Privacy policy

This Privacy Policy sets out our commitment to protecting the privacy of personal information provided to us, or otherwise collected by us, offline or online, including through our website (Site). In this Privacy Policy we, us or our means ICANSTUDY PTY LTD (ACN 644 853 967).

Further, this Privacy Policy details what information we collect, how we use that information and what your rights are regarding any information collected by us. We are subject to certain requirements of applicable Australian, United States, Canadian and European Union laws and strive to meet the requirements of the Australian Privacy Principles and the applicable United States, Canadian and European Union privacy laws.

We sustain your right to nondiscrimination with respect to the exercise of your rights under this Privacy Policy and all applicable laws.

Personal information

The types of personal information we may collect about you include:

your name;
your current year level;
your photo;
your school;
your contact details, including email address, city, mailing address, street address and/or telephone number;
your credit card or payment details (through our third party payment processor);
your browser session and geo-location data, device and network information, statistics on page views and sessions, acquisition sources, search queries and/or browsing behaviour;
information about your access and use of our Site, including through the use of Internet cookies, your communications with our Site, the type of browser you are using, the type of operating system you are using and the domain name of your Internet service provider; and
any other personal information requested by us and/or provided by you or a third party.

We may collect these types of personal information directly from you or from third parties.

Collection and use of personal information

We may collect, hold, use and disclose personal information for the following purposes:

to enable you to access and use our Site, associated applications and associated social media platforms;
to renew and update of your membership details;
to provide you with our publications and information;
to contact and communicate with you;
for internal record keeping, administrative purposes, invoicing and billing purposes;
for analytics, market research and business development, including to operate and improve our Site, associated applications and associated social media platforms;
to run competitions and/or to offer additional benefits to you;
for advertising and marketing, including to send you promotional information about our products and services and information about third parties that we consider may be of interest to you; and
to comply with our legal obligations and resolve any disputes that we may have.

The collection, use, retention and sharing of your personal information is limited to the purposes described in this Privacy Policy that are compatible with the context of the collection. In the event of any change to the purposes, we will notify you and obtain your consent.

We may also collect, use and share aggregated data such as statistical or demographic data. Aggregated data is derived from your personal data but is not considered personal data under data protection law as it does not directly or indirectly reveal your identity. For example, we may aggregate data about your use of the Site to calculate the percentage of users accessing a specific feature. Likewise, we may aggregate data that we collect through your use of the Site in order to produce certain benchmarking reports. However, if we combine or connect aggregated data with your personal data so that we can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

If we propose to collect information about you that you would not reasonably expect, you will be provided with “just in time” notice when that information is collected.

The information collected by us will be retained for 7 years, being no longer than is reasonably necessary for the purposes disclosed to you in this Privacy Policy and otherwise.

Disclosure of personal information to third parties

We may disclose personal information to:

third party service providers for the purpose of enabling them to assist us in providing our services to you, including (without limitation) IT service providers, data storage, web-hosting and server providers, debt collectors, maintenance or problem-solving providers, marketing or advertising providers, professional advisors and payment systems operators;
our employees, contractors and/or related entities;
your school, and/or the schools where we run workshops;
our existing or potential agents or business partners (including other providers of similar services with which we have a relationship);
sponsors or promoters of any competition we run;
anyone to whom our business or assets (or any part of them) are, or may (in good faith) be, transferred;
credit reporting agencies, courts, tribunals and regulatory authorities, in the event you fail to pay for goods or services we have provided to you;
courts, tribunals, regulatory authorities and law enforcement officers, as required by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights;
third parties, including agents or sub-contractors, who assist us in providing information, products, services or direct marketing to you. This may include parties located, or that store data outside of Australia; and
third parties to collect and process data, such as Google Analytics. This may include parties located, or that store data outside of Australia.

We may also include your photo in marketing and promotional materials.

Where we disclose your personal information to third parties, we will request that the third party handle your personal information in accordance with this Privacy Policy and in this regard, we will enter into written contracts with those service providers to limit the use of personal information by those service providers to the business purpose of those contract.

By providing us with personal information and using the Site, you consent to the disclosure of your information in accordance with this Privacy Policy. You acknowledge that some overseas third parties may not be regulated by the Privacy Act 1988 (Cth) (“Privacy Act”) and the Australian Privacy Principles in the Privacy Act and if any third party engages in any act or practice that contravenes the Australian Privacy Principles, it would not be accountable under the Privacy Act and you will not be able to seek redress under the Privacy Act.

