The purpose of this Privacy Policy is to describe how Alto Education Pty. Ltd. ("Alto," "us," "we," or "our") collects, uses, and shares information about you through our online interfaces (e.g., websites and mobile applications) owned and controlled by us, including but not limited to alto-education.com(referred to from now on as the "Site"). Please read this Privacy Policy carefully to understand what we do. If you do not understand any aspects of our Privacy Policy, please feel free to contact us at abohac@alto-education.comYour use of our Site is also governed by our Terms of Use. Terms used but not defined in this Privacy Policy can be found in our Terms of Use.
Alto Education Pty. Ltd. is a private company registered in Victoria, Australia with a principal place of business at 12 Mark St, North Melbourne, VIC 3051, Australia. If you reside or are located in the European Economic Area ("EEA") Alto is the data controller of all Personal Data (as defined below) collected via the Site or our products or service and of certain Personal Data collected from third parties, as set out in this Privacy Policy.
This Privacy Notice covers information we collect from you through our Site. Some of our Site’s functionality can be used without revealing any Personal Data, but for features or services related to our courses, Personal Data are required. In order to access certain features and benefits on our Site, you may need to submit, or we may collect, "Personal Data" (i.e., information that can be used to identify you and which may also be referred to as “personally identifiable information” or “personal information”). Personal Data can include information such as your name, email address, IP address, and device identifier, among other things. You are responsible for ensuring the accuracy of the Personal Data you submit to Alto. Inaccurate information may affect your ability to use the Site, our products or services, the information you receive when using our products, services or the Site, and our ability to contact you. For example, your email address should be kept current because that is one of the primary ways in which we communicate with you.
We consider that the legal bases for using your personal information as set out in this Privacy Policy are as follows:
Which legal basis applies to a specific activity will depend on the type of personal information used and the context in which it is being used.
If we rely on our (or another party’s) legitimate interests for using your personal information, we will undertake a balancing test to ensure that our (or the other party’s) legitimate interests are not out weighed by your interests or fundamental rights and freedoms which require protection of the personal information.
We may process your personal information in some cases for marketing purposes on the basis of your consent (which you may withdraw at any time as described below).
If we rely on your consent for us to use your personal information in a particular way, but you later change your mind, you may withdraw your consent by contacting us on abohac@alto-education.com at any time. If you withdraw your consent, this may impact the ability for us to provide some of our services or products to you.
We gather two types of information about users through the Site:
If you participate in a service or a product, we may collect certain user-generated content, such as assignments you submit, peer-graded assignments, and peer grading feedback. We also collect course data, such as responses to quizzes, exams, and surveys. You should not include any Personal Data or other information of a personal or sensitive nature, whether relating to you or another person, on assignments, exams, or surveys, except for information required to participate in or submit such assignments, exams, or surveys.
Additional information collected
Audio Recording and Data Usage
Audio Recording:
Our app utilizes the android.permission.RECORD_AUDIO permission to allow users to interact with the app using their voice. This feature enables users to speak, which is then translated into text for processing by the OpenAI GPT model. The primary purpose of this audio recording is to provide an interactive AI coaching experience. We do not use audio recordings for any purpose other than to facilitate this interaction.
Data Storage and Security: The transcribed text from your audio recordings is securely stored in Firebase and is associated with each user's profile. We take the security of your data seriously and implement appropriate measures to protect it against unauthorised access or use. Please note that while we store the text data, the audio recordings themselves are not retained beyond the necessary duration for transcription.
User Consent: By using our app, you consent to the audio recording and data processing as described above. You have the option to opt-in or opt-out of the audio recording feature. We respect your privacy and provide you with the ability to control your data. You can request access to or deletion of your data at any time.
Compliance and Updates: We are committed to complying with applicable laws and regulations regarding data privacy and protection. This section of the privacy policy may be updated as necessary, and we will notify you of any significant changes.
Contact Us: If you have any questions or concerns about our use of audio recordings and data, please do not hesitate to contact us.
