Privacy Policy

1. Important Information and Who We Are

Purpose of This Privacy Notice

This privacy notice aims to give you information on how CDKW collects and processes your personal data through your use of this website and our services, including any data you may provide when you sign up for our services, subscribe to our newsletter, or participate in our programs.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.

Controller

CDKW Pty Ltd is the controller and responsible for your personal data. We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

Contact Details

Complaints

You have the right to make a complaint at any time to the Office of the Australian Information Commissioner (OAIC), the Australian supervisory authority for data protection issues (www.oaic.gov.au). We would, however, appreciate the chance to deal with your concerns before you approach the OAIC, so please contact us in the first instance.

Changes to Privacy Notice

This version was last updated on 22 July 2024. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-Party Links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements.

2. The Data We Collect About You

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, maiden name, last name, username or similar identifier, title, date of birth and gender.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

Children's Data

Our services are designed for use by children in educational settings. We collect limited personal data about children, including their first name and learning progress data. We do not knowingly collect sensitive personal data from children. Parents and guardians can contact us at any time to review, delete, or stop the collection of their child's personal information.

3. How is Your Personal Data Collected

We use different methods to collect data from and about you including through:

Direct Interactions

You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

• Apply for our products or services
• Create an account on our website
• Subscribe to our service or publications
• Request marketing to be sent to you
• Enter a competition, promotion or survey
• Give us feedback or contact us

Automated Technologies

As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.

Third Parties

We may receive personal data about you from various third parties including analytics providers, advertising networks, and search information providers.

4. How We Use Your Personal Data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal obligation.

Purposes for Using Your Data

We have set out below a description of the ways we plan to use your personal data:

• To register you as a new customer
• To process and deliver your order
• To manage our relationship with you
• To enable you to participate in promotions or complete a survey
• To administer and protect our business and website
• To deliver relevant website content and advertisements to you
• To use data analytics to improve our website, products, marketing, customer relationships and experiences
• To make suggestions and recommendations to you about goods or services that may be of interest to you

5. Disclosures of Your Personal Data

We may share your personal data with the parties set out below for the purposes set out in this privacy notice:

• Service providers acting as processors who provide IT and system administration services
• Professional advisers including lawyers, bankers, auditors and insurers
• Government bodies that require us to report processing activities
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International Transfers

We share your personal data within our group of companies. This will involve transferring your data outside Australia.

Many of our external third parties are based outside Australia so their processing of your personal data will involve a transfer of data outside Australia.

Whenever we transfer your personal data out of Australia, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
• Where we use certain service providers, we may use specific contracts approved for use which give personal data the same protection it has in Australia.

7. Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data Retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

9. Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data:

• Request access to your personal data (commonly known as a "data subject access request")
• Request correction of the personal data that we hold about you
• Request erasure of your personal data
• Object to processing of your personal data
• Request restriction of processing of your personal data
• Request transfer of your personal data to you or to a third party
• Withdraw consent at any time where we are relying on consent to process your personal data

If you wish to exercise any of the rights set out above, please contact us at hello@candokidsworldwide.com.

No Fee Usually Required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

Time Limit to Respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. Glossary

Lawful Basis

• Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience.
• Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
• Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Third Parties

• Internal Third Parties: Other companies in the CDKW group acting as joint controllers or processors.
• External Third Parties: Service providers acting as processors who provide IT and system administration services; Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers; Government regulators and other authorities acting as processors or joint controllers.

Your Legal Rights

Under Australian Privacy Principles (APPs) and the General Data Protection Regulation (GDPR) where applicable, you have the right to:

• Request access to your personal data
• Request correction of your personal data
• Request erasure of your personal data
• Object to processing of your personal data
• Request restriction of processing your personal data
• Request transfer of your personal data
• Right to withdraw consent