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<h1>
Fishbole Privacy Policy
</h1>
<p>
Last updated: 29 March 2020.
</p>
<h2>
WHAT DOES THIS PRIVACY POLICY COVER?
</h2>
<p>
Welcome to Fishbole, the online service of Fishbole Pty Ltd (“Fishbole,” “we,” or “us”). Our Privacy Policy
explains how we collect, use, disclose, and protect information that applies to our Service, and your
choices about the collection and use of your information. Capitalized terms that are not defined in this
Privacy Policy have the meaning given to them in our Terms of Use. If you do not agree with this Privacy
Policy in general or any part of it, you should not use our online services.
</p>
<h2>
1. Information we collect and its use
</h2>
<p>
We collect the following types of information about you:
</p>
<h3>
(a) Information you provide us directly
</h3>
<p>
We may ask for certain information such as a username, your first and last names, birthdate, phone number,
profession and e-mail address when you register for a Fishbole account, or if you correspond with us. We
also collect any messages you send us through the Service, and may collect information you provide in User
Content you post to the Service (such as video and images you upload to use in your video presentations). We
use this information to operate, maintain, and provide the features and functionality of the Service to you,
to correspond with you, and to address any issues you raise about the Service.
</p>
<h3>
(b) Information we collect from you automatically
</h3>
<p>
We will directly collect analytics data, or use third-party analytics tools, to help us measure traffic and
usage trends for the Service. These tools collect information sent by your browser or mobile device,
including the pages you visit and other information (in respect of which, please see the paragraph on log
file information below) that assists us in improving the Service.
</p>
<h3>
(c) Cookies information and information taken from similar technologies
</h3>
<p>
When you visit the Service, we will send cookies — small text files containing a string of alphanumeric
characters — to your computer that uniquely identifies your browser and lets Fishbole help you log in faster
and enhance your navigation through the site. A cookie may also convey information to us about how you use
the Service (e.g., the pages you view, the links you click and other actions you take on the Service), and
allow us or our business partners to track your usage of the Service over time.<br />
You can control or reset your cookies and similar technologies through your web browser, which will allow
you to customise your cookie preferences and to refuse all cookies or to indicate when a cookie is being
sent. However, some features of the Service may not function properly if the ability to accept cookies is
disabled.
</p>
<h3>
(d) Log file information
</h3>
<p>
Log file information is automatically reported by your browser or mobile device each time you access the
Service. When you use our Service, our servers automatically record certain log file information. These
server logs may include anonymous information such as your web request, Internet Protocol (“IP”) address,
browser type, referring / exit pages and URLs, number of clicks and how you interact with links on the
Service, domain names, landing pages, pages viewed, and other such information.
</p>
<h3>
Clear gifs/web beacons information
</h3>
<p>
When you use the Service, we may employ clear GIFs (also known as web beacons) which are used to anonymously
track the online usage patterns of our Users. In addition, we may also use clear GIFs in HTML-based emails
sent to our users to track which emails are opened and which links are clicked by recipients. This
information allows for more accurate reporting and improvement of the Service.
</p>
<h3>
(f) Device identifiers
</h3>
<p>
When you access the Service by or through a mobile device (including but not limited to smart-phones or
tablets), we may access, collect, monitor and/or remotely store one or more “device identifiers,” such as a
universally unique identifier (“UUID”). Device identifiers are small data files or similar data structures
stored on or associated with your mobile device, which uniquely identify your mobile device. A device
identifier may be data stored in connection with the device hardware, data stored in connection with the
device’s operating system or other software, or data sent to the device by Fishbole. A device identifier may
convey information to us about how you browse and use the Service. A device identifier may remain
persistently on your device, to help you log in faster and enhance your navigation through the Service. Some
features of the Service may not function properly if use or availability of device identifiers is impaired
or disabled.
</p>
<h2>
2. Requested account permissions
</h2>
<p>
Some permissions to your account are required for the product to operate. The Service will ask for
permissions to access your account to see basic pieces of information, your Slides, and to access the
Slides. The permissions granted are used exclusively for the operation of the product limited to the
services offered. Below are the specific permission to data access requirements, why they are necessary and
how they are used:
</p>
<h3>
Google account
</h3>
<h4>
Google Drive
</h4>
<ul>
<li>View and manage the files in your Google Drive</li>
<li>See, edit, create, and delete all of your Google Drive files</li>
<li>View and manage Google Drive files and folders that you have opened or created with this app</li>
</ul>
<p>
The Service uses these permissions exclusively to search for Google Slides and files in your Google Drive.
