Privacy notice

Last updated 8 January 2019

This privacy notice tells you how we, Yes Club Group, will collect and use your personal data to provide our service which allows educators, of any kind, to create a private space online, filled with tools that easily create courses and activities, all optimised for collaborative learning.

Personal data

Under the EU’s General Data Protection Regulation (GDPR) personal data is defined as: “any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.

Will Yes CLub Group share my personal data with anyone else?

We may pass your personal data on to third-party service providers contracted to Yess CLub Group in the course of dealing with you. We do this because there are some services, such as our video conferencing facility, which will not work unless we are able to make these transfers. Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to deliver the service they provide on our- and of course, your-behalf. When they no longer need your data to fulfil this service, they will dispose of the details in line with Yes CLub Group’s procedures. If we wish to pass your sensitive personal data onto a third party we will only do so once we have obtained your consent, or if it is necessary to comply with an employment contract, unless we are legally required to do otherwise. If you would like an up-to-date register of all our third-party service providers, please contact admin@yesclubgroup.com and we will be happy to provide it.

How will Yes Club Group use the personal data it collects about me?

Yes Club Group will process (collect, store and use) the information you provide in a manner compatible with the EU’s General Data Protection Regulation (GDPR). We will endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary. Yes Club Group maintains a register of its data processes which includes a record of the data retention policy for each type of data collected and is committed to only ever trying to process the minimum amount of data needed. Yes Club Group is required to retain certain information in accordance with the Law, such as information needed for income tax and audit purposes. How long certain kinds of personal data should be kept may also be governed by specific business-sector requirements and agreed practices. Personal data may be held in addition to these periods depending on individual business needs.

Can I find out the personal data that the organisation holds about me?

Yes Club Group at your request, can confirm what information we hold about you and how it is processed. If Yes Club Group does hold personal data about you, you can request the following information:

  • Identity and the contact details of the person or organisation that has determined how and why to process your data.
  • Contact details of our data protection officer in the EU, where applicable.
  • The purpose of the processing as well as the legal basis for processing.
  • If the processing is based on the legitimate interests of Moodle Pty Ltd or a third party, information about those interests.
  • The categories of personal data collected, stored and processed.
  • Recipient(s) or categories of recipients that the data is/will be disclosed to.
  • If we intend to transfer the personal data to a third country or international organisation, information about how we ensure this is done securely. The EU has approved sending personal data to some countries because they meet a minimum standard of data protection. In other cases, we will ensure there are specific measures in place to secure your information. These will rely on measures approved by the EU Commission.
  • How long the data will be stored.
  • Details of your rights to correct, erase, restrict or object to such processing.
  • Information about your right to withdraw consent at any time.
  • How to lodge a complaint with the supervisory authority.
  • Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
  • The source of personal data if it wasn’t collected directly from you.
  • Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.

What forms of ID will I need to provide in order to access this?

Yes Club Group accepts a request made through a edu.yesclubgroup.com account while the person making the request is logged in. In certain circumstances Yes Club Group could ask for additional information and the following forms of ID when information on your personal data is requested:

