We are Perth Education City Inc (ABN: 76 842 611 690) trading as StudyPerth (StudyPerth).
StudyPerth is committed to providing quality services to you and this policy outlines our ongoing obligations to you in respect of how we manage your information, including your personal information.
What This Policy Covers
If you do not agree with our procedures and practices, you should not use our services including those provided on our Website.
1. What is personal information
Australia’s Privacy Act 1988 (Cth) defines “personal information” to mean information or an opinion that identifies an individual, or an individual who is reasonably identifiable:
- whether the information or opinion is true or not; and
- whether the information or opinion is recorded in a material form or not.
2. The kinds of personal information we collect, use and disclose
We will only use or disclose your personal information for the primary purposes for which it was collected or as consented to by you.
At or around the time we collect personal information from you, we will endeavour to provide you with a notice which details how we will use and disclose that specific information.
We set out some common collection, use and disclosure instances in the table below:
Types of information
StudyPerth services and Enquiries
· User profile information: Such as your name, address, email address, phone number, country of origin, academic institution, and study program.
· User account information such as username and password.
· Customer Service or enquiries: Information collected in connection by our student services department.
The types of uses we will make of personal information collected for this type of purpose include:
· Services: the provision of our services to you including:
- Using your personal information in order for you to use the products and services offered.
- To provide customer service functions, including handling customer enquiries and complaints.
· Marketing: using your personal information for the purposes set out in “Marketing” below.
· General administrative and security use:
- To protect StudyPerth’s website from security threats, fraud or other criminal activities.
- For the administration and management of StudyPerth
- Maintenance and development of our products and services, business systems and infrastructure.
- In connection with the sale of any part of StudyPerth’s business.
- To provide customer services to users, and for quality assurance purposes.
The types of disclosures we will make of personal information collected for the type of purposes listed include, without limitation, to:
· Third parties connected with the sales process including ecommerce, payment gateway providers and financial institutions.
· Service providers (including IT service providers and consultants) who assist StudyPerth in providing our products and services.
· Third parties in connection with the sale of any part of StudyPerth’s business.
As required or authorised by law.
· Contact information: Such as your name, email address, current postal and residential addresses, phone numbers, country of residence, and age (if applicable).
· Website enquiries: Such as your name, email address, phone number and any information you provide to us as part of your message.
· Online blogs/Forums: Information such as:
- User consent in the StudyPerth ProsPER portal; and .
- any other information provided to us or posted on the StudyPerth ProsPER portal.
· Social media activity: Including “likes”, comments posted, any of your oppositions or feedback, photos posted or uploaded and other information pertaining to your social media activities which concern, or relate, to StudyPerth.
· General marketing and consumer analytics: using your personal information:
- To aggregate with other information and to then use it for marketing and consumer analytics.
- To offer you updates on products, events or information that may be of interest to you.
- For marketing and promotional activities by us (including by direct mail, telemarketing and email) such as our email alerts, product awareness information and newsletters.
- For the Uses detailed above in “StudyPerth Services and enquiries”.
· Online accounts or social media: If you participate in our social media platforms and you provide us your personal information, we will use it for:
- Adding account holders to the marketing database.
- Customer service related contact.
- Responding to social media messages.
- Fulfilling social media platform rules.
We may disclose your personal information to:
· Third parties connected with the marketing process who assist us in providing our products and services to you.
· The parties listed in the Disclosure column for “StudyPerth Services and enquiries”.
We may also collect information that does not identify you personally, which may include your age, the educational courses that you are interested in and what languages.
3. How we collect and hold your personal information
We collect personal information from you directly unless it is unreasonable or impractical to do so.
We collect personal information when you register with StudyPerth ProsPER and begin the different activities within the portal. It is completely optional for you to engage in these activities.
Depending upon the reason for requiring the information, some of the information we ask you to provide may be identified as mandatory or voluntary. If you do not provide the mandatory information or any other information we require in order for us to provide our products or services to you, we may be unable to provide our products or services to you in an effective manner, or at all.
We may also collect personal information about you from other sources, such as competitions and also from third parties. Some examples of these alternative collection events are:
- when we collect personal information about you from third parties; or
- when we collect personal information about you from publicly available sources including but not limited to, Australia Post, White Pages directory, and social media platforms (such as Facebook, Twitter, Google, Instagram etc).
Notification of collection
If we collect details about you from someone else, we will, whenever reasonably possible, make you aware that we have done this and why, unless special circumstances apply, including as described below.
Generally speaking, we will not tell you when we collect personal information about you where information is collected from publicly available sources including but not limited to social media platforms (such as Facebook, Twitter, Google, Instagram etc); or as otherwise required or authorised by law.
Unsolicited personal information
In the event we collect personal information from you, or a third party, in circumstances where we have not requested or solicited that information (known as unsolicited information), and we determine (in our absolute discretion) that the personal information is not required, we will destroy the information or ensure that the information is de-identified.
