Privacy Policy (Effective Date: From the first day of November 2018)

1    General Information

1.1 This Privacy Policy sets out how we collect and use information from customers, users and other individuals who access or use our website(s), our application(s) and/or any of our products, platforms, social media, emails, texts, direct messages, services and/or any technology we may deliver in the future (the “Product/Services”).

1.2 This includes where the site management is outsourced to a third party.

1.3 By using our Product/Services you understand that we will collect and use your information as described in this Privacy Policy. If you or your organisation has a separate agreement with us that agreement may have privacy terms that also apply to the information you provide to us under that agreement.  You must read the terms in that agreement because they may be different or be more restrictive than the terms in this Privacy Policy.

1.4 This Privacy Policy does not apply to any third-party websites and/or apps that you may use, that are linked to in our Products/Services. You must review the terms and policies of any third-party websites and apps before clicking on any links.

1.5 Effort Tracking’s Products/Services help users document and review their progress with respect to effort in the field of education with the objective to improving motivation in students for further study. In addition our products and services allow teachers and parents to compere effort scores given to students by their teachers with effort scores given to themselves by the students.  The exchange and analysis of this data will allow students, parents and teachers to map the student’s perception of effort with the perceptions of his or her teacher. This innovative process of accurately measuring and tracking perceptions of effort is aimed at improving intrinsic motivation for learning as well as developing a ‘growth mindset’ in students as well as teachers.

1.6 As part of our Products/Services, we will collect and record information that helps measure and track effort and the validity of any transactions. This information includes the persons who are involved in using the Products/Services together with any data uploaded or downloaded from our products.

1.7 You must read this Privacy Policy in full to ensure you are fully informed. Under our Licence Agreement and our Terms and Conditions to use our products and services you may authorise others to access our products and services; collectively your ‘Authorised Users’. Under these Agreements you must have full legal authority to accept this Privacy Policy on their behalf and in particular on behalf of your Authorised Users who are 18 years of age or under.  

1.8 The Internet and technology is constantly changing and that means we will need to change this policy from time to time to keep up with developments. You must return here regularly to check for any updates.

2    Why we collect your details

2.1 Part of delivering our Products/Services is recognising who we are talking to, so we can provide the products and services that you want and need from us. To do that, we may need to request and store some of your data and private information. We have a duty to protect your privacy, so these details will only ever be used in accordance with the terms of this Privacy Statement.

3.0 What we collect

3.1 We limit the information we collect to only what we consider is necessary. This includes:

3.1.1     The names and details of your Authorised Users such as age, gender, class or position with you, assessment results and the like

3.1.2     Your emails, data uploaded by you and your Authorised Users of the App,

3.1.3     Your IP addresses and your Authorised Users IP addresses and phone numbers.

3.2 Any other information we need to deliver or products and services to you.

3.3 Retaining server logs of requests made to our server, but for no more than 90 days.

3.4 Retaining non-identifiable IP addresses, but for no more than five years.

3.5 Sometimes we may need to work with third party partners from time to time and use their external platforms. That means we may also collect your personal details from other sites.

3.6 We will be transparent about this process. However, the Australian Privacy Principles and the Spam Act 2003 may possibly apply to one or more of those other parties. Your privacy in that case should be covered by the other party’s policy as well as our own.

4.0 What we do with the data

4.1 We use these details to give you a more personalised service and experience, for internal record keeping, for research, to improve our products and services, to customise our websites and platforms, to contact you periodically, telephone you and/or send you promotional emails, texts, faxes or mail about new products, services and special offers, to update you about things we are doing that you might find interesting.

4.2 When you become a Licensee, we may send you emails with details and information that helps you to understand our Products and Services.

5.0 How to unsubscribe

5.1 You can unsubscribe or opt-out from our communications at any time by emailing This email address is being protected from spambots. You need JavaScript enabled to view it.. or by writing to the Privacy Officer at Effort Tracking at 137/ 149-197 Pyrmont Street, Pyrmont, NSW 2009.

6.0 Where we share your information

6.1 We may share non-identifiable data with third parties such as Google, Facebook and others. Our main technology service providers are Google Adwords, Google Analytics, Adobe Media Optimizer, Facebook Social Plugins, Google +1, ShareThis, BazaarVoice, Flashtalking, Rocketfuel, Sociomantics, Feedbackify, Loop11, 5th Dimension and Zopim.

6.2 Information submitted through our Products/Services may be shared with a third-party service provider who operates a platform for us. Our service providers have all passed strict organisational and technical security standards set up with your privacy in mind.

6.3 We do not share your identifiable details with these third parties, but we may release your information when we believe that it is appropriate to comply with the law, to enforce our Product/Services policies, to protect our or others’ rights, property and/or safety. We may also share non-personally identifiable visitor information with other parties for marketing, advertising, or other uses.

6.4 At all times we use our best endeavours to ensure that any recipients of your information will not be in breach of this privacy statement, and that your privacy is protected.

7.0 Security and keeping your personal details safe

7.1 We have put in place physical, electronic and managerial procedures to secure any information collected online from misuse, interference or loss. We do this by design and do our best to prevent unauthorised access, modification or disclosure of that information and we continuously monitor new technologies to do our best to anticipate and block hackers.

8.0 Credit card security

8.1 If we send you request for payment most, but not all, of the numbers on your credit card will be masked. This masking of details is consistent with a worldwide payment card industry data security standard. To ensure security, your credit card details are not held by us, but stored securely by our bank.

8.2 All details, including credit card information, submitted through the Products/Services, pass through our secure server, which offers 128-bit encryption. Our main servers are located in Australia.