</p>
<h4>
Google Slides
</h4>
<ul>
<li>View and manage your Slides in Google Drive</li>
<li>See, edit, create, and delete your Slides in Google Drive</li>
</ul>
<p>
This permission allows Fishbole to create, view and modify existing Google Slides. The Service uses it
exclusively to: Import, edit and save Google Slides presentation in Fishbole. The user must grant Fishbole
permission to your Google Drive Account. Any content saved from the users Google Slides account to Fishbole
is the users, Fishbole does not lay claim to any of this content.
</p>
<h2>
3. How we use your information
</h2>
<p>
We use the information we collect about you for the purposes set out above which we have described in more
detail below:
</p>
<ul>
<li>Providing you with the Service: We use the information that you provide us to provide the Service to
you. This includes allowing you to log in to Fishbole, operating and maintaining the Service, giving
you access to your presentation and billing you for transactions that you make via the Service. We
also use information we collect about you automatically to remember information about you so that
you will not have to re-enter it during your visit or the next time you visit the site.</li>
<li>For data analytics: We use information about you to help us improve the Fishbole Service and our
users’ experience, including by monitoring aggregate metrics such as total number of visitors,
traffic, and demographic patterns.</li>
<li>Customising the Service for you: We use information you provide us and information about you to make
sure that your use of the Service is customised to your needs. For example, if you tell us you're a
primary school teacher we can recommend presentation content that islikely to be relevant to you.
</li>
<li>To communicate with you about the Service: We use your contact information to get in touch with you
and to send communications about critical elements of the Service. For example, we may send you
emails about technical issues, security alerts or administrative matters.</li>
<li>To promote and drive engagement with the Fishbole Service: We use your contact information to get in
touch with you about features and offers relating to the Service that we think you would be
interested in. We also use information we collect about you to make sure that you get the most
relevant offers and promotions based on your use of the Service, and your preferences. You can
opt-out of getting these communications as described below.</li>
<li>Customer service: We use information about you, information that you provide to our customer service
team, and information about your interactions with the Service to resolve technical issues you
experience with the Service, and to ensure that we can repair and improve the Service for all
Fishbole users.</li>
<li>For security measures: We use information about you to monitor activity that we think is suspicious
or potentially fraudulent, and to identify violations or this Privacy Policy or our Terms of
Service.</li>
<li>For matters that we are required to use your information by law: Fishbole will use or disclose your
information where we reasonably believe that such action is necessary to (a) comply with the law and
the reasonable requests of law enforcement; (b) to enforce our Terms of Use or to protect the
security or integrity of our Service; and/or (c) to exercise or protect the rights, property, or
personal safety of Fishbole, our Users or others.</li>
</ul>
<h3>
Legal bases for processing information under the GDPR (for users in the EEA)
</h3>
<p>
For Fishbole users in the European Economic Area (EEA) Fishbole processes your information in accordance
with European laws and regulations such as the General Data Protection Regulation (GDPR). The GDPR governs
how Fishbole may process your information, and the rights that EEA users have in relation to it.<br />
This means that Fishbole will collect and use your information only where:
</p>
<ul>
<li>We need it to provide you the Service and fulfil our obligations to you under our Terms of Service.
This includes providing you with access to the information that you create in your designs.</li>
<li>It is in our legitimate interests to provide a useful Service, to send you marketing and to enhance
our Service via research and development (but only where our legitimate interest isn’t overridden by
your interest in protecting your data).</li>
<li>You consent to us using your information in a certain way – for example, to hear about new features
or offers.</li>
<li>It is necessary for compliance with our legal obligations.</li>
</ul>
<p>
If you have consented to our use of your information you can withdraw that consent at any time. Depending on
the situation you can either withdraw your consent by emailing [email protected], or through your account
settings page. Where we are using your information because of a legitimate interest to do so, you have the
right to object to that use. However, if you do so it may mean that it is not possible for you to continue
using the Services.<br />
For the purposes of the GDPR, Fishbole Pty Ltd is the data controller with registered address at 52 Victoria
Street Paddington, Sydney NSW 2021 AUSTRALIA.