How we hold your personal information
Once we collect your personal information, we will either hold it securely and store it on infrastructure owned or controlled by us or with a third party service provider who have taken reasonable steps to ensure they comply with the Privacy Act 1988 (Cth). We provide some more general information on our security measures in Section 12 (Data security and quality).
Note: If your personal information is being procured or collected by a third party website or service, this Policy will not apply and we suggest that you approach the third party for information about the privacy and data security of your personal information.
4. Uses and disclosures of personal information
Use and disclosure details
We provide a detailed list (at Section 2 above) of some common uses and disclosures we make regarding the personal information we collect.
Other uses and disclosures
There are additional circumstances in which we may also use or disclose your personal information and in doing so, we are not required to seek your additional consent:
- when it is disclosed or used for a purpose related to the primary purposes of collection detailed above and you would reasonably expect your personal information to be used or disclosed for such a purpose;
- if we reasonably believe that the use or disclosure is necessary to lessen or prevent a serious or imminent threat to an individual’s life, health or safety or to lessen or prevent a threat to public health or safety;
- if we have reason to suspect that unlawful activity has been, or is being, engaged in; or
- if it is required or authorised by law.
Use and disclosure procedures
5. Cookies and IP addresses
A cookie is a piece of data stored on the user’s computer tied to information about the user. In most cases, a cookie does not identify you personally but may identify your internet service provider or computer.
The StudyPerth Website uses ‘cookies’ to monitor traffic patterns and trends on our website, and to serve you more efficiently if you revisit our website. We may gather your IP address as part of our business activities and to assist with any operational difficulties or support issues with our services.
You can set your browser to notify you when you receive a cookie and this will provide you with an opportunity to either accept or reject it in each instance. However, if you disable cookies, you may not be able to access certain areas of our websites or take advantage of the improved web site experience that cookies offer. You can also clear cookies after visiting our Website through your internet browser settings.
In using cookies, StudyPerth does not record any personal information or collect names or details of commercial transactions.
6. Click-stream data
Browsing any website, including the Website, generates a trail of the pages that are visited, and the time spent on each page. Click streams are the paths a user takes when navigating a website and the Internet in general.
When you visit our Website, our servers may record the following information for statistical purposes:
- Your IP address and machine name
- The date and time of visit to the site
- The pages accessed and documents downloaded
- The number of bytes transmitted and received for each request
- The address of the referring page visited (if provided)
- Search terms used
- The type of browser used.
StudyPerth examines this information to determine the traffic through the server, and to specific pages or applications, in order to deliver better services.
No attempt will be made to identify users or their browsing activities except in the event of an investigation, or the need to determine details related to a security breach or unlawful activity.
7. Third Party websites
The Website links to other websites who provide services included in the portal. StudyPerth is not responsible for the content of any linked sites.
8. Sensitive information
Sensitive information is a subset of personal information. It means information or opinion about an individual’s racial or ethnic origin, political opinions, membership of a political organisation, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual orientation or practices, criminal record, health information about an individual, genetic information, biometric information that is to be used for the purpose of automated biometric verification or biometric identification or biometric templates.
We do not collect, use or disclose sensitive information. If you provide sensitive information to us, it will be treated in accordance with unsolicited information, see Section 2.
9. Direct Marketing
Express informed consent
You give your express and informed consent to us using your personal information set out in:
- the “StudyPerth services and Enquiries” section of the table at Section 2 of this document above; and
- the “Marketing Services” section of the table at Section 2 of this document above;
to provide you with information and to tell you about our products, services or events or any other direct marketing activity (including third party products, services, and events) which we consider may be of interest to you, whether by post, email, SMS, messaging applications and telephone (Direct Marketing Communications).
Inferred consent and reasonable expectations of direct marketing
Without limitation to Section 8, if you have provided inferred or implied consent (e.g. not opting out where an opt-out opportunity has been provided to you) or if it is within your reasonable expectation that we send you Direct Marketing Communications given the transaction or communication you have had with us, then we may also use your personal information for the purpose of sending you Direct Marketing Communications which we consider may be of interest to you.
If at any time you do not wish to receive any further Direct Marketing Communications from us, you may unsubscribe from our mailing lists at any time by contacting us in writing at: firstname.lastname@example.org.
You can also do this at any time by using the “unsubscribe” facility included in the direct marketing communication, or by contacting us via the details set out in this Policy
10. Anonymity and pseudo-anonymity
To the extent practicable and reasonable, we will endeavour to provide you with the option of dealing with StudyPerth on an anonymous basis or through the use of a pseudonym. However, there may be circumstances in which it is no longer practicable for StudyPerth to correspond with you in this manner and your personal information may be required in order to provide you with our products and services or to resolve any issue you may have.
11. Cross Border Disclosure
We recommend that you become familiar with that service partner’s privacy and data security policies, and that you contact the service partner directly if you have any concerns regarding the security of your data, including your personal information.