8.3 As part of doing business in the online world, your information may be accessible to the owners of these servers, but not in an identifiable format.

8.4 Your information is stored on third party servers for the purposes of storage only. Nevertheless, we do our best to ensure that any recipients of your information will not be in breach of this privacy policy.

9.0 Information in the cloud

9.1 When data and information is uploaded by you and/or stored in a cloud, or you access our App, we have adopted a privacy-by-design approach. That means building privacy measures into the design of the technology we use and we are continuously working with our third party suppliers to make these better. Part of our contracting process is making sure our suppliers and their employees and service providers abide by the Australian Privacy Principles and the Spam Act 2003. You should know that if you are accessing our information from third party sites, the privacy policy of those sites applies, not our own.

10.0      How we use cookies

10.1   A cookie is a text file containing a small amount of data which is downloaded to your computer or digital device when you use one of our products or services or engage one of our Internet advertisements.

10.2   We use cookies to improve and tailor our products and services. They are useful because they help us arrange the content and layout of our products and services and recognise computers or devices that have visited us before. The cookie file also helps us better analyse our web traffic. This information does not identify you personally, and is used for statistical analysis and to help us personalise the content we deliver to you. If you prefer you can modify your settings to decline cookies. Note that if you do that, this might stop you from taking full advantage of our products and services.

10.3   We may contract with third-party service providers to help us understand our customers better. These service providers are not allowed to use the information they collect on our behalf, other than to help us conduct and improve our business.

10.4   Other websites, platforms and technology

10.5   We are also present on social media sites like Facebook, Twitter and Instagram. If you “follow” us, “like” or “share” information you will be covered by that site’s privacy policy and not our own. If you’re a member of one of those social media sites, they may be able to connect your visits to one or more sites with other personal information.

10.6   Our Products/Services may contain links to other websites we think will improve your experience. Once you are on those third party sites, we do not have any control over what those other websites do and we do not endorse or condone third party content or conduct. We have limited or no control over information you give when visiting other websites not governed by our privacy policy. We recommend that you look out for and read the privacy policy of each website.

10.7   We do not sell, trade, or otherwise transfer personally identifiable information to outside parties relating to you or your users of our App. However, this does not include trusted third party service providers who help us operate one or more of our Products/Services. These third parties must keep your information confidential and meet the strict organisational and technical security standards Effort Tracking demands.

11.0      Your control over your information

11.1   You are able to restrict the collection or use of your personal information at any time.

11.2   If you have previously agreed to us using your personal information for direct marketing purposes, you can change your mind at any time by writing to or emailing the Privacy Officer at This email address is being protected from spambots. You need JavaScript enabled to view it. with the subject heading “Details Correction”.

11.3   We will not sell or lease your personal information to third parties, except for direct marketing purposes, where we have your permission, or where we are required by law to do so. We may send you promotional information about third parties which we think you may find interesting. But again, you can also tell us you do not want this to happen.

11.4   We will never disclose your name to another organisation, or share your personal information without your consent.

11.5   We take reasonable steps to ensure your information is accurate and up to date. If you think any information we are holding about you is incorrect or incomplete, please write to the Privacy Officer at Effort Tracking at 137/ 149-197 Pyrmont Street, Pyrmont, NSW 2009 or email ith the subject heading “Details Correction”. We will correct any information found to be incorrect. There is no charge for this correction.

11.6   You are also entitled to access your personal information as set out in Australian Privacy Principles, unless prevented by other laws or regulations. If you would like a copy of what we are storing, email us at This email address is being protected from spambots. You need JavaScript enabled to view it. with the subject heading “Request for Personal Information”. There is no charge for this.

12.0      We comply with the Children’s Online Privacy Protection Act and similar legislation.

13.0     If your server is in the USA, and you’re under the age of 13 (as per the requirements of COPPA (Children’s Online Privacy Protection Act), you must not use this site.

14.0      The EU General Data Protection Regulation the ‘GDPR’

14.1   The focus of the GDPR is increased privacy for the personal “data” of individuals in the EU through the entire life-cycle of collection, use, retention, transfer and deletion of data. “Data” includes any information relating to an identified or identifiable natural person and can include an individual’s name, photo, email address, identification number or opinion.

14.2   Additional protections in the GDPR apply to ‘special categories’ of personal data, such as information relating to an individual’s gender identity, trade union activities and racial or ethnic origin.

14.3   As we do not have an establishment in the EU, currently do not offer goods and services in the EU, monitor the behaviour of individuals in the EU, process the personal information of individuals in the EU, target or and market goods and services to individuals in the EU or monitor or profile them, Effort Tracking considers that it is GDRP exempt.

14.4   If you wish to obtain any further information regarding our privacy policy as it applies to individuals outside Australia please contact our Data Protection /Privacy Officer on this email This email address is being protected from spambots. You need JavaScript enabled to view it.

15.0      If you are unhappy

15.1   If you believe any of our products or services breach the Australian Privacy Principles, or a relevant code, please write to the Privacy Officer at Effort Tracking at 137/ 149-197 Pyrmont Street, Pyrmont, NSW 2009 or email us at  This email address is being protected from spambots. You need JavaScript enabled to view it. with the subject heading “Privacy Complaint”. There is no charge for this.

15.2   We will reply to your complaint as soon as possible, no later than 30 calendar days. If you think we have not adequately addressed your complaint, or you receive no response after 30 calendar days, you can make a complaint to the Office of the Australian Information Commissioner (OAIC). Please see their guide for more details.

15.3   This document seeks to comply with the Australian Privacy Principles 2014 and the Mobile Privacy Guidelines September 2013 published by the Office of the Australian Information Commissioner