</p>
<p>
If you have any queries about our Privacy Policy, please contact [email protected]
</p>
<h2>
4. Sharing your information
</h2>
<p>
We will not rent or sell your information to third parties outside Fishbole and its group companies
(including any parent, subsidiaries and affiliates) without your consent, except as noted in this section:
</p>
<h3>
(a) Who we share your information with
</h3>
<p>
We share your information with third-party service providers for the purpose of providing the Service to you
and to facilitate Fishbole’s legitimate interests in providing a service which is useful to you. Those
service providers will only be provided with access to your information as is reasonably necessary for the
purpose that Fishbole has engaged the service provider, and we will require that such third parties comply
with this Privacy Policy, appropriate data processing terms and any applicable laws.<br />
Some of the third parties that Fishbole may share your personal information with include providers who
assist Fishbole with functions such as:
</p>
<ul>
<li>Billing;</li>
<li>Customer support and customer management;</li>
<li>Email services;</li>
<li>Hosting and storage;</li>
<li>Analytics; and</li>
<li>Importing content;</li>
</ul>
<h3>
(b) Who you can choose to share your User Content with
</h3>
<p>
Any information or content that you voluntarily disclose for posting to the Service, such as User Content,
becomes available to the public, as controlled by any applicable privacy settings. Subject to your profile
and privacy settings, any User Content that you make public is searchable by other Users. If you remove
information that you posted to the Service, copies remain viewable in cached and archived pages of the
Service, or if other Users have copied or saved that information. By default all content you create in
Fishbole is publicly available at https://spaces.fishbole.io/
</p>
<p>
You may share your Fishbole content to your social media accounts, including LinkedIn, Facebook, and
Twitter.. You should ensure that you familiarise yourself with the privacy policies of each of these
services and any privacy settings that may apply to the content you choose to share on those accounts.
</p>
<h3>
(c) Sharing with other third parties
</h3>
<p>
Fishbole will also share your information with third parties in certain circumstances, such as where:
</p>
<ul>
<li>we are required to do so as a result of a court order, subpoena or other legal requirement;</li>
<li>we believe that it is necessary to protect you or Fishbole, such as where we consider that there is
a need to investigate potentially fraudulent or criminal activity;</li>
<li>you have consented to our sharing it with a third party for a particular purpose;</li>
</ul>
<p>
Fishbole will also share your information with a third party in circumstances where we sell, divest or
transfer Fishbole (including any shares in Fishbole), or any combination of its products, services, assets
and/or businesses to a third party. Information such as customer names and email addresses, User Content and
other user information related to the Service may be among the items sold or otherwise transferred in these
types of transactions. We will also sell, assign or otherwise transfer such information in the event of
corporate divestitures, mergers, acquisitions, bankruptcies, dissolutions, reorganisations, liquidations,
similar transactions or proceedings involving all or a portion of Fishbole. You will be notified via email
and/or a prominent notice on the Service if such a transaction takes place and be given notice of any
material changes to the way we handle your data under this policy.<br />
We may also aggregate or otherwise strip data of all personally identifying characteristics and may share
that aggregated, anonymized data with third parties.
</p>
<h2>
5. How we transfer, store and protect your data
</h2>
<p>
Your information collected through the Service will be stored and processed in the United States, Australia,
New Zealand and any other country in which Fishbole or its subsidiaries, affiliates or service providers
maintain facilities. Fishbole transfers information that we collect about you, including personal
information, to affiliated entities, and to other third parties across borders and from your country or
jurisdiction to other countries or jurisdictions around the world. As a result, we may transfer information,
including personal information, to a country and jurisdiction that does not have the same data protection
laws as your jurisdiction, and you consent to the transfer of information to the U.S. or any other country
in which Fishbole or its parent, subsidiaries, affiliates or service providers maintain facilities and the
use and disclosure of information about you as described in this Privacy Policy.
</p>
<h2>
6. Cross-border transfers of information (for users in the EEA)
</h2>
<p>
For Users in the EEA, where we transfer your information to a third party provider that is not located in
the EEA, and is not subject to an adequacy decision by the EU Commission, we will require those third party
providers to enter into an agreement that provides appropriate safeguards for your information, including by
using the EU Model Clauses.
</p>
<h2>
7. Keeping your information safe
</h2>
<p>
Fishbole cares about the security of your information, and uses appropriate safeguards to preserve the
integrity and security of all information collected through the Service. To protect your privacy and
security, we take reasonable steps (such as requesting a unique password) to verify your identity before
granting you access to your account. You are responsible for maintaining the secrecy of your unique password
and account information, and for controlling access to your email communications from Fishbole, at all
times. However, Fishbole cannot ensure or warrant the security of any information you transmit to Fishbole
or guarantee that information on the Service may not be accessed, disclosed, altered, or destroyed.
