1. What is Privacy Policy?
1.1 This Privacy Policy describes the policies and procedures on the collection, use and disclosure of information about you or associated with you (“Personal Information”) when you use our Services through the Platform.
1.2 By using the Platform, you agree and consent to the collection, use and sharing of Personal Information in accordance with this Privacy Policy.
1.3 We are firmly committed to privacy and are bound by the Australian Privacy Principles contained in the Privacy Act 1988 (Cth) (collectively, the “Applicable Laws”).
1.4 The protection of your privacy is very important and we have adopted the following practices to safeguard the confidentiality of your personal information
1.5 Unless otherwise explicitly defined in our Terms and Conditions, the below mentioned terms shall have the following meanings under this Privacy Policy:
"FifthDomain" (referred to as either "FifthDomain", "we", "us" or "our" in this Privacy Policy) refers to FIFTH DOMAIN PTY LTD (ACN 606 251 585).
"Device" means any device that can access the Services such as a computer, a cell phone or a digital tablet.
“Personal Data” means collectively all the information including Personal Information and Usage Data that we collect from you.
"You" or “your” refer to the user of the Platform, or other legal entity or a natural person on behalf of which such user is accessing or using the Platform, as applicable.
2. What information do we collect from you?
2.1 Personal Information
When you use the Platform, we may ask you to provide us with some or all of the following Personal Information about you or the user you represent which includes the following, but is not limited to:
Identity Information – e.g. name (including “gaming alias”), gender, photograph, date of birth and age (including proof of identity documents);
Contact Details –e.g. email address, phone number and residential address;
Employment and Education details – e.g. current job title, self-reported training, years of work experience and level of education;
Payment Information – credit/debit card details, bank account details and billing address; and
Other information – details of feedback or complaints about Services provided by us, internal Security Operations Center (SOC) functional and team structures
We may collect or verify some of your Personal Information, from employers, schools, or event organisers as applicable. This facilitates us to set up multiple Accounts
simultaneously across the Platform.
You will be requested to give your consent for the collection of Personal Information prior to the provision of any of our Services or at the time of creating an Account when you are using the Platform. You have the right to withdraw your consent at any time without any additional costs. This shall mean deleting the Account, which may result in termination of the ongoing Services. You can withdraw your consent by emailing us at helpdesk@fifthdomain.com.au. and further request us to notify you of how the Account deletion will impact the Services we offer you.
2.2 Usage Data
When you visit the Website, we automatically collect certain information (“Usage Data”) about your Device, browser type and version, IP address, time zone, cookies that are installed on your Device and information when you interact with the Website including, but not limited to the pages of our Services that you visit, time and date of your visit, time you spent on those pages, whereabouts you click, how you solve problems, unique identifiers and other diagnostic data. Please be aware that we might use the Usage Data to process and create new information about you for our data analytic purposes.
When you use the Platform, we collect the following categories of Usage Data from you:
Engagement Information – progress through the content, how you have performed in competition, assessment and courses;
Cyber Skills – tracking performance and details of various cyber skills that a user has demonstrated; and
Personality Information – e.g. details on a User’s approach to teamwork, teamwork skills, other skills, talents and motivations.
When you access the Platform through a mobile device, we may collect certain information automatically, including, but not limited to, the type of mobile device you use, your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile internet browser You use, unique device identifiers and other diagnostic data.
We automatically collect certain Usage Data using the following technologies:
Cookies - a small data file placed on your Device and which often includes an anonymous unique identifier. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Services. Unless you have adjusted your browser setting so that it will refuse Cookies, our Services may use Cookies.
Log files - which track actions occurring on the Website, and collect data including your IP address, browser type, internet service provider, referring/exit pages, and date/time stamps.
Web beacons – electronic files used to record information about how you browse the Website (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit FifthDomain, for example, to count users who have visited those pages and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).
In order to provide some features of the Platform, we may collect the following data with your prior permission:
Geo-location data - collected using GPS technology (or other similar technology) to determine the User’s current location when they have given the appropriate permissions. Additionally, background geo-location may be collected for the duration of their shift and for safety and billing purposes.
