following rights apply to you.

You are entitled to ask us to port your Personal Information (i.e. to transfer in a structured, commonly used and machine-readable format, to you), to erase it, or restrict its processing. You also have rights to object to some processing that is based on our legitimate interests, such as profiling that we perform for the purposes of direct marketing, and, where we have asked for your consent to process your data, to withdraw this consent.

These rights are limited in some situations – for example, where we can demonstrate that we have a legal requirement to process your Personal Information. In some instances, this means that we may retain some data even if you withdraw your consent.

Where we require your Personal Information to comply with legal or contractual obligations, then provision of such data is mandatory and if you do not provide it then we will not be able to manage our contractual relationship with you, or to meet obligations placed on us. In those cases, you must provide us with your Personal Information, otherwise the provision of requested Personal Information is optional.

If you have unresolved concerns, you also have the right to complain to data protection authorities. The relevant data protection authority will be the data protection authority in the country:

Your privacy is important to us. If you have any complaints, concerns or questions about our handling of your Personal Information, we ask that you first contact our privacy officer whose contact details are listed below. We will investigate your complaint and reply to you in writing if you provide us with contact details and request us to do so.

• Email: help@airchild.ai
• Telephone: (07) 4429 8888
• Post: 12/104 Barwon St, Morningside QLD 4170, Australia

If, after we have conducted our investigations you are still not satisfied, then we ask you to consult with the Office of the Australian Information Commissioner:

• Email: enquiries@oaic.gov.au
• Telephone: 1300 363 992 (from overseas +61 2 9284 9749)
• Post: GPO Box 5218
  Sydney NSW 2001