Privacy Policy

Privacy Statement


This TOI 2021 Beta Program: Rich Dreams K-12 Education Privacy Policy document was created and developed specifically for the purposes of The Orbispace Initiative Limited ABN 15 643 089 267’s 2021 TOI Beta Program and supersedes all prior or contemporaneous documents, policies, and agreements with respect to Rich Dream’s policies on privacy and personal data collection. In the event of any conflict or inconsistency between the terms of this policy and any other policy or document specific to Rich Dreams, the terms of this Policy shall prevail to the extent necessary to resolve such inconsistency.


Rich Dreams (Provided to you by THRIVE REVENUE PTY LTD, ABN 96 631 822 056 22), is continually improving how we communicate our privacy practices. This K-12 policy statement explains how Rich Dreams processes personal information provided to or collected from Student Dreamers (defined below) who are under the age of 18 years. This policy has been prepared in accordance with applicable Australian privacy and data protection laws, including the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles contained therein; and the General Data Protection Regulation (EU) 2016/679 (GDPR).


Education Subscriber

The system accountable for controlling all K-12 Accounts under the applicable domain for primary and secondary school or the school district. Registered charities working with children under the age of 18 are considered under this definition. For the purposes of this policy, this includes The Orbispace Initiative Limited.

K-12 Account Admin

The elected personnel by the Education Subscriber with the right to use the provided Rich Dreams K-12 accounts to administer the Service and respond to the personal information access requests of Student Dreamers by either the parents or legal guardians of the Student Dreamer.

K-12 Moderators

The school personnel (mainly principals and staff) with the authority from the Education Subscriber to utilize its K-12 Moderator Account for educational purposes including to moderate and facilitate the usage of the Rich Dreams platform by Student Dreamers.

Student Dreamers

A student at the school who the Education Subscriber permits to use the Rich Dreams Services under the moderation of K-12 Moderators.

K-12 Account

Education Subscribers can use Rich Dreams’ cloud platform by establishing K-12 Account for their K 12 Moderators. K-12 Moderators can create K-12 Access as permitted agents of an Education
Subscriber but should only use the Services of Rich Dreams with direct permission of the Education Subscriber.
Rich Dreams urges K-12 Moderators to securely and confidentially provision Student Dreamers with a K-12 Accounts to ensure that the Education Subscriber can supervise and moderate its Student Dreamers’ account.
Student Dreamers

Rich Dreams does not allow children and teens under the age of 16 to create a Rich Dreams account (and uses an age screening software when users are signing up to enforce the restriction). However, Student Dreamers, even if under the age of 13, may hold an account if provisioned by a K-12 Moderator. Students of schools registered with the Education Subscriber have received the relevant consents and permissions to use the services under their K-12 Accounts.

Roles of the Parties

Education Subscriber

The Education Subscriber is the owner of the K-12 Account. The Education Subscriber oversees how personal information is processed under their K-12 Account in connection with the provisions of Services of Rich Dreams. The Education Subscriber decides when the Rich Dreams platform is used.

The Education Subscriber determines and administers the processing of Student Dreamers' personal information under its privacy policies for the usage of the Services by a Student Dreamer. If parental guardians have questions or requests regarding the usage of collected personal information of Student Dreamers, they are to refer to the privacy policies of the Education Subscriber and are to direct their inquiries to the K-12 Moderator or K-12 Account Administrator.

Rich Dreams

Rich Dreams provides a safe platform for K-12 Moderators on receiving permission and direction from the Education Subscriber. Rich Dreams is considered a “school official” through its contractual agreements and may receive Student Dreamer personal information to perform its service that furthers a “legitimate educational interest” by provisioning education services in a remote setting. Rich Dreams retains Student Dreamer's personal information on behalf of, and at the direction of, the Education Subscriber and does not use the Student Dreamer personal information for other purposes except as authorized by applicable law, including valid contracts with Education Subscribers.

Rich Dreams is accountable for complying with the instructions of the Education Subscriber. E.g., on an Education Subscriber’s direction, Rich Dreams may provide statements including personal information concerning the K-12 Account and its users (including Student Dreamers) to that Education Subscriber.
European Economic Area (EEA) and the UK residents should examine our Privacy Statement for further information concerning how European privacy rights are addressed by Rich Dreams.

Information Collected by Rich Dreams

Rich Dreams may collect Personal Information including, in some instances, Sensitive Information when K-12 Account holders use the Services. For the purposes of the TOI 2021 Beta Program, Personal Information will not be collected for the purpose of creating student accounts; however Personal Information of educators may be collected to create educator/teacher accounts.

Personal Information includes information that identifies a natural person, or by which the person’s identity may be reasonably determined. It may include a person’s full name, mailing or residential address, date of birth, bank account details, credit card details, phone number, and email address, and includes personal data for the GDPR. For this Policy, the term Personal Information also includes personal information obtained from a third party which, under and in accordance with the Privacy Act may lawfully be exchanged.

Sensitive Information includes information (or an opinion) about an individual’s racial or ethnic origin, political opinions, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual orientation or practices or criminal record, as well as information about an individual’s health, genetic information, or biometric information.

K-12 Moderators

K-12 Moderators must provide information such as the following when creating a K-12 Account with the permission of an Education Subscriber:

First and last name
Work-issued email address
School/district name
Job title
School location

Student Dreamers

With the provision by a K-12 Moderator when a Student Dreamer holds an account, Rich Dreams receives personal information, including in the form of “Customer Content.” This is any data uploaded by a K-12 Account holder to the Rich Dreams platform in the usage of the Service. An example of this is when a feature enabled by the Education Subscriber allows Student Dreamers to share files. Customer Content may include personal information that is part of an “educational record.”


