Privacy Policy – Toddle

1. Introduction

1.1 The Toddle online application (Web App) is owned by KN Enrol Pty Ltd ACN 618 980 706 (Toddle, we or us).

1.2 Toddle provides a service to assist in the enrolment of children at child care centres (Centres) through the Web App (Services).

1.3 In providing the Services, Toddle offers the Web App to parents/guardians (Parent, you or your) and Centres as a tool for:

  • Centres to communicate with Parents about the availability of child care places at a Centre;
  • Parents and Centres to communicate about enrolment of a child at a Centre; and
  • Parents to provide relevant information about a child to a Centre.

1.4 In order to provide the Services, Toddle requires certain information to be provided by Parents and Centres, the treatment of which is covered under this Privacy Policy. Further information about the Services is set out in Toddle’s Terms and Conditions.

1.5 In this Privacy Policy:

  • Personal information is any information about a person where their identity is apparent, or can reasonably be ascertained, and includes Sensitive Information (Personal Information).
  • Sensitive Information is information or an opinion about a person’s racial or ethnic origin, political opinions, membership of a political association, religious beliefs or affiliations, philosophical beliefs, sexual preferences, health or medical information or criminal records (Sensitive Information).
  • A reference to Personal Information in this Privacy Policy is also a reference to Sensitive Information.

2. What this Policy is about

2.1 This Policy explains the key measures we have taken to implement the requirements of the Privacy Act 1988 and the Australian Privacy Principles. Toddle is committed to ensuring that you and your child’s privacy is protected. This Privacy Policy describes how Toddle collects, uses, discloses and stores Personal Information that is provided by Centres to Toddle and generated by your use of the Web App.

2.2 We endorse fair information handling practices and use of information in compliance with our obligations under the privacy laws in force in Australia from time to time. Any information provided, including identification of individuals, will be used only for the purpose/s intended or authorised and where the intention includes confidentiality, information will be treated as such unless otherwise required by law.

2.3 This Policy represents the default position that Toddle will take in its treatment of Personal Information. Toddle will treat all Personal Information in a manner consistent with this Policy unless you (either directly or through a Centre) have provided your express consent otherwise.

3. Collection of Personal Information

3.1 We collect only the Personal Information that is reasonably necessary for us to provide the Services.

3.2 Personal Information may be collected:

  • directly from you via the Web App;
  • when a Centre provides information to Toddle for the purposes of enabling Toddle to provide the Services; and
  • when a Centre provides information to Toddle for the purposes of the Centre providing services to you.

3.3 Where Personal Information is collected from a Centre, Toddle requires the Centre to have obtained the consent of the Parent for the collection, use, and disclosure of Personal Information by Toddle as a service provider to the Centre. Toddle cannot ensure the accuracy of Personal Information provided by the Centre.

3.4 Personal Information collected by Toddle will primarily include:

  • name of Parent and child, address and contact details (for example, email, phone and fax number);
  • information about a child’s identity (for example, gender and date of birth);
  • government identifiers (for example, Tax File Numbers and Customer Reference Numbers) – for Parents and child;
  • financial information (for example, credit or debit card details); and
  • information about the days a child will be attending a Centre, including the child’s starting date.

3.5 Sensitive Information collected by Toddle may include:

  • health information (for example, medical history, immunisations, allergies, special needs, disabilities or injuries) – for Parents and child;
  • ethnic or racial origin – for Parents and child;
  • and could extend to other categories of information designated as sensitive information under the Privacy Act 1988.

4. Use of Personal Information

4.1 By using the Web App, you consent to Toddle’s use of your and your child’s Personal Information in accordance with this Policy.

4.2 Toddle may use your Personal Information for the following purposes:

  • facilitating the provision of services by Centres to you;
  • providing Services to Parents and Centres and conducting our business;
  • the operation, administration, development or enhancement of the Web App;
  • research, planning, product and service development and security and testing (including in relation to the Web App); and
  • any other purposes required or authorised by law or for which you have (either directly or through a Centre) provided specific consent.

4.3 Toddle may use your Personal Information (i.e. your contact details including name, address, phone number and email address) to direct market to you and may also provide your Personal Information to third party organisations for their direct marketing purposes. A Parent will always have the option to ‘opt out’ of receiving direct marketing materials from Toddle and third party organisations in each direct marketing communication.

4.4 A Parent may request Toddle not to use or disclose your Personal Information for the purpose of direct marketing or to facilitate direct marketing by other third party organisations. Toddle will give effect to any such request within a reasonable period of time and at no cost.

5. Disclosure of Personal Information

5.1 The parties we may share Personal Information with are employees, subcontractors, suppliers and affiliates of Toddle on a need to know basis. Access to Personal Information will be revoked within a reasonable timeframe of access no longer being required.