12. Data security and quality
StudyPerth’s security generally
We have taken steps to help secure and protect your personal information from unauthorised access, use, disclosure, alteration, or destruction. You will appreciate, however, that we cannot guarantee the security of all transmissions or personal information, especially where human error is involved or malicious activity by a third party.
Notwithstanding the above, we will take reasonable steps to:
- make sure that the personal information we collect, use or disclose is accurate, complete and up to date;
- protect your personal information from misuse, loss, unauthorised access, modification or disclosure both physically and through computer security methods; and
- destroy or permanently de-identify personal information if it is no longer needed for its purpose of collection.
The accuracy of personal information depends largely on the information you provide to us, so we recommend that you:
- let us know if there are any errors in your personal information; and
- keep us up-to-date with changes to your personal information (such as your name or address).
We provide information about how you can access and correct your information in Section 12.
13. How you may access your personal information that we hold or seek the correction of such information
You are entitled to have access to any personal information relating to you which we hold, except in some exceptional circumstances provided by law (including the Privacy Act 1988 (Cth)). You are also entitled to edit and correct such information if the information is inaccurate, out of date, incomplete, irrelevant or misleading.
If you would like access to or correct any records of personal information we have about you, you are able to access and update that information (subject to the above) by contacting us via the details set out in this document.
You may send us an email to correct or delete any personal information that you have provided to us, or to be provided with details of such personal information. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
We will require verification of your identity to deal with any such request in relation to your personal information.
Interaction of this Policy with contracts
- certain sections or paragraphs in this policy are incorporated into that contract, but in such a way that they do not give rise to contractual obligations onto StudyPerth, but do create contractual obligations on the other party to the contract; and
- the consents provided in this policy become contractual terms provided by the other party to the contract.
This Policy may change from time to time and the updated version is available on the Website.
We do not knowingly collect information from children under the age of 13 and StudyPerth does not target its websites to children under 13 years.
We have put in place an effective mechanism and procedure to resolve privacy complaints. We will ensure that all complaints are dealt with in a reasonably appropriate timeframe so that any decision (if any decision is required to be made) is made expeditiously and in a manner that does not compromise the integrity or quality of any such decision.
If you have any queries or complaints about how we have collected, used, disclosed or stored your personal information or personal data, please contact us at: email@example.com or by post at [5/28 The Esplanade, Perth, 6000]. Please mark your correspondence to the attention of the Privacy Officer.
If you think that any of your personal information held by StudyPerth has been subject to unauthorised access or disclosure, or has been lost, please contact StudyPerth at: firstname.lastname@example.org.
We will endeavour to deal with your query or complaint within 30 days. We will also keep a record of the complaint and any action taken in a register of complaints.
If you feel that StudyPerth has not adequately dealt with your complaint or query within 30 days, you may contact the Office of the Australian Information Commissioner, including by email at email@example.com or telephone 1300 363 992.
18. Addendum: European Union GDPR
Application. If you are a resident of the European Union for the purposes of the GDPR (being Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC), then the additional provisions in this Section 17 also apply to you.
Compliance with GDPR. In providing our products and services, or collecting and using your personal data (having the meaning given to that term in the GDPR), we are required to comply with the GDPR if you are a resident of the European Union.
GDPR obligations. Under the GDPR, StudyPerth is considered a “data controller” in the provision of its services to you, and as such determines the purposes and means for processing of personal data.
In its role as the “data controller”. StudyPerth has implemented appropriate technical and organisational measures to ensure and to be able to demonstrate that processing is performed in accordance with the GDPR.
Your data subject rights. In addition to your general rights of access and correction as set out further above, as a data subject you may:
- (access) request access to your personal data held by StudyPerth;
- (rectification) request to update or rectify any of the personal data that we hold about you by contacting us at the details specified above and request personal data updates;
- (erasure) withdraw your consent to StudyPerth’s use of your personal data as described in this policy by deletion or erasure of your personal data that we hold where that data is no longer required for the purpose for which it was collected;
- (restriction on processing) obtain from StudyPerth a restriction on processing of your personal data where:
- accuracy of the personal data is contested;
- the processing by the controller is unlawful (and you oppose erasure but request restriction of use);
- StudyPerth no longer needs your personal data; or
- you have objected to processing pursuant to your right to object under Article 21(1) of the GDPR;
- (data portability) request that StudyPerth:
- provides you with a copy of the personal data that UniLodge holds about you in a portable, machine readable form; or
- share your personal data with a nominated third party.
If you wish to exercise any of your data subject rights, please send your request in writing to our Privacy Officer using the contact details in Section 16.
We will process your request promptly and usually within one month of receipt of receiving it.
Complaints. If you have any concerns in relation to StudyPerth’s collection or processing of your personal data, then you also have a right to complain to the relevant supervisory authority (within the meaning of the GDPR).