For your convenience we may provide links to sites operated by organisations other than Alto ("Third Party Sites") that we believe may be of interest to you. We do not disclose your Personal Data to these Third Party Sites unless we have a lawful basis on which to do so. We do not endorse and are not responsible for the privacy practices of these Third Party Sites. If you choose to click on a link to one of these Third Party Sites, you should review the privacy policy posted on the other site to understand how that Third Party Site collects and uses your Personal Data.
We keep your Personal Data for no longer than necessary for the purposes for which the Personal Data are collected and processed. The length of time we retain Personal Data for depends on the purposes for which we collect and use it and/or as required to comply with applicable laws and to establish, exercise, or defend our legal rights.
We will use standard physical, technical, and administrative security measures to keep your Personal Data confidential and secure, and will not share it with third parties, except as otherwise provided in this Privacy Policy, or unless such disclosure is necessary in special cases, such as a physical threat to you or others, as permitted by applicable law. Because the Internet is not a 100% secure environment, we cannot guarantee the security of Personal Data, and there is some risk that an unauthorized third party may find a way to circumvent our security systems or that transmission of your information over the Internet will be intercepted. It is your responsibility to protect the security of your login information. Please note that e-mail communications are typically not encrypted and should not be considered secure.
You have certain rights in relation to your Personal Data. You can access your Personal Data and confirm that it remains correct and up-to-date, choose whether or not you wish to receive material from us or some of our partners, and request that we delete or provide you with a copy of your personal data by contacting us on abohac@alto-education.com.
If you would like further information in relation to your rights or would like to exercise any of them, you may also contact us via abohac@alto-education.com.
If you reside or are located in the EEA, United Kingdom, Switzerland, or other region that offers similar protections, you have the right to request that we:
We try to answer every request promptly where possible, and provide our response within the time period stated by applicable law. Keep in mind, however, that when deleting your Personal Data there may be residual information that will remain within our databases, access logs, and other records, which may or may not contain your Personal Data. Please also note that certain Personal Data may be exempt from such requests in certain circumstances, which may include if we need to retain your Personal Data to comply with a legal obligation. When you email us with a request, we may ask that you provide us with information necessary to confirm your identity.
If you have any privacy-related questions, suggestions, unresolved problems, or complaints, you may contact us via abohac@alto-education.com.
If you reside or are located in the EEA, United Kingdom, Switzerland, or other region that offers similar protections, you may also make a complaint to our supervisory body for data protection matters (namely the UK Information Commissioner's Office or Dutch Autoriteit Persoonsgegevens) or seek a remedy through local courts if you believe that your rights have been breached.
Our Sites are operated and managed on servers located and operated by globally distributed services. In order to provide our products and services to you, you may be sending your Personal Data outside of the country where you reside or are located. Accordingly, if you reside or are located outside of Australia, your Personal Data may be transferred outside of the country where you reside or are located, including to countries that may not or do not provide the same level of protection for your Personal Data. We are committed to protecting the privacy and confidentiality of Personal Data when it is transferred.
Please note that we review our privacy practices from time to time, and that these practices are subject to change. Any change, update, or modification will be effective immediately upon posting on our Site. We will notify you of any material change to this Privacy Policy by posting a notice on our Site’s homepage for a reasonable period of time following such update or by sending an email to the email address associated with your user account, and by changing the effective date. Be sure to return to this page periodically to ensure familiarity with the most current version of this Privacy Policy.
Alto strongly believes in protecting the privacy of children. Any use or access by anyone under the age of 13 is prohibited. Inline with this belief, we do not knowingly collect or maintain Personal Data on our Site, products or services from persons under 13 years of age, and no part of our Site is directed to persons under 13 years of age. If you are under 13years of age, then please do not use or access this Site at any time or in any manner. We will take appropriate steps to delete any Personal Data of persons less than 13 years of age that has been collected on our Site, products or services without verified parental consent upon learning of the existence of such Personal Data.