Privacy Statement

LessonBuffet.com's Privacy Statement

This document declares the undertakings by LessonBuffet.com ("LessonBuffet") in relation to its handling of Your Data.
At LessonBuffet, we value our reputation. This means that we won't steal your identity, spam you silly, or sell or distribute any of your personal information except as required by law (and even then, they'd better have a warrant).
Any information submitted by you is used solely for the purpose of completing the transaction, delivering the product and addressing any customer service issues.
If you'd like the fully-blown legal explanation, by all means scroll down & have a read.

Data Collection

LessonBuffet undertakes to collect Your Data by means that are:

  • fair;
  • legal; and
  • transparent.

If you visit LessonBuffet's web-site, your web-browser automatically discloses, and LessonBuffet's web-server automatically logs, the following information: the date and time, the IP address from which you issued the request, the type of browser and operating system you are using, the URL of any page that referred you to the page, the URL you requested, and whether your request was successful. This data may or may not be sufficient to identify you.

Any additional data that you provide, e.g. in a web-form, may also be logged. This data may or may not be sufficient to identify you.

Any additional data that your web-browser automatically provides may also be logged. This will be the case, for example, if your browser has previously been requested to store data on your computer in 'cookies' and submits them each time you request a web-page
within a particular domain (such as LessonBuffet.com). This data may or may not be sufficient to identify you.

If you disclose personal data to LessonBuffet in conjunction with an identifier such as your name, LessonBuffet will collect Your Data. Moreover, any data that becomes available to LessonBuffet through any of the means described in the preceding paragraphs may
be able to be associated with that identifier, and hence become Your Data.

Subject to the qualifications immediately below, LessonBuffet undertakes to collect Your Data from you and not from other parties. This undertaking is qualified as follows:

  • where LessonBuffet reasonably considers that the protection of its financial interests requires that it gather Your Data from other sources, or from additional sources.
  • where LessonBuffet reasonably considers that its capability to deliver quality services to you will be materially enhanced by gathering Your Data from other sources. This applies in particular to consumer profile data.

Where LessonBuffet collects Your Data from sources other than you, it undertakes:

  • to do so only by legal means;
  • to do so only with your Consent; and
  • to declare to you what sources it uses, and under what circumstances.

LessonBuffet undertakes to declare the purpose of collection in a manner which is clear and meaningful, and to avoid vague, highly inclusive statements such as 'to support our operations'.

Data Security

LessonBuffet undertakes to store Your Data in a manner that ensures security against unauthorised access, alteration or deletion, at a level commensurate with its sensitivity.
LessonBuffet undertakes to store Your Data only in jurisdictions where data protections are at least equivalent to those required under the OECD Guidelines.
LessonBuffet undertakes to transmit Your Data in a manner that ensures security against unauthorised access, alteration or deletion, at a level commensurate with its sensitivity.

LessonBuffet undertakes to implement appropriate measures to ensure security of Your Data against inappropriate behaviour by LessonBuffet's staff-members and contractors. These include:

  • training for staff in relation to privacy;
  • access control, to limit access to Your Data to those staff and contractors who have legitimate reasons to access it;
  • particularly in the case of sensitive data, audit trails of accesses, including the identities of staff and contractors accessing the data;
  • reminders to staff and contractors from time to time about the importance of data privacy, and the consequences of inappropriate behaviour;
  • declaration of appropriately strong sanctions that are to be applied in the event of inappropriate behaviour
  • clear communication of policies and sanctions; and
  • processes to audit, to investigate and to impose sanctions.

Data Use

Use refers to the application of Your Data by any part of LessonBuffet, or any staff-member or contractor of LessonBuffet in the course of their work.

LessonBuffet undertakes to use Your Data only for:

  • the purposes for which it was collected;
  • such other purposes as are subsequently agreed between LessonBuffet and You;
  • such additional purposes as may be required by law. In these circumstances, LessonBuffet will take any reasonable steps available to it to communicate to You that the use has occurred, unless it is precluded from doing so by law; and
  • such additional purposes as are authorised by law (in particular to protect LessonBuffet's interests, e.g. if it believes on reasonable grounds that You have failed to fulfil your undertakings to LessonBuffet or have committed a breach of the criminal law).

LessonBuffet undertakes to use Your Data only if it has demonstrable relevance to the particular use to which it is being put.

LessonBuffet undertakes to use Your Data in such a manner as to take into account the possibility that it is not of sufficient quality for the purpose, e.g. because it is inaccurate, out-of-date, incomplete, or out-of-context.

Data Disclosure

Disclosure refers to making Your Data available to any party other than LessonBuffet and You. The term disclosure may include many different conditions of data transfer, including selling, renting, trading, sharing and giving.
LessonBuffet undertakes to disclose Your Data only under the following circumstances:

  • in the course of business being conducted between You and LessonBuffet, where disclosure is necessary to a contractor, such as a transport company. Where Your Data is disclosed in this way, LessonBuffet undertakes to exercise control over LessonBuffet's contractors to ensure that
    their actions are compliant with these Terms;
  • in other circumstances that are directly implied by the purpose agreed between You and LessonBuffet at the time of data collection or subsequently. Where Your Data is disclosed in this way, LessonBuffet undertakes to exercise control over LessonBuffet's contractors to ensure that their actions are compliant with these Terms;
  • with your consent, or at your request;
  • where required by law, such as a provision of a statute, or a court order such as a search warrant or sub poena. In these circumstances, LessonBuffet will take any reasonable steps available to it to communicate to You that the disclosure has occurred, unless it is precluded
    from doing so by law;
  • where permitted by law (e.g. the reporting of suspected

    breach of the criminal law to a law enforcement agency; and in an emergency, where LessonBuffet believes on reasonable grounds that the disclosure of Your Data will materially assist in the protection of the life of health of some person), provided that LessonBuffet will apply due diligence to ensure that the exercise of the permission is justifiable.