Microphone and Camera - collected when the User is attempting to upload images or audio information in the form of notes, signatures etc.
The User can enable or disable access to this information at any time through their device settings.
To update any of your Personal Information please make a request to us using the contact information we have provided at the end of this Privacy Policy.
3. How do we use your Personal Data?
3.1 We use your Personal Data for purposes for the following purposes:
Provide and maintain our Services: to operate, administer and maintain the Platform and generally provide the functions and features that are part of our Services including registering you as a User, verifying your identity when you sign in to your Account, to facilitate and process transactions that take place on the Platform, send information about your Account and to respond to support requests.
Analyse and develop our Services: to develop, deliver, measure, monitor, analyse and improve our Services and develop new Services.
Communicate with you: to respond to your complaints, queries and provide customer support, associated with the functions and features of the Services.
Marketing and advertising: to customise our Services and the Platform for advertising, sending you marketing and promotional materials (e.g. Our Newsletter) and such other purposes in order to provide you with a more personalised experience where you have given us consent.
Sharing information: sharing your information such as reports about your performance (e.g. your quiz results in a particular competition) on our Services with your employer, school or other organisations, group-level data of you and other users (e.g. combining your quiz scores with the scores of other users to create course average) including your engagement data (e.g. your user name and your score in a competition leaderboard) with other users.
Legal compliance: to comply with legal obligations and protect our rights and interests and our Users.
Other purposes: to data analytics, identify usage trends, provide recommendations to you and other users, determine the effectiveness of our promotional campaigns, skill matching you with possible employers who are hiring etc.
4. When do we share your Personal Data?
4.1 We may share your Personal Data with your employer, school or event organiser if you are using our Services as a part of your employer’s training program, as a part of the course curriculum at school or as a part of a competition as the case maybe. We may also share your Personal Data with companies or organisations who are interested in hiring you.
4.2 We may share your Personal Data with your employer, school or event organiser if you are using our Services as a part of your employer’s training program, as a part of the course curriculum at school or as a part of a competition as the case maybe. We may also share your Personal Data with companies or organisations who are interested in hiring you.
4.3 We will make the Personal Data we collect from you available to third party service providers (companies or individuals employed by FifthDomain to facilitate the Website and the Platform, to perform Services related to, for security purposes and assist FifthDomain in analysing how the Website and the Platform are used) where it is reasonably necessary to enable us to make the Platform available in full operation to you, when we need to send you more personalised content, when we are required to do so by law or when you give us permission to do so, when you make payments using the Platform in accordance with our Terms and Conditions of Use.
4.4 If you are an employer, school or an event organiser, our Services allow you to share information about your entity and the users you represent with other individuals and entities including other users and potential users of the Services as authorised by you. Please consider your own privacy and your employee's, student’s or participant’s privacy (as applicable) when sharing your information with anyone.
5. Transfer of Personal Data
5.1 Your information, including Personal Data, is processed at FifthDomain’s operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to and maintained on servers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.
5.2 Your information, including Personal Data, is processed at FifthDomain’s operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to and maintained on servers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.
5.3 Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.
5.4 FifthDomain will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy. No transfer of your Personal Data will take place to a company or a country unless adequate controls are in place, including the security of your data and other personal information. These controls may include a country having an “adequate data protection framework” as determined by the European Commission’s adequacy decisions on the basis of article 45 of Regulation (EU) 2016/679, a company having binding rules to protect your data or another party having a binding agreement that will ensure your data is secure.
6. Security of Personal Data
6.1 To keep your Personal Data secure, FifthDomain practises data minimization and storage limitation by collecting only necessary personal information and deleting it when no longer needed, reducing the risk of data breaches (For more details see clause 7) and implementation or technical measures. Technical measures include removing names from data and using end-to-end encryption to enhance security. Additionally, FifthDomain ensures its employees are trained in email, internet, and cyber security and restricts access to personal information, minimising the risk of mishandling.
