Privacy Policy

Semaphore Consulting Pty Ltd (“us”, “we”, or “our”) operates the www.xuno.com.au website, Xuno Family and Xuno Staff mobile application (hereinafter referred to as the “Service”), Accelerus Reporting, Student Maps and Purchase Orders.

We are committed to protecting your personal information and complying with applicable privacy laws, including the Privacy and Data Protection Act 2014 (Vic) (“PDP Act”). We are bound by the PDP Act when handling personal information on behalf of Victorian public sector organisations, including government schools. We also adhere to the Australian Privacy Principles (APPs) under the Privacy Act 1988 (Cth) where applicable.

This policy outlines how we collect, use, disclose, and manage your personal information in accordance with the Information Privacy Principles (IPPs).

We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy have the same meanings as in our Terms and Conditions.

Definitions

Service : Service means the www.xuno.com.au website, the Xuno Family and Xuno Staff mobile applications, Accelerus Reporting, Student Maps and Purchase Orders operated by Semaphore Consulting Pty Ltd

Personal Data : Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).

Usage Data : Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

Cookies : Cookies are small files stored on your device (computer or mobile device).

Data Controller : Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed.

For the purpose of this Privacy Policy, we are a Data Controller of your Personal Data.

Data Processors (or Service Providers) : Data Processor (or Service Provider) means any natural or legal person who processes the data on behalf of the Data Controller.

We may use the services of various Service Providers in order to process your data more effectively.

Data Subject (or User) : Data Subject is any living individual who is using our Service and is the subject of Personal Data.

Information Collection and Use

We collect several different types of information for various purposes to provide and improve our Service to you.

Types of Data Collected

Personal Data

While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally identifiable information may include, but is not limited to:

• Teachers, Student and parent/guardian base information (e.g. email, phone, address)
• Attendance, academic and behavioural data
• System usage logs
• Support tickets and communications
• Device and browser information
• Cookies and Usage Data

We only collect information necessary for our functions and services. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send or by contacting us.

Usage Data

We may also collect information that your browser sends whenever you visit our Service or when you access the Service by or through a mobile device (“Usage Data”).

This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When you access the Service with a mobile device, this Usage Data may include information such as 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.

Tracking & Cookies Data

We use cookies and similar tracking technologies to track the activity on our Service and we hold certain information.

Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyse our Service.

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 portions of our Service.

Examples of Cookies we use:

• Session Cookies. We use Session Cookies to operate our Service.
• Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
• Security Cookies. We use Security Cookies for security purposes.

Why We Collect Your Data

Semaphore Consulting Pty Ltd uses the collected data for various purposes:

• To provide and maintain our Service
• To notify you about changes to our Service
• To allow you to participate in interactive features of our Service when you choose to do so
• To provide customer support
• To gather analysis or valuable information so that we can improve our Service
• To monitor the usage of our Service
• To detect, prevent and address technical issues
• To provide you with news, offers, and general information about our goods, services, and events, if you have opted for it.

Legal Basis for Processing Personal Data under the General Data Protection Regulation (GDPR)

If you are from the European Economic Area (EEA), Semaphore Consulting Pty Ltd legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.

Semaphore Consulting Pty Ltd may process your Personal Data because:

• We need to perform a contract with you
• You have given us permission to do so
• The processing is in our legitimate interests and it is not overridden by your rights
• To comply with the law

Retention of Data

Semaphore Consulting Pty Ltd will retain your 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.

Semaphore Consulting Pty Ltd 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 Service, or we are legally obligated to retain this data for longer periods.

Transfer of Data

Your information, including Personal Data, may be transferred to – and maintained on – computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

If you are located outside Australia and choose to provide information to us, please note that we transfer the data, including Personal Data, to Australia and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Semaphore Consulting Pty Ltd will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organisation or a country unless there are adequate controls in place including the security of your data and other personal information.

