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 Library
• 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 Australian Privacy Principles under the 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
• Use accurate email addresses for each user to enable features such as "Forgot my password" self‑help

If information is not provided

Providing this information is not mandatory. Where it is not provided, some features will not be available to that individual:

• Where identifiable information (such as first name and surname) is not used for a user account, activity cannot be reliably attributed or audited, for example tracing watch statistics or loan history.
• Where an accurate email address is not provided, features such as "Forgot my password" self‑help, overdue notices and system notifications cannot be delivered to that user.
• Where other information listed above is not provided, related features may be unavailable, but access to the Services is not otherwise affected.

FSI does not collect personal information beyond what is reasonably necessary to deliver the Services.

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, including AI-assisted support triage and responses via our sub-processor Zendesk (see section 9)
• 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.

FSI develops and operates its own software. SmartSuite Library is designed, written and maintained in-house by FSI. It is not a rebadged or licensed third-party product, and FSI does not use third-party cloud hosting or platform-as-a-service providers to run it.

FSI owns and operates its own servers, storage and network infrastructure. This equipment is housed in a third-party data centre facility, which provides the building, power, cooling, connectivity and physical security only. The facility operator does not administer, access or manage FSI systems, applications or customer data.

FSI does not use third-party system plugins within its products, and delivers its own training directly rather than through third-party training platforms or event providers.

FSI engages a small number of specialist sub-processors for defined support functions, including transactional email delivery, payment processing and support ticketing. Each is listed in section 9, together with the data involved, the purpose and the location. Notification and alert logic is built and operated within FSI's own platform; external providers are used as a delivery channel only.

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 Privacy Act 1988 (Cth), including the Australian 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.

9.2 AI-assisted customer support

FSI uses Zendesk's AI-agent functionality to help triage, draft and respond to customer support requests as part of its Concierge and general support service. This means:

• (a) AI may read the content of your ticket, including your contact details, message, subject and any prior conversation history in the ticket, in order to understand your request;
• (b) AI may draft a response for a human agent to review and send, or in some cases may send a response directly to you without human review. All AI-generated responses are clearly labelled as generated by AI;
• (c) FSI's AI-assisted support answers questions using content from FSI's published knowledge base only. It does not make decisions about your subscription, pricing, contract, financial matters or access to the Services. Those decisions are made by FSI staff;
• (d) You may request a human agent at any time by replying to the ticket asking for one, or by contacting FSI on 1800 241 709.

Your ticket content is processed by Zendesk under Zendesk's Data Processing Agreement and its published data-use commitments, which state that customer data is not used to train Zendesk's AI features or any underlying model, and that AI processing occurs on a zero-retention basis. FSI does not send your data to any AI provider outside of the Zendesk service.

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, Australia: 1800 241 709
• Telephone, New Zealand: 0800 448 402
• International callers: +61 3 9079 1000
• 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 Version 2.0, current as at 17 September 2026. This policy is reviewed at least annually and on any material change to our products, services or sub-processors.