6.2 The security of your Personal Data is important to us, but please be aware that no method of transmission over the internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
7. Retention and Erasure of your Personal Data
7.1 FifthDomain will collect your Personal Data only as required to provide you with the Services and retain such Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with Applicable Laws), resolve disputes, and enforce our legal agreements and policies.
7.2 We will erase or anonymize the following types of Personal Data as outlined below:
7.3 If you have a registered Account without verification, your identity information, contact details and payment information will be deleted no later than 28 days upon registering as a User.
7.4 Having a registered and verified Account if you either withdraw your consent or delete your Account:
Your identity information will be deleted unless retained for legal compliance;
Your payment information will be deleted unless for legal compliance or settlement of any outstanding amounts that you owe us; and
All other information of you will be retained for legal compliance or shall be anonymized with immediate effect.
7.5 FifthDomain will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Services, or we are legally obligated to retain this data for longer time periods.
8. Your Rights over your Personal Data
8.1 Access: You can request access to the Personal Data we hold about you, including why we have it, why we use it, who we share it with, how long we keep it, where we collect it from and proof of your consent. You will be provided with a copy of this information (except certain information that we believe is necessary to protect the rights of other Users) on request.
8.2 Correction: If you believe we have incorrect information, you can make a request to correct your information.
8.3 Erasure: You can request the erasure of your personal information that we hold. Please be aware that erasure will be subject to terms under this Privacy Policy and that some Services may be impacted once your information is erased.
8.4 Restriction: You can request us to restrict the use of your personal information for certain purposes, such as if it's inaccurate, no longer needed by us or being used unlawfully. Please be aware that we can still store your personal information despite your request for any restrictions.
8.5 Rights over automatic processing: If we automatically process your information, you can request a human review, especially if it has significant impact for you including any legal consequences.
8.6 To enforce your rights or for more information about your rights over your Personal Data email us at helpdesk@fifthdomain.com.au.
9. Children's Privacy
9.1 Our Services are not available for children below the age of 12, if you between the ages of 13 to 15 (inclusive), provision of our Services will be subject to consent of a parent or a guardian. We do not knowingly collect personally identifiable information from anyone below the age of 12.
9.2 If you are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact us at helpdesk@fifthdomain.com.au. If we become aware that we have collected Personal Data from a minor between the ages of 13 to 15 (inclusive) without verification of parental or guardian’s consent, we take steps to remove that information from our servers with immediate effect.
10. Links to other Websites
10.1 Our Website may contain links to other websites that are not operated by us. If you click on a third party link, you will be directed to that third party's website. We strongly advise you to review the privacy policy of every website you visit.
10.2 Our Website may contain links to other websites that are not operated by us. If you click on a third party link, you will be directed to that third party's website. We strongly advise you to review the privacy policy of every website you visit.
10.3 We have no control over and assume no responsibility for the content, privacy policies or practices of any third party websites or services.
11. Changes to Privacy Policy
We reserve the right to update our Privacy Policy from time to time. We will let You know via email and/or a prominent notice on our Website, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page. In all cases, your use of the Platform after a new effective date indicates your acceptance of the modified Privacy Policy.
12. How to complain about Personal Data Breach?
12.1 If you believe your privacy has been breached by us or have any questions or concerns about our Privacy Policy please, contact us using the contact information below and provide details of the incident so that we can investigate and respond to your complaint promptly.
12.2 If you believe your privacy has been breached by us or have any questions or concerns about our Privacy Policy please, contact us using the contact information below and provide details of the incident so that we can investigate and respond to your complaint promptly.
12.3 We will treat your queries and complaints confidentially.
12.4 Our representative will contact you within a reasonable time after receipt of your query or complaint to discuss your concerns and outline options regarding how they may be resolved. We will aim to ensure that your complaint is resolved in a timely and appropriate manner.
12.5 Please contact us by sending an email to helpdesk@fifthdomain.com.au.
12.6 You can also send a complaint to the Office of the Information Commissioner. More information about making a complaint can be found here.