Rich Dreams collects certain statistical information automatically through the use of a K-12 Account.
Statistical Information includes the internet protocol (IP) address of your device used to connect to the Services, time zone setting, language preferences, location data, information about your mobile phone and/or browser, operating system and device, and other information which does not identify you personally, but which tracks your usage of the Services.

How Rich Dreams Uses Personal Information

Rich Dreams Uses Personal Information collected from and about Student Dreamers only as needed to deliver the functionality of the Rich Dreams platform, operate the business (including to enhance or improve the Rich Dreams Services), and as instructed by Education Subscriber. For Student Dreamers:
- Rich Dreams never sells the personal information of Student Dreamers
- Rich Dreams does not deliver behavioral advertising using the personal information of Student Dreamers.
- Rich Dreams does not have third-party advertising cookies on product pages.

Rich Dreams distributes two types of web pages: product and marketing. Rich Dreams’ product webpage enables a Student Dreamer to log in via a domain provided to their Education Subscriber and use the Rich Dreams services. There are no advertising cookies on the product web pages. The analytic cookies on the product webpages are to help the Education Subscriber track data of their Student Dreamers.
Marketing webpages, such as are designed to encourage sales of Rich Dreams subscriptions. They are targeted at a general audience over the age of 16. Rich Dreams designed the
Student Dreamer experience to ensure that Student Dreamers never need to visit the marketing webpages to use the Services provided to them under a K-12 Account.

How Rich Dreams Shares Personal Information

Rich Dreams does not share personal information with individuals, organizations, or companies outside of Rich Dreams, unless under one of the following circumstances:

To Provide Our Services

Rich Dreams provides personal information to third-party services to help provide the Service. These third parties are prohibited from using personal information for any reason other than to provide the contracted-for services, and in compliance with appropriate privacy and security obligations.

With Other Student Dreamers

Rich Dreams may share personal information with other Student Dreamers connected with the K-12 Account(s) of the Education Subscriber.

For Particular Corporate Transactions

Rich Dreams may share personal information for strategic or other business reasons if we decide to sell, merge, buy or reorganize our business. In such scenarios, Rich Dreams may receive or transfer personal information. The personal information of Student Dreamers will be subject to this K-12 Privacy Policy unless a successor entity makes changes.

For Legal Reasons

Rich Dreams will share personal information with entities outside of its business if the following reasons apply:
- To fulfill applicable regulation, law, enforceable government request, or legal process. - Investigate potential violations to comply with enforceable applicable provisions of the Terms of Service.
- To identify, avoid or otherwise address technical issues, security, or fraud. - To protect Rich Dreams, our account holders, or the public from harm including to help prevent the loss of life or serious injury to anyone as required or permitted by law.

Third Parties

Rich Dreams does not share the personal information of account holders with third parties, unless it complies with the description herein, or as requested by law, except at the direction and on behalf of an Education Subscriber.


It is a top priority of Rich Dreams to maintain the confidentiality, integrity, and security of personal information related to Student Dreamers. We have in place measures designed to help us to achieve this goal and protect personal information from unauthorized access, use, or disclosure. Rich Dreams has safeguarded K-12 Accounts as privately hosted to ensure that it is not interrupted by uninvited account users. For guidance on how to secure your account, please review our Security Guide.

Data Retention

Rich Dreams retains personal information for as long as necessary to fulfill the purposes for which Rich Dreams has collected it, including to satisfy any Law. To determine the appropriate retention period for Personal Information, Rich Dreams considers the amount, nature, and sensitivity of the Personal Information collected, the potential risk of unauthorized use or disclosure of that personal information, the purposes for which Rich Dreams processes the personal information, and whether Rich Dreams can achieve those purposes through other means. Rich Dreams will also always have regard to the applicable legal requirements under the GDPR and/or the Privacy Act (as applicable).

Access and deletion of information

If a parent, legal guardian, or Student Dreamer would like to request to access, review, refuse further collection of, or delete a Student Dreamer’s personal information, they must refer their request to the Education Subscriber of the K-12 Account. Rich Dreams can not respond to parental or student requests directly as it must comply with its contractual confidentiality obligations relating to the processing of personal information of Student Dreamers. Rich Dreams will delete or restrict the further collection of Student Dreamer’s personal information upon receiving a request from an Education Subscriber or following the automatic termination of the K-12 Account.

Conflicting Terms

This privacy policy provides summary information on how Rich Dreams processes personal information relating to K-12 Accounts. It is consistent with the Privacy Policy which provides further explanations and examples that may be of use. Where terms differ, this K-12 Privacy Policy takes precedent.

Notice of Changes

If material changes are made to this K-12 Privacy Policy, a revised version will be posted on this page and a notice of this change will be provided on our website.

How to Contact Rich Dreams

If you believe that the privacy of your Personal Information has been compromised or has not been used in accordance with this Policy, you should contact Rich Dreams as soon as possible using the contact form.
How to Contact the Office of the Australian Information Commissioner.

If you do not receive a satisfactory response from Rich Dreams, or you believe that Rich Dreams has not handled your complaint satisfactorily, you may wish to refer your complaint to the Office of the Australian Information Commissioner at:
Address: GPO Box 5218, Sydney NSW 2001
Phone: 1300 363 992