We use different methods to collect data from and about you including through:
· Direct interactions. You may give us your: identity data, contact data, transaction data, financial data and marketing and communications data by filling in forms on our website or in person at one of our campuses, or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you apply for one of our products or services and when you maintain an ongoing relationship with us as a student.
· Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
· Where we need to perform the contract we are about to enter into or have entered into with you.
· Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
· Where we need to comply with a legal or regulatory obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data, save where we explicitly ask for consent. You have the right to fully or partially withdraw consent to marketing at any time by contacting us.
We do not knowingly collect any information from children under the age of 16 unless and until the relevant consent and authorisation has been provided for a student under 16 to use the products and services and for us to collect information from such student.
Purposes for Which we will use Your Personal Data
We have set out below, in tabular form, the ways in which we may use your personal data, and which of the legal bases we rely on to do so. Where appropriate, we have also identified our legitimate interests. Please note that we may process your data for more than one lawful ground depending on the circumstances and the specific purpose. Please contact us if you would like more detail about the specific legal ground which we are relying on to process your personal data, where more than one ground has been identified below.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Promotional Offers From Us
We may use your identity, contact, technical, usage and profile data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased products (including publications) or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
Anonymising Personal Data
We may aggregate and/or anonymise personal data so that it will no longer be considered personal data.
You can ask us to stop sending you marketing messages at any time by following the opt-out/unsubscribe links on any marketing message sent to you or by contacting us at any time.
Where you opt out of receiving these marketing messages, we will stop sending you marketing messages but we will continue to process your personal data if there are legitimate grounds for further processing which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims.
Change of Purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use for another reason and that reason is connected with the original purpose. If you wish to get an explanation as to how processing for the new purpose is connected with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you first and provide you with information about that unrelated purpose.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Disclosures of Your Personal Data
We may share your personal data with the parties set out below for the purposes set out in the table above - Purposes for Which we will use Your Personal Data:
· Other companies in the UP Education Limited group.
· External Third Parties, if related to the purposes for which the personal data is collected, these can include providers of services such as website hosting, data analysis, information technology, auditing, payment processing, and other services.
· To comply with an applicable law, to cooperate with law enforcement, to respond to requests from public and government authorities, and other legal reasons for disclosure.
We seek to ensure that all third parties respect the security of your personal data and to treat it in accordance with all applicable laws.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
How Long will you use my Personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any compliance, legal, accounting, or reporting requirements.
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it, or if your personal data has been unlawfully processed. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Privacy Concerns or Questions
If you have any concerns regarding your privacy or wish to use your rights of access or correction, please contact us at firstname.lastname@example.org.
If you are not satisfied with our response to any privacy-related concern you may have, you can contract the Privacy Commissioner.