Privacy policy

Crystal Delta PTY.LTD. respect and value the privacy of everyone who visits this website, www.xen.education (“Our Site” or “Site”), the Xen.Ed platform (“Our Platform”) and uses the offered services (“Our Services” or “Services”) and will only collect and use Personal Data in ways that are described here, and in a way that is consistent with our obligations and your rights under all relevant data privacy laws.

Please read this Privacy Policy carefully and ensure that you understand it. Regardless of what type of user you are as described below Tenancy Administrator/User, End User and/or Site Visitor, this Privacy Policy creates a legal agreement directly between you and Us and explain the rules governing use of the Platform, Service and Site. If you do not agree with and accept this Privacy Policy, do not access or use our Site and/or Platform or any other aspect of Our business. You will be required to read and accept this Privacy Policy when signing up for a trial account to use Our Platform.

We may, from time to time, modify this Privacy Policy. Please check this web-page periodically for updates. We will comply with applicable legal obligations to provide you with relevant notice of changes to this Privacy Policy. Your continued use of the Site, the Platform and Services after any such update constitutes your acceptance of such changes.

If you have additional questions or require more information about our Privacy Policy, do not hesitate to contact us at support@xen.education.

This Privacy Policy applies only to our online activities and the Xen.Ed platform, and is valid for visitors to our website with regards to the information that they shared and/or collect in xen.education. This policy is not applicable to any information collected offline or via channels other than this website and the Xen.Ed platform.

Consent

By using our website, you hereby consent to our Privacy Policy and agree to its terms.

Information we collect

The personal information that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point we ask you to provide your personal information.

If you contact us directly, we may receive additional information about you such as your name, email address, phone number, the contents of the message and/or attachments you may send us, and any other information you may choose to provide.

When you register for an Account, we may ask for your contact information, including items such as name, company name, address, email address, and telephone number.

(i) Tenancy Administrator/User

If you are or represent a User that utilises Our Platform to create, edit and host a Tenancy, please see below our legal basis and learn how we process your Personal Data.

When a User tries, subscribes or uses Our Platform and Services and obtains support for the above under an agreement with Us, We receive data from the User and collect and generate data based on Our legitimate interest to provide the requested Services (including improving, securing, and updating the Service), conduct our business operations, and communicate with the User, carry out business development and marketing activities and for administrative and auditing purposes.

The Personal Data provided by the User may include:

• Full name;
• E-mail;
• Financial information when you make a subscription (account details, payment information);
• Identifiable IT information (IP addresses, usage data, cookies data, online navigation data, browser data);
• Telephone number;
• Business name;
• Recurring payment information.

The Personal Data we collect while you use our Product and Services include:

• Web browser type and version;
• Operating system;
• A list of URLs starting with a referring site, your activity on Our Site, and the site you exit to;
• Number of log-ins.

(ii) End User

If you are an End User of a Tenancy, please see the terms and conditions and privacy policy of the relevant Tenant and direct your privacy inquiries, including any requests to exercise your data protection rights, to the Tenancy’s Administrator. We are not responsible for the privacy or security practices of our Tenancies, which may differ from those set forth in this privacy policy. However, we process your Personal Data and act as data processors to the Tenancy Administrator that is the data controller, with whom you have entered into an agreement with.

The Personal Data provided by the End User may include:

• Name.
• Email Address.
• Other custom form fields and profile information (occupation or other demographic information, address, job title) subject to the Tenancy set-up.
• End-user’s personal interests or preferences (including purchase history, marketing preferences and publicly available social media profile information subject to the Tenancy set-up.

The Personal Data we collect while you use our Product and Services may include:

• Identifiable IT information (IP addresses, usage data, cookies data, online navigation data, browser data).
• Number of log-ins.
• Webpages visited.
• Activity on the said Online School.

If you use a Tenancy Account you can:

• Control and administer your Account, including controlling privacy-related settings.
• Access and process your Personal Data, including the interaction data and the contents of your communications and files associated with your account in the Online School.
• Access and process your End User’s Personal Data as provided by them to offer the agreed services.

When you use a Tenancy, the processing of your Personal Data in connection with that Tenant is governed by an agreement between Crystal Delta and the respective Tenant who administrates the Tenancy. Crystal Delta processes your Personal Data to provide its Services to your Tenancy Administrator and you.

