Privacy Policy

Functional Solutions International Pty Ltd (FSI) is committed to protecting personal information and maintaining the privacy of individuals who use our products, service websites, customer service centres and public websites.

This privacy policy explains how we collect, use, store, disclose and protect personal information for users of our products and services, including (but not limited to):

• SmartSuite
• TV4Education
• SmartClassrooms
• SmarteCloud
• SmartLessons
• MyLessons
• MyTV4Education
• TV4Ed Essentials

Some products are offered to schools and some directly to individual educators; this policy applies to all of them unless otherwise stated.

By providing FSI with personal information (your own or that of third parties), you consent to us handling that information in accordance with this policy and the Information Privacy Principles under the Australian Privacy Act 1988 (Cth).

We may update this policy from time to time and will provide written notice to customers of any changes, including how to access the updated version.

FSI hosts personal information that may identify individuals so they can use our products and services, access our service websites, communicate with our customer service team and interact with our business development staff.

Personal information may include any data entered or uploaded by administrators into any FSI product, including (but not limited to):

• Legal names
• Date of birth
• Email addresses
• Parent or guardian information
• Images and other media associated with user profiles

We recommend that administrators:

• Use identifiable information for user accounts (such as first name and surname) to assist with auditing (for example, tracing watch statistics), although this is not mandatory
• Use accurate email addresses for each user to enable features such as "Forgot my password" self‑help, although this is not mandatory

We collect and host personal information so individuals can access and use FSI product lines and for related support and communication purposes.

Functions available to users include, but are not limited to:

• Authenticating and logging in to products
• Transacting business functions for libraries
• Managing access security for resources (for example, videos and books)
• Delivering support and customer satisfaction services
• Providing system notifications (for example, TV4Education request completions, bulk data changes, overdue book notices)
• Providing FSI notifications (for example, product updates, outages, security information) to active users, and separate marketing communications to prospects who have provided their details for lead generation

We collect contact information on our public websites and landing pages for the purpose of lead generation, such as when you request a demo, download resources, or register for an event.

We use this information only to communicate with you about FSI products and services, including upcoming events, new feature releases, service updates and other information we consider relevant to you as a prospect. We do not sell or rent this information to third parties and we do not allow third parties to use it for their own marketing.

FSI will not include active users of our products in lead generation marketing activities. Communications sent to active users are limited to service delivery and customer relationship purposes, such as product updates, outage notifications, security information and customer satisfaction activities.

You may opt out of receiving marketing communications from us at any time by using the unsubscribe link in our emails or by contacting us using the details in the "Access, correction and privacy concerns" section.

We collect and store personal information only via our product user interfaces.

The ability to input, modify or remove personal information is limited to administrative user roles granted during onboarding or as assigned by other administrators during the subscription.

All FSI product lines secure and encrypt data at rest using modern encryption technology and upstream security protocols.

During customer service activities, FSI technicians may need to interrogate or view data from your database. This access will be communicated and logged in customer service tickets for audit purposes.

We may collect personal information from third parties only where the FSI customer has provided express written authorisation.

We hold personal information in electronic form in secured data centres owned and operated by FSI.

As a general rule, FSI does not disclose your personal information to third parties without your written consent.

In the ordinary operation of our products and services, we do not rely on third‑party providers for:

• System plugins
• Hosting services
• Training events
• Online training platforms
• Notification and alerts systems

As a result, we do not routinely store or disclose personal information to third parties for these purposes.

Exceptions where personal information may be disclosed include:

• Customer Data Evacuation (CDE): Where a customer elects to evacuate all organisational data, including personal information and assets, FSI will invoice a Data Evacuation fee and provide all proprietary data stored in an FSI product in an industry‑standard format to the customer. Seventy‑two (72) hours after completion of the CDE, FSI will purge all organisational data from FSI data centres, including backups.
• Discontinuation of service: Where a customer discontinues a subscription, forty‑eight (48) hours from notification of discontinuation or two weeks from the last lapsed subscription date (whichever is later), FSI will purge all organisational data from FSI data centres, including backups. No pro rata refunds apply to contracts discontinued within the 12‑month cycle.
• Legal and regulatory requirements: As required or permitted by the Australian Privacy Act 1988 (Cth), including the Information Privacy Principles, for example where disclosure is required by law, to respond to lawful requests from government authorities, or to manage or report a data breach.

We take reasonable steps to protect data stored in all product lines from misuse, interference, loss, unauthorised access, unauthorised modification and unauthorised disclosure, using both physical and electronic security measures.

These measures include:

• All FSI staff members and contractors passing police checks and holding valid Working With Children clearances
• Secured data centre premises and locked infrastructure cabinets
• Segregated databases for each organisation to avoid cross‑contamination between sites
• Password and user role access controls
• Anti‑virus software and firewalls
• System audit logs and monitoring

Information supplied to us is transmitted over the internet. While we take reasonable steps to secure data in transit, you provide personal information at your own risk.

FSI does not use third‑party hosting services or apps to produce its product lines; instead, we host systems in our own infrastructure located within third‑party data centre facilities.

All proprietary FSI data centres are located in Queensland, Australia, including infrastructure hosted within Polaris Data Centre facilities.

We use a small number of carefully selected third‑party service providers (sub‑processors) to help us deliver our products and services. These providers process personal information only on our instructions and only for the purposes described below.

We remain responsible for the acts and omissions of our sub‑processors and require each provider to implement appropriate security, privacy and confidentiality measures.

9.1 Current sub‑processors

We do not permit these sub‑processors to use personal information for their own marketing purposes. They may only process personal information to support the services we provide to you and our customers.

We will update this section at least 30 days before adding a new sub‑processor or making a material change to an existing sub‑processor, so that customers can review the change and raise any concerns.

FSI staff undergo periodic training in data management and privacy requirements throughout each year.

Our existing product lines are subject to regular penetration testing. We use system artificial intelligence and monitoring to detect and respond to attempts to harvest, breach or hack our product lines. These systems are both proactive and reactive, alerting FSI infrastructure teams to pending or active threats to organisational data (including personal information).

All pending updates undergo penetration, performance and security testing before BETA release. During BETA release, FSI monitors AI and alert systems for potential threats. On full deployment, FSI infrastructure teams engage full system AI and monitoring to ensure data security.

All FSI staff undergo periodic state and federal checks. Any breach of employment conditions relating to criminal offences results in immediate termination and auditing of information accessed by the employee.

If you have concerns about your data or how we handle personal information, or if you wish to request access to, or correction of, personal information we hold about you, please contact our customer service team:

• Telephone: 03 9079 1000 ext. 1
• Email: support@functionalsolutions.com.au

All privacy concerns are referred to members of the FSI executive team:

• Managing Director
• Director

If you are not satisfied with the outcome, you may request that an alternate FSI executive review your concern by emailing complaints@functionalsolutions.com.au.

You may also have the right to contact the Office of the Australian Information Commissioner (OAIC) if you remain dissatisfied with our response (visit oaic.gov.au for current contact details and guidance).

This policy is current as at 8 April 2026.