</p>
<h2>
8. Compromise of information
</h2>
<p>
In the event that any information under our control is compromised as a result of a breach of security,
Fishbole will take reasonable steps to investigate the situation and where appropriate, notify those
individuals whose information may have been compromised and take other steps, in accordance with any
applicable laws and regulations.
</p>
<h2>
9. Your choices about your information
</h2>
<h3>
(a) You control your account information and settings
</h3>
<p>
You may update your account information by logging into your account and changing your profile settings. You
can also stop receiving promotional email communications from us by clicking on the “unsubscribe link”
provided in such communications. We make every effort to promptly process all unsubscribe requests.<br />
You may not opt out of Service-related communications (e.g., account verification, purchase and billing
confirmations and reminders, changes/updates to features of the Service, technical and security notices)
although you can object to us providing these emails by emailing [email protected]<br />
If you have any questions about reviewing or modifying your account information, you can contact us directly
</p>
<h3>
(b) Opting out of collection of your information
</h3>
<p>
Please refer to your mobile device or browser’s technical information for instructions on how to delete and
disable cookies, and other tracking/recording tools. Depending on your type of device, it may not be
possible to delete or disable tracking mechanisms on your mobile device. Note that disabling cookies and/or
other tracking tools prevents Fishbole or its business partners from tracking your browser’s activities in
relation to the Service, and for use in targeted advertising activities by Fishbole, including via third
parties’ websites. However, doing so may disable many of the features available through the Service. If you
have any questions about opting out of the collection of cookies and other tracking/recording tools, please
read our Cookies Policy you can contact us directly at [email protected].
</p>
<p>
If you want us to stop collecting information about you, there may be some settings you can adjust in your
browser or device.
</p>
<h3>
(c) Rights in respect of your Information
</h3>
<p>
The laws of some countries grant particular rights in respect of personal information. In certain
circumstances, users in the EEA have the right to:
</p>
<ul>
<li>Request a copy of your information;</li>
<li>Request that we correct inaccuracies relating to your information;</li>
<li>Request that your information be deleted or that we restrict access to it;</li>
<li>Request a structured electronic version of your information; and</li>
<li>Object to our use of your information.</li>
</ul>
<p>
Should you wish to make a request in respect of your personal information please contact us at
[email protected]. You also have the right to object to our processing of personal data about you in order to
send you marketing and we will stop processing data for that purpose.<br />
In some circumstances Fishbole will not be able to comply with a request that you make in respect of your
personal data. For example, we may not be able to provide a copy of your information where it infringes on
the rights of another User. We may also be required to retain certain information that you ask us to delete
for various reasons, such as where there is a legal requirement to do so. In some cases, you may have shared
your information with third parties, such as by publishing content on a third party’s website. In that case
Fishbole will not be able to delete the information, and you will need to contact that third party
directly.<br />
If we are unable to resolve your request, or if you are concerned about a potential violation, you also have
the option to report the issue or make a complaint to the data protection authority in your jurisdiction.
Where you have provided your consent to certain processing and no longer want us to use your information for
that purpose, you may withdraw your consent to this use, although this will not affect the lawfulness of
processing based on consent before its withdrawal.<br />
Please see paragraph “You control your account information and settings” for more options on how to opt-out
of marketing communications.
</p>
<h2>
10. How long we keep your information
</h2>
<p>
Following termination, deactivation of your User account, Fishbole will retain your profile information and
User Content for a commercially reasonable time, and for as long as we have a valid purpose to do so. In
particular, Fishbole will retain your information for the purpose of complying with its legal and audit
obligations, and for backup and archival purposes.