  • A colour copy of a Passport, driving licence or National ID Card

DATA POLICY

  1. ScopeAll data subjects whose personal data is collected, in line with the requirements of the GDPR.
  2. ResponsibilitiesAll data subjects whose personal data is collected, in line with the requirements of the GDPR.
    • 2.1 Where Yes Club Group is hosting a website on its own behalf, it is the Data Controller for all the data collected. Where Moodle Pty Ltd is hosting someone else’s installation of the Moodle Platform (as with MoodleCloud) it is the Data Processor for the Site Admin for that installation.
    • 2.2 When Moodle Pty Ltd is not hosting an installation of the Software Platform, it is neither the Data Controller or the Data Processor and those duties fall on the people or organisations who have installed and are hosting those installations.
  3. Privacy notice
  • 3.1 Who are we?Moodle Pty Ltd is a software company which allows educators, of any kind, to create a private space online, filled with tools that easily create courses and activities, all optimised for collaborative learning. The Moodle software is open source, and may be hosted by Moodle, but also by anyone who wishes to manage an installation.We collect personal data relating to you for specific purposes, with the nature of the data collected depending on your interaction with Moodle Pty Ltd. We are committed to transparency in this and have provided a very detailed breakdown of these processes in Annex 1 at the end of this document.Our legal basis for processing for personal data:
      • Article 6.1(a), GDPR, Consent
      • Article 6.1(b), GDPR, Contract
      • Article 6.1(f), GDPR, Legitimate Interest
    Any legitimate interests pursued by us, or third parties we use, are as follows:
      • Recruitment and Induction of new Candidates
      • Emergency Contacts for people who work with us, such as employees and Contractors for Health and
        Safety purposes.
      • Business Development
      • Providing login systems to users via their existing social media accounts
    The special categories of personal data concerned are:
      • Biometric Data in the form of facial images
      • Health Data in respect of employees, Contractors and other people who work with us
      • Any special categories of special personal data which any user volunteers while using the Moodle systems or any Moodle website- for example in a forum or submission
    3.2 ConsentBy consenting to this privacy notice you are giving us permission to process your personal data specifically for the purposes identified. Where consent is required for Moodle Pty Ltd to process both standard and sensitive types of personal data, but it must be explicitly given. Where we are asking you for sensitive personal data we will always tell you why and how the information will be used. Agreement with this Privacy Notice and its accompanying Terms and Conditions (as applicable) (and any Data Processing Agreements, if they apply to you) will be considered to be explicit consent and we will keep a copy of the records of that consent for audit purposes.You may withdraw consent at any time by:Please identify your role in relation to Moodle (if you are a Contractor, Staff member, Moodle Partner, End-user, Site Admin etc.), and the data you wish to withdraw consent to be processed.

  • 3.3 DisclosureMoodle Pty Ltd will pass on your personal data to certain third parties. Moodle is a distributed, global company and it uses cloud services which may be accessed by Moodle employees in any part of the world, including our Head Office in Australia.The Moodle Software platform is open source, so that anyone can install and host a copy of the software, as the data controller. In those circumstances, it will be a matter for the Data Controller to ensure they have also put the necessary safeguards in place for any international transfers outside the EU.Third country (non-EU)/international organisationSafeguards in place to protect your personal dataMoodleCloud: Australia, GlobalUse of the EU’s Standard Contract Clauses, Privacy Shield, and binding corporate rulesOther Moodle Sites and servicesUse of the EU’s Standard Contract Clauses, Privacy Shield, and binding corporate rulesOther Moodle installations, not hosted by Moodle Pty Ltd or additional processing of data from MoodleCloud by the Data ControllerTo be provided directly to you by the Data Controller for that installation.
  • 3.4 Retention periodMoodle Pty Ltd will processes different forms of personal data for as long as is necessary and proportionate for the purpose for which it has been supplied and will store the personal data for the shortest amount of time possible, taking into account legal and service requirements. For further details on the retention period for any particular type of data, please contact privacy@moodle.com
  • 3.5 Your rights as a data subjectAt any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:
    • Right of access – you have the right to request a copy of the information that we hold about you.
    • Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
    • Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
    • Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
    • Right of portability – you have the right to have the data we hold about you transferred to another organisation.
    • Right to object – you have the right to object to certain types of processing such as direct marketing.
    • Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.
    • Right to judicial review: in the event that Moodle Pty Ltd refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined in clause 3.6 below.
    Where Moodle Pty Ltd are your Data Controller, you may make a request directly to the Data Protection Officer using the email address dpo@moodle.comWhere Moodle Pty Ltd are a Data Processor, and act on behalf of a data controller (such as MoodleCloud) any requests received by Moodle Pty Ltd will be passed on to the Data Controller.Where Moodle Pty Ltd are not involved with your data, such as where the Moodle platform has been self-hosted, you should address your requests to the data controllers of those sites. Moodle Pty Ltd will have no access to your data.
  • 3.6 ComplaintsIn the event that you wish to make a complaint about how your personal data is being processed by Moodle Pty Ltd (or third parties as described in 3.4 above), or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and Moodle Pty Ltd’s data protection Officer, Data Compliance Europe Ltd.If you wish to make a complaint about how your personal data has been processed in MoodleCloud, or by a Self-Hosted installation of the Moodle Software you should contact your Moodle Site Admin or the Data Controller for your Moodle installation. (For example, if your university or school hosts their own Moodle site, they will be the Data Controller).The details of Contacts for where Moodle Pty Ltd’s are the Data Controller:Supervisory authority contact detailsData Protection Officer (DPO) / GDPR Owner contact detailsContact Name:Data Protection CommissionerData Compliance Europe,Address line 1:Canal HouseLower Bridge StreetAddress line 2:PortarlingtonDublin 8Address line 3:Co LaoisAddress line 4:R32 AP23Email:info@dataprotection.iedpo@moodle.comTelephone:+353 57 8684800The details of Contacts for where Moodle Pty Ltd is not the Data Controller, in your installation of Moodle, are available directly from your Data Controller.