In all cases, LessonBuffet undertakes to disclose only such of Your Data as is necessary in the particular circumstances.

Data Retention and Destruction

Subject to the qualifications immediately below, LessonBuffet undertakes:

  • to retain Your Data only as long as is consistent with its purpose; and
  • to destroy Your Data when its purpose has expired, and to do so in such a manner that Your Data is not subsequently capable of being recovered.

This undertaking is qualified as follows:

  • Your Data may be retained in LessonBuffet's logs, backups and audit trails within short-term retention cycles that are devised to protect the company's operations. In such cases, Your Data will be destroyed in accordance with those cycles;
  • Your Data may be retained beyond the expiry of its purpose if that is required by law, such as a provision of a statute, or a court order such as a search warrant or sub poena, or a warning by a law enforcement agency that delivery of a court order is imminent. In these circumstances, LessonBuffet:
    • will take any reasonable steps available to it to communicate to You that Your Data is being retained, unless it is precluded from doing so by law; and
    • will only retain Your Data while that provision is current, and will then destroy Your Data;
    • Your Data may be retained beyond the expiry of its purpose if it is authorised by law (in particular to protect LessonBuffet's interests, e.g. if it believes on reasonable grounds that You have failed to fulfil your undertakings to LessonBuffet or have committed a breach of the criminal law). In these circumstances, LessonBuffet will only retain Your Data while that situation is current, and will then destroy Your Data.

Access by You to Your Personal Data

LessonBuffet undertakes to provide you with access to Your Data, subject to only such conditions and processes as are reasonable in the circumstances. In particular, LessonBuffet undertakes to enable access:

  • conveniently;
  • without unreasonable delay; and
  • without cost.

LessonBuffet undertakes to establish and operate identity authentication protections for access to Your Data that are appropriate to its sensitivity, but practical. This may involve some inconvenience; for example, relatively straightforward procedures may be involved in order to provide you with access through a channel that you have previously registered with LessonBuffet (such as a particular email-address), but may impose more onerous procedures if you wish to use some other channel.
In the event that you dispute some aspect of Your Data, LessonBuffet undertakes to take reasonable steps in relation to the amendment, supplementation or deletion of Your Data.
You undertake:

  • not to seek access for frivolous purposes, or unreasonably frequently;
  • to accept that deletion of some data may not be consistent with the
    provision of particular services by LessonBuffet to you.

Information about Data-Handling Practices

LessonBuffet undertakes to make information available to you about the manner in which LessonBuffet handles your data:

  • in general terms, in a readily accessible manner; and
  • in more specific terms, on request.

Where Your Data is disclosed to a contractor, LessonBuffet undertakes to make information available to you on request about the manner in which LessonBuffet's contractors handle your data.
LessonBuffet undertakes to ensure that the information provided is meaningful, and addresses your concerns.
You undertake:

  • not to seek such information for frivolous purposes, or unreasonably frequently; and
  • to accept that the disclosure of excessive detail may harm the security of Your Data and LessonBuffet's business processes, and may harm LessonBuffet's commercial interests.

Handling of Enquiries, General Concerns and Complaints

If you have enquiries, general concerns, or complaints about these Terms, or about LessonBuffet's behaviour in relation to these Terms, you undertake:

  • to communicate them in the first instance:
    • to LessonBuffet only;
    • in sufficient detail;
    • through a channel made available by LessonBuffet for that purpose;

LessonBuffet undertakes:

  • to provide one or more channels for communications to LessonBuffet, which are convenient to users;
  • to promptly provide acknowledgement of the receipt of communications, including the provision of a copy of the communication, the date and time it was registered, and LessonBuffet's reference-code for the communication;
  • to promptly provide a response to the communication, in an appropriate and meaningful manner.

You further undertake to not pursue LessonBuffet through any Regulator or the media:

  • until and unless LessonBuffet has had a reasonable opportunity to respond to the initial communication; and
  • while LessonBuffet and you remain are conducting a meaningful dialogue about the matter.

Changes to These Privacy Undertakings

This privacy statement is subject to change without notice by LessonBuffet. LessonBuffet encourages you to periodically review this Statement to be informed of how LessonBuffet is protecting your information.

Definitions

LessonBuffet means LessonBuffet.com.
Your Data means data that is capable of being associated with you, whether or not it includes an explicit identifier such as your name or customer number. In particular, it encompasses all data that LessonBuffet is capable of correlating with you, using such means as server-logs and cookie-contents.

Your Data does not refer to data that can no longer be associated with you. This includes aggregated data that does not and cannot identify the individuals whose data are included in the aggregation.

Consent means your concurrence with an action to be taken by LessonBuffet. Consent may be express or implicit, but in either case must be informed and freely-given.

Note: This Privacy statement has been adopted from Xamax Consultancy Pty Ltd.
The original template can be located at: http://www.anu.edu.au/people/Roger.Clarke/DV/PST.html. The original template has been modified to use our name, to remove the enforcement section, and change the changes to these privacy undertakings sections.