For Xen.Ed Platform and Services provided by an Tenancy Administrator to minors, Crystal Delta will:

not collect or use such Personal Data beyond that needed for authorised operational purposes and to provide the relevant Services;

not sell or rent such Personal Data;

not use or share such Personal Data for advertising or similar commercial purposes, such as behavioural targeting of advertisements to minors;

not build a personal profile of a minor, other than for supporting authorised educational or learning purposes or as authorised by the parent or guardian; and

require that our Tenants with whom minors’ Personal Data is shared to deliver the Service, if any, are obligated to implement these same commitments for such Personal Data.

(iii) Site Visitors

When you visit our Site the following information may be collected: your IP address, which browser version you use, time of your visit, how you use Our website and information about your device (e.g. geographical location, operating system, host name of accessing computer). For details, please read our Cookie Policy below under Part 13.

The above mentioned data does not contain additional Personal Data, and cannot be assigned to specific persons.

You may choose to voluntarily submit your Personal Data by filling in the form(s) on our website (e.g. registration for a free trial). Such information shall consist of your email address, full name, and address of operation.

How we use your information

We use the information we collect in various ways, including to:

• Provide, operate, and maintain our website
• Improve, personalise, and expand our website
• Understand and analyse how you use our website
• Develop new products, services, features, and functionality
• Communicate with you, either directly or through one of our partners, including for customer service, to provide you with updates and other information relating to the website, and for marketing and promotional purposes
• Send you emails
• Find and prevent fraud

Log Files

Crystal Delta follows a standard procedure of using log files. These files log visitors when they visit websites. All hosting companies do this and a part of hosting services’ analytics. The information collected by log files include internet protocol (IP) addresses, browser type, Internet Service Provider (ISP), date and time stamp, referring/exit pages, and possibly the number of clicks. These are not linked to any information that is personally identifiable. The purpose of the information is for analysing trends, administering the site, tracking users’ movement on the website, and gathering demographic information.

Cookies and Web Beacons

Like any other website, Crystal Delta uses ‘cookies’. These cookies are used to store information including visitors’ preferences, and the pages on the website that the visitor accessed or visited. The information is used to optimise the users’ experience by customising our web page content based on visitors’ browser type and/or other information.

Advertising Partners Privacy Policies

You may consult this list to find the Privacy Policy for each of the advertising partners of Crystal Delta.

Third-party ad servers or ad networks uses technologies like cookies, JavaScript, or Web Beacons that are used in their respective advertisements and links that appear on Crystal Delta, which are sent directly to users’ browser. They automatically receive your IP address when this occurs. These technologies are used to measure the effectiveness of their advertising campaigns and/or to personalise the advertising content that you see on websites that you visit.

Note that Crystal Delta has no access to or control over these cookies that are used by third-party advertisers.

Third Party Privacy Policies

Crystal Delta’s Privacy Policy does not apply to other advertisers or websites. Thus, we are advising you to consult the respective Privacy Policies of these third-party ad servers for more detailed information. It may include their practices and instructions about how to opt-out of certain options. You may find a complete list of these Privacy Policies and their links here: Privacy Policy Links.

You can choose to disable cookies through your individual browser options. To know more detailed information about cookie management with specific web browsers, it can be found at the browsers’ respective websites. What Are Cookies?

CCPA Privacy Rights (Do Not Sell My Personal Information)

Under the CCPA, among other rights, California consumers have the right to:

Request that a business that collects a consumer’s personal data disclose the categories and specific pieces of personal data that a business has collected about consumers.

Request that a business delete any personal data about the consumer that a business has collected.

Request that a business that sells a consumer’s personal data, not sell the consumer’s personal data.

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us.

GDPR Data Protection Rights

We would like to make sure you are fully aware of all of your data protection rights. Every user is entitled to the following:

The right to access – You have the right to request copies of your personal data. We may charge you a small fee for this service.

The right to rectification – You have the right to request that we correct any information you believe is inaccurate. You also have the right to request that we complete the information you believe is incomplete.

The right to erasure – You have the right to request that we erase your personal data, under certain conditions.

The right to restrict processing – You have the right to request that we restrict the processing of your personal data, under certain conditions.

The right to object to processing – You have the right to object to our processing of your personal data, under certain conditions.

The right to data portability – You have the right to request that we transfer the data that we have collected to another organisation, or directly to you, under certain conditions.

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us.