Annex 1

Purpose of processingCategories of personal dataThe source of the personal data
sending e newsletters to moodle.com usersemail address, nameData subject
sending e newsletters to moodle.org usersemail address, nameData subject
Attendee registrations and payment for moodlemoot.orgemail address, name, payment detailsData subject
Presentation admission process run by Marketing department for moodle moot’s eventsemail address, name, workplace, summary of applicable presentationsData subject
Communicating marketing campaigns on Facebookname, email address, location, job title, interests, any other Facebook categories usedData subject
Communicating marketing campaigns on Twittername, email address, location, interestsData subject
MOOC participants information (Learn Moodle)name, email addressData subject
RecruitmentName, Address, phone number, email, social media profile links, Photograph, educational and work history, interestsCandidate
RecruitmentContact detailsCandidate
On-boardingContact details, emergency contact details, drivers licence, passport, id documents, banking details, tax details, superannuation details, gender, qualifications, biometric data, date of birthEmployees
Health and SafetyName, phone number, email, relationship with EmployeeEmployees
HR RecordsHealth RecordsEmployees
On-boardingContact details, emergency contact details, drivers licence, passport, ID documents, banking details, gender, qualifications, biometric data
Employees
On-boardingTelephone numberTeam Members
Performance
Performance information, contact detailsManagers/HR
EngagementContact details, job information, engagement informationEmployees/HR
Letter of OfferName, address, phone number, email and remuneration detailsEmployees/HR
Confirmation of InformationContact details, remuneration details, length of service, job informationEmployees, HR
Exit interviewsContact details, feelings about working at MoodleEmployees
On-boardingPhotographEmployees
InterviewAnswers to questions around previous job and skillsMoodle HR
Central code repositorycontact details (name, surname, email, photo), activity and contributionData subject
Community education and feedback (moodle.org)contact details (name, surname, email, photo), activity and contributionData subject
Mirror of central code repositorycontact details (name, surname, email, photo), activity and contributionData subject
Developer code repositorycontact details (name, surname, email, photo), activity and contributionData subject
Developer code repository (Local git repositories on dev machines)contact details (name, surname, email, photo), activity and contributionData subject
Sharing of rapid prototypes, research artefacts, usability testing feedbackContact details, activity, contributionEmployee
Conduct user studies, interviews, and surveysContact details, activity, contributionEmployee
Conduct user surveys, Mobile – Support for Airnotifier websitesContact details, form entries,Data subject
Scheduler for usability testing & user interviewsName, email, Contact details, schedules, location dataData Subject, Employees
Hosts the usability tests and user interview recordingsContact details, biometric, video, voice recording,Data Subject, Employees
Community engagement & recruitment for user studiesContact details, activity, contributionData Subject, Employees
Community engagement & recruitment for user studiescontact details (name, surname, email, photo), activity and contribution
MOBILE – Training in Moodlemootscontact details (name, surname, email, photo), activity and contributionData subject
Paying wages to employeesContact details (name, surname and email), Bank details, Tax details, sick leave, Annual Leave, salary, pensionEmployee
Collecting fees payable by direct clientsContact details (name, surname and email)Client
Collecting fees payable by partnersContact details (name of partner, email, name and surname of partner representative)Partner
Receiving event registration feeContact details (name, surname, email of the participant, phone number, business name and address)Attendee
Paying supplier invoicesSupplier details (name, surname, email, bank details)Attendee
Individual’s Profile on Moodle Partner siteContact detailsData subject and data subject employer
Individual’s data on Moodle Partner websiteUser and activity dataData subject, Controller
Partner Marketing SupportPartner details, Location, Date, TimesData subject
Partner Marketing SupportClient details, Partner detailsData subject, data subject employer, Partner organisation
Partnership support conference callsName, Voice Recording, Video/Photograph of userMoodle HQ – Moodle Partner website Data
Partner Organisation Profile on Moodle Partner siteUser details, Partner Organisation detailsPartner Organisation provides info and manages it
Partnership team commercial discussion about Partners and sectorsHQ Organisation details, Partner Organisation details, names, emails, addressesController(s) – Moodle Pty Employees (Moodle HQ) and for contractors ->themselves or company.