Disclosure of Data

Disclosure for Law Enforcement

Under certain circumstances, Semaphore Consulting Pty Ltd may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Legal Requirements

Semaphore Consulting Pty Ltd may disclose your Personal Data in the good faith belief that such action is necessary to:

• To comply with a legal obligation
• To protect and defend the rights or property of Semaphore Consulting Pty Ltd
• To prevent or investigate possible wrongdoing in connection with the Service
• To protect the personal safety of users of the Service or the public
• To protect against legal liability

Security of Data

We implement appropriate security controls to protect personal information, including:

• Encryption of data in transit and at rest
• Access controls and authentication
• Secure hosting within Australia
• Regular audits and monitoring

In the event of a data breach, we will act swiftly and notify affected parties in accordance with legal requirements.

Data Quality and Accuracy

We take reasonable steps to ensure that the personal information we collect, use, and disclose is accurate, complete, and up to date. You can request corrections at any time.

Unique Identifiers

We may assign unique identifiers (e.g., usernames, IDs) to facilitate system use, but only where necessary and in line with privacy principles. These identifiers are not used for unrelated purposes.

Anonymity and Pseudonymity

Where lawful and practicable, individuals may interact with us anonymously or under a pseudonym. However, full identification is often required to deliver services accurately and securely.

Your Data Protection Rights under the General Data Protection Regulation (GDPR)

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. Semaphore Consulting Pty Ltd aims to take reasonable steps to allow you to correct, amend, delete or limit the use of your Personal Data.

If you wish to be informed about what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.

In certain circumstances, you have the following data protection rights:

• The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
• The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
• The right to object. You have the right to object to our processing of your Personal Data.
• The right of restriction. You have the right to request that we restrict the processing of your personal information.
• The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
• The right to withdraw consent. You also have the right to withdraw your consent at any time where Semaphore Consulting Pty Ltd relied on your consent to process your personal information.

Please note that we may ask you to verify your identity before responding to such requests.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).

Service Providers

We may employ third party companies and individuals (such as cloud hosting provider) to facilitate our Service (“Service Providers”), provide the Service on our behalf, perform Service-related services or assist us in analysing how our Service is used.

These providers are contractually bound to uphold confidentiality and security and are not permitted to use your data for unrelated purposes.

Child Safety and Information Sharing Obligations

We are committed to supporting the wellbeing and safety of children and young people, and we recognise our obligations under the Child Wellbeing and Safety Act 2005 (Vic), including the Child Safe Standards and the Child Information Sharing Scheme (CISS).

As a provider of systems and services to schools and educational institutions, We may, where permitted or required by law, collect, use, or share child-related information to promote the safety or wellbeing of a child or group of children. This may occur without consent if there is a reasonable belief that such action is necessary to prevent harm or support early intervention.

In accordance with the CISS, We may disclose relevant information to prescribed entities — such as education providers, health services, and child protection agencies — when doing so is reasonably necessary to support a child’s wellbeing or safety.

We also supports the implementation of the Child Safe Standards, and we work with our client schools to help ensure child safety is embedded in the digital tools they use. Internally, we maintain policies, employee training, and system safeguards designed to uphold child safety, manage data responsibly, and respond appropriately to safety concerns.

Where personal or sensitive information about children is handled, we take all reasonable steps to protect it from misuse, loss, unauthorised access, modification, or disclosure — in alignment with both Victorian privacy law and our obligations under the CISS.

Access and Correction

You have the right to access personal information we hold about you and to request corrections if it is inaccurate. Requests can be made by contacting us using the details below.

Links to Other Sites

Our Service may contain links to other sites that are not operated by us. If you click a third party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Changes to This Privacy Policy

We may update our Privacy Policy from time to time. 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.

Contact Us

If you have a privacy complaint, we encourage you to contact us first by email – help@xuno.com.au. We will investigate and respond promptly. If unresolved, you may contact the Office of the Victorian Information Commissioner (OVIC).