</p>
<h2>
11. Children’s privacy
</h2>
<p>
Fishbole does not knowingly collect or solicit personal information from children under the age of 13 and
the Service and its content are not directed at children under the age of 13. In the event that we learn
that we have collected personal information from a child under age 13 without verification of parental
consent, we will delete that information as quickly as possible. If you believe that we might have any
information from or about a child under 13, please contact us at [email protected]
</p>
<p>
FISHBOLE CLASSROOMS: Children under the age of 13 may use our Fishbole classroom service under the
supervision of their teacher. We will only collect student data where such collection is authorised by
participating educational institutions who have obtained parental consent. We will share student data with
our third party service providers solely to the extent necessary for them to perform a business or
technology support function for us. This may include data processing, account management or the provision of
usage analytics.<br />
The following third party service providers will process student data for the sole purpose of delivering the
Fishbole classroom service. If a school deletes their Fishbole classroom account, or requests the deletion
of personally identifiable information associated with a student’s account, Fishbole will direct these
services to delete any such information they hold:
</p>
<table>
<tr>
<td>
Provider
</td>
<td>
Purpose
</td>
</tr>
<tr>
<td>
Amazon Web Services
</td>
<td>
Data storage
</td>
</tr>
<tr>
<td>
Mailchimp
</td>
<td>
Service emails
</td>
</tr>
<tr>
<td>
Google Drive
</td>
<td>
Content linking
</td>
</tr>
</table>
<p>
If a student account is inactive for more than 12 months, we will send an email to the email address
associated with that account to confirm if the student wishes to continue using the service. If the student
does not respond within 3 months of receipt of that email and there has been no activity on the account, we
will delete their account.<br />
Upon termination of a school’s Fishbole Classroom account, we will delete all student accounts associated
with that school.
</p>
<p>
Educational institutions will have direct control of student data at all times. If a school wishes to
inspect, review, amend or delete data we have collected from a student, they may submit an authorised
request to [email protected] or by any of the contact details provided in section 16 below. Such a request
must come from the email address that owns the Fishbole account. To protect children’s privacy and security,
we will take reasonable steps to help verify the school’s identity before granting access to any personal
information.
</p>
<h2>
12. Links to other websites and services
</h2>
<p>
We are not responsible for the practices employed by websites or services linked to or from the Service,
including the information or content contained therein. Please remember that when you use a link to go from
the Service to another website, our Privacy Policy does not apply to third-party websites or services. Your
browsing and interaction on any third-party website or service, including those that have a link or
advertisement on our website, are subject to that third party’s own rules and policies. In addition, you
agree that we are not responsible for and we do not exercise control over any third-parties that you
authorize to access your User Content. If you are using a third-party website or service (like Facebook) and
you allow such a third-party access to your User Content you do so at your own risk. This Privacy Policy
does not apply to information we collect by other means (including offline) or from other sources other than
through the Service.
</p>
<h2>
13. California users’ Privacy Rights
</h2>
<p>
Californian users of Fishbole have additional rights afforded to them under the California Consumer Privacy
Act (CCPA).<br />
</p>
<h3>
Categories of personal information collected by Fishbole
</h3>
<p>
For more details about the personal information Fishbole has collected in the past year, please see section
1 “Information we collect and its use”. For details on how we use that information, and who we share it
with, please see section 2 “How we use your information” and section 3 “Sharing your information”.<br />
Fishbole does not “sell” (as defined in the CCPA) the personal information of Fishbole users.
</p>
<h3>
Making a request in relation to your personal information
</h3>
<p>
The CCPA gives California consumers various rights with respect to the personal information we collect,
including the right to (subject to certain limitations):
</p>
<ul>
<li>
Request to access the personal information Fishbole has about you; and
</li>
<li>
Request that Fishbole delete all of your personal information.
</li>
</ul>
<p>
California users may make a request by contacting us at [email protected]. We will authenticate your request
using the email address associated with your Fishbole account and if necessary, proof of residency.
</p>
<h2>
14. Video Content
</h2>
<h3>
For Video Creators
</h3>
<p>
Your video content is yours. Fishbole, grants you the admin role to collect and share the videos as you
wish. We do not sell or use videos or content created/imported/collected by you for our business
requirements.
</p>
<h3>
For Video Viewers
</h3>
<p>
Videos are administered by video creators. We also host the videos on our service and collect the page view
data for the video creators and Fishbole.
</p>
<p>
If you have any questions about a video you are viewing, please contact the video creator directly, as
Fishbole is not responsible for the content of that video.
</p>
<p>
We don’t sell or share your viewer data to third party advertisers or marketers.
</p>
<h2>
15. Changes to this Policy
</h2>
<p>
We may update this policy from time to time to reflect our current practice and ensure compliance with
applicable laws. If we make any material changes to the way we collect, use, store and/or share your
personal information, we will notify you by prominently posting notice of the changes on our website and/or
sending an email to the email address associated with your Fishbole account. We recommend that you check
this page from time to time to inform yourself of any changes.
</p>
<h2>
16. How to contact us
</h2>
<p>
If you have any questions about this Privacy Policy or the Service, or wish to make a complaint please
contact us at:
</p>
<ul>
<li>
Email: [email protected]
</li>
</ul>
</section>
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