Partnership team discussionPartner Organisation detailsController(s) – Moodle Pty Employees (moodle HQ) and for contractors ->themselves or company.
Moodle HQ team communicationsContact details and any other as comes up in emailsController
Moodle HQ team communicationsContact detailsController
Moodle Client Customer financial data from PartnersClient details, Partner detailsMoodle Partner
Moodle Client Customer financial data from PartnersClient details, Partner detailsMoodle Partner
Lead / Customer InformationContact DetailsData Subject
writing and storage of agreements/contracts/documentation with partners, and potential partnersContact detailsMoodle Partner / Applicant
General Business Documentation of meetings including attendeesPartner Organisation details, Partner details, Partner EmployeesController
General Business DocumentationPartner Organisation details, Partner detailsController
General Business DocumentationPartner Organisation details, Partner detailsController
log storing and searching for analysing and troubleshooting MoodleCloud sites and signup/provisioningLocation, IP addressMoodleCloud site admins and MoodleCloud site users
Storing of historical logs – moodle, web server, statisticswebsite name, location, IP addressMoodleCloud site admins and MoodleCloud site users
Facilitating the signup and control of the MoodleCloud accountName, email, location, telephone numberMoodleCloud site admins
Primary provider for text messaging. Logs for text message sendingPhone numbersMoodleCloud site admins
Email processing (Moodle and signup)emailMoodleCloud site admins and MoodleCloud site users
Backup text messaging service. Data processed by TwilioPhone numbersMoodleCloud site admins
News, Updates, Product tip emails subscriber lists (opt in)Name, emailMoodleCloud site admins
Email sent to site admins regarding their MoodleCloud serviceName, email, financial dataMoodleCloud site admins
Operational reporting on cloud servers and moodle sitesLocation, IP address, moodle activity dataMoodleCloud site admin
Recurring subscriptions and Paymentname, email, countryMoodleCloud site admins
Billing engine and subscription managementcontact details, country, website nameMoodleCloud site users
Assignment submission document converter (when students submit assignments in various file formats, this process converts them into PDF file so the teacher can grade and annotate the document)could be any data submitted in the fileMoodleCloud site users
Webconferencing feature for all MoodleCloud sitescontact details, voice, audio, video, biometrics, IP address, location dataMoodleCloud site users
Authentication, Design, development and tracking of Moodle code, profile published on Tracker site, notificationsContact details, biometric (avatar)Data subject
Authentication, profile published, notificationsContact details, biometric (avatar), any details provided by userData subject
Authentication, notificationsContact details, biometric (avatar)Data subject
Statistics and error recordingIP Address, error logged messages potentially including usernames, and usage recordsWebsite records
Business Development statistics generationData compiled from other listed data sourcesWebsite records
Making and receiving phone callsCall metadata including phone numbers and time & call durationtelephone records
Making and receiving phone callsCall metadatatelephone records
Authentication, documents, usage, emailsNames, Addresses., emails, phone numbers, Health Records, Contact details, biometric (avatar), IP Address, document contents, email contents, usage recordsData Subjects, Moodle HQ
Communication in and outside of companyNames, Addresses., emails, phone numbers, Health Records, Contact details, biometric (avatar), IP Address, document contents, email contents, usage recordsData Subjects, Moodle HQ
Communication in and outside of companyNames, Addresses., emails, phone numbers, Health Records, Contact details, biometric (avatar), IP Address, document contents, email contents, usage recordsData Subjects, Moodle HQ
Internal HR functions, leave and communicationsHQ personal staff information, leave information, communications detailsData Subjects, Moodle HQ
Partner billing, record keeping and communicationsHQ authentication information, contact details, Moodle partner contact details, client statistics & invoicingData Subjects, Moodle HQ
Purchasing various services (domains, etc)Profile data and credit card for Moodle HQ Staff or ContractorData Subjects, Moodle HQ
Licenses for softwarePersonal contact information, cloud stored work may have personal data in itData Subjects, Moodle HQ
Notifications of critical ICT eventsMoodle HQ person information, possible data in alert if relevant to alertingData Subjects, Moodle HQ
Authentication, subscribed marketing & security notifications, bounce records, read and open records, link click recordsPersonal contact information (Name & Email)Data Subjects, Moodle HQ
Billing & PurchasingBilling information including name, addresses, order informationData Subjects, Moodle HQ