5.2 Occasionally, Toddle may also use Personal Information for other purposes or share Personal Information with an organisation because:

  • we believe it is necessary to protect the rights, property or personal safety of a Parent or child;
  • we believe it is necessary to do so to prevent or help detect fraud or serious credit infringements - for example, we may share information with other credit reporting agencies, law enforcement agencies and fraud prevention units; or
  • we believe it is necessary to protect the interests of Toddle – for example, disclosure to a Court in the event of legal action to which Toddle is a party;

5.3 As set out in clause 4.3 of this Policy, Toddle may also disclose Personal Information to third party organisations for their direct marketing purposes.

5.4 When we share information with other organisations and service providers as set out above, we do so in accordance with this Policy. To the extent that these organisations and service providers gain access to Personal Information, their use is governed by the rules set out in the Privacy Act 1988.

6. Cookies

6.1 We wish to provide Parents with a positive user experience. To do so, Toddle may use ‘cookies’ to collect information through our websites (www.Toddle.com) and the Web App. 'Cookies' are alphanumeric identifiers that are stored by the web browser on a computer's hard-drive that enable our system to recognise a visitor to the website or the Web App.

6.2 Cookies help Toddle to track basic visitor information on our websites for the purposes of optimising the design of our systems and optimising our marketing activities. We may also use memory-based cookies in support of authenticating the user of the Web App. If you are a registered user of the Web App, we may use cookies so we can provide you with personalised information based on preferences you have indicated by using the Web App.

6.3 Most web browsers automatically accept cookies and this function can be disabled by changing the browser settings of the user. However, if you reject cookies you may not be able to utilise Toddle services that require registration.

7. Confidentiality and Data Security

7.1 The Web App has been built with modern, best-practice web development methods, with security a foremost consideration. Personal Information collected is stored on secure servers in Australia. Toddle will not transfer any Personal Information overseas.

7.2 We take all reasonable steps to manage data stored on our servers to ensure data security and to prevent the loss, misuse or alteration of Personal Information.

7.3 Physical, electronic, and procedural safeguards have been implemented in order to protect Personal Information, however, although we take all care to respect and protect Personal Information, we will not accept any responsibility for any unauthorised use.

8. Retention and Disposal of Personal Information

8.1 We will retain the Personal Information of Parents and their child for as long as is required to provide the Services and to comply with legal requirements.

8.2 If we no longer require Personal Information for any purpose, including legal purposes, we will take reasonable steps to securely destroy or permanently de-identify the Personal Information.

8.3 Personal Information is backed up frequently and tested regularly in line with Toddle’s standard backup procedures. Personal Information that has been deleted may therefore persist within backups for a period of time after which it falls outside the backup rotation.

9. Access to Personal Information

9.1 A Parent can access the Personal Information held about them or their child at any time. You may contact us to make a request at help@toddle.com.

9.2 We will always endeavour to meet requests for access. However, in some circumstances we may decline a request for access. This includes the following circumstances:

  • we no longer hold or use the information;
  • providing access would have an unreasonable impact on the privacy of other persons;
  • the request is frivolous or vexatious;
  • the information relates to existing or anticipated legal proceedings and would not normally be disclosed as part of those proceedings;
  • providing access would be unlawful;
  • providing access would be likely to prejudice the detection, prevention, investigation and prosecution of possible unlawful activity; and
  • the information would reveal a Centre’s commercially sensitive information.

9.3 If we decline a request for access, we will provide reasons for our decision when we respond to the request.

9.4 We reserve the right to charge Parents a reasonable fee for access to you or your child’s Personal Information. These charges will be limited to the cost of recouping our expenses for providing the Personal Information, such as document retrieval, photocopying, labour and delivery.

10. Changing or deleting Personal Information

10.1 We will take reasonable steps to ensure that Personal Information is accurate, complete and up-to-date at the time of collecting the Personal Information from a Parent or a Centre, using or disclosing the Personal Information, or during other interactions with the Parent or the Centre.

10.2 If you otherwise believe that any Personal Information we hold about you or your child is inaccurate, you may contact us to make a request at help@toddle.com. We will do our best to correct the Personal Information or dispose of it in accordance with this Policy.

11. Contact Information and Changes to Privacy Policy

11.1 If you have any further queries relating to Toddle’s Privacy Policy or wish to make a complaint in relation to the way Personal Information has been handled by Toddle, please contact us at help@toddle.com. If Toddle becomes aware of any ongoing concerns or problems with a Parent or their child’s Personal Information, we will take these issues seriously and work to address these concerns.

11.2 From time to time, our policies will be reviewed and may be revised. Toddle reserves the right to change this Policy at any time.

Last reviewed: September 2017