Authentication, document management & office licenseContact Details, IP addressesData Subjects, Moodle HQ
Hosting corporate infrastructureHQ Person information, all data covered by other register entries.Data Subjects, Moodle HQ
Legacy ticketing systemContact details, biometric (avatar), any details provided by userData Subjects, Moodle HQ
Ticketing System / Public Comms HubContact details, biometric (avatar), any details provided by userData Subjects, Moodle HQ
CRM for Services teamContact details, contract details with partners, any other information related to partnership with Moodle HQData Subjects, Moodle HQ
MonitoringNo personal data, just system level metricsData Subjects, Moodle HQ
Authentication, Database/API query derived statisticsContact detailsData Subjects, Moodle HQ
Credential and secure information storeUsername and passwords for cloud services, may contain other notesData Subjects, Moodle HQ
Public site spam preventionUser contributed content (forum posts)Data Subjects, Moodle HQ
DNS and Denial of Service Protection (gradually being phased out)Website usage and all passed traffic dataData Subjects, Moodle HQ
Voice and Video MeetingsMoodle HQ Employee contact information and recorded videoData Subjects, Moodle HQ
Monitoring sitesEmail address & Name for AuthenticationData Subjects, Moodle HQ
Virus & Malware scanning for Windows UsersEmail address, Name, Scan data from local computerData Subjects, Moodle HQ
Moodlebot Telegram Bot (Allows Telegram to interact with Tracker and logs conversation in public chat rooms)Any data listed in Tracker as well as free form chatData Subjects, Moodle HQ
Sharing created courses with other Moodle users worldwide for moodle.netProfile data for course creatorsData Subjects, Moodle HQ
Notification & Contact Forwarding, Analytics for moodle.comHQ Staff and Contractor profile informationData Subjects, Moodle HQ
Moodle Staging Sites for internal use onlyAny non-anonymised data from production instances for testingData Subjects, Moodle HQ
Test specific features as part of developmentShould be no personal data stored, however IP addresses and other data may end up in logs, Moodle will also display IP data in internal logs which is publicly availableData Subjects, Moodle HQ
Demo most recent version of software to the publicShould be no personal data stored, however IP addresses and other data may end up in logs, Moodle will also display IP data in internal logs which is publicly availableData Subjects, Moodle HQ
Statistics and Marketing TrackingIP addresses and logs, site behaviour analyticsData Subjects, Moodle HQ
Communication about Moodle Moot EventsHQ Staff and Contractor profile informationData Subjects, Moodle HQ
Ongoing testing of softwareLogins for staff, possible other data as test casesData Subjects, Moodle HQ
Distribution of softwareSource code with names in it and Moodle profiles for HQ Staff and ContractorsData Subjects, Moodle HQ
Language translations for MoodleProfile dataData Subjects, Moodle HQ
Moodle documentation repositoryProfile dataData Subjects, Moodle HQ
Private Moodle Code RepositoryProfile DataData Subjects, Moodle HQ
Learning Moodle courseProfile data, course resultsData Subjects, Moodle HQ
Public Moodle Code RepositoryProfile dataData Subjects, Moodle HQ
Storage of documents and other communicationsFree form storage of documents, so any personal data is possibleData Subjects, Moodle HQ
Home page for Moodle User AssociationProfile dataData Subjects, Moodle HQ
Data collection for applications to be part of the Partner NetworkPartner applications, Profile dataData Subjects, Moodle HQ
Service status notificationsUser logins for HQ StaffData Subjects, Moodle HQ
User login and other informationLogin and other personal profile informationData Subjects, Moodle HQ
Course hosting serviceLogin and other personal profile informationData Subjects, Moodle HQ
Testing accessibility features in MoodleLogin and other personal profile informationData Subjects, Moodle HQ
Collaborative document/code editingOpen system with varied data as well as user IP addressesData Subjects, Moodle HQ
Register of research related to MoodlePublished research documents, login details and profileData Subjects, Moodle HQ
Hosting applications for MoodleLogin informationData Subjects, Moodle HQ
Legacy Moodle sitesLogin informationData Subjects, Moodle HQ
Indexing for search purposesAny data supplied over our sites networkData Subjects, Moodle HQ
Collection and processing of anonymized data from third partiesAnonymized data from other institutions as well as login/profile for Moodle HQ employees and contractorsData Subjects, Moodle HQ
News and information for the Development communityLogin and other personal profile information. Details of specific development project participantsData Subjects, Moodle HQ
Communication to Moodle communityLogin and other personal profile informationData Subjects, Moodle HQ
Accounts for access to software and licensingLogin and other personal profile informationData Subjects, Moodle HQ

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