How we treat personal information that is also sensitive information

Sensitive information is a sub-set of personal information that is given a higher level of protection under the Australian Privacy Principles. Sensitive information means information relating to your racial or ethnic origin, political opinions, religion, trade union or other professional associations or memberships, philosophical beliefs, sexual orientation or practices, criminal records, health information or biometric information.

We do not currently collect sensitive information. If we do collect sensitive information, provided you consent, your sensitive information may only be used and disclosed for purposes relating to the primary purpose for which the sensitive information was collected.

Sensitive information may also be used or disclosed if required or authorised by law.

Data Protection Principles

We adhere to the principles set out in data protection law when handling personal information and data. These principles require personal information and data to be:

processed lawfully, fairly and in a transparent manner;
collected and used only for specified, explicit and legitimate purposes that are compatible with previously disclosed purposes, unless first providing you with notice and obtaining your consent otherwise;
adequate, relevant and limited in collection to what is necessary and in relation to the purposes for which it is processed;
collected, used, retained and shared in a way that is minimised to what is reasonably necessary and proportionate to achieve the purpose of collection or processing or for another disclosed purpose that is compatible with the context of collection;
accurate record of processing activities and, where necessary, kept up to date;
not kept in a form which permits identification of data subjects for longer than is necessary for the purposes for which the data is processed;
processed in a manner that ensures its security using appropriate technical and organisational measures to protect against unauthorised or unlawful processing and against accidental loss, destruction or damage;
not transferred to another country without appropriate safeguards being in place;
made available to data subjects and to allow data subjects to exercise certain rights in relation to their personal data;
registered with the applicable data protection authority; and
limited in its access to only those employees in our organization who need it.

We are also responsible and accountable for ensuring that we can demonstrate compliance with the data protection principles listed above.

Your rights and controlling your personal information

Information from third parties: If we receive personal information about you from a third party, we will protect it as set out in this Privacy Policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have such person’s consent to provide the personal information to us.

Restrict: If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by contacting us using the details provided below.

Access: You may request details of the personal information that we hold about you. An administrative fee may be payable for the provision of such information.

If you would like to request for:

specific pieces or categories of information which we have collected about you;
the sources from which that information was collected;
the purpose for which that information was collected; or
deletion of any parts of your information held by us,

please contact us using the details provided below.

Correction: If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the details provided below. We will take reasonable steps to correct any information found to be inaccurate, incomplete, misleading or out of date.

Complaints: If you wish to make a complaint about how we have handled your personal information, please contact us using the details provided below and provide us with full details of the complaint. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint.

Unsubscribe: To unsubscribe from our e-mail database or opt-out of communications (including marketing communications), please contact us using the details provided below or opt-out using the opt-out facilities provided in the communication.

Consent/Opt-in:

In accepting this Privacy Policy, you acknowledge and agree that:

you consent to provide your personal information to us; and
by providing your personal information to us that us, our related bodies corporate and partners and each of our officers, employees, agents and contractors are permitted to collect, store, use and disclose your personal information in the manner set out in this Privacy Policy and in accordance with Australian, the applicable United States, Canadian, European Union privacy and data protection laws.

You do not have to provide personal information to us, however, if you do not, it may affect your use of this Site or the products and/or services offered on or through it.

Automated Decision Making

We do not use Automated Decision Making such as “profiling” in connection with decisions related to your performance, economic situation, health, personal preferences, interests, reliability, behavior, location or movements (where your consent is automatically given).

Storage and security

We are committed to ensuring that the personal information we collect is secure. In order to prevent unauthorised access or disclosure, we have put in place industry standard mechanisms such as firewalls, data encryption and Secure Socket Layer and suitable physical, electronic and managerial procedures to safeguard and secure the personal information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.

In addition, we have implemented reasonable security measures to detect fraudulent identity verification activity and to prevent unauthorised access to or deletion of personal information in order to minimise cybersecurity risk

We cannot guarantee the security of any information that is transmitted to or by us over the Internet. The transmission and exchange of information is carried out at your own risk. Although we take measures to safeguard against unauthorised disclosures of information, we cannot assure you that the personal information we collect will not be disclosed in a manner that is inconsistent with this Privacy Policy.

Cookies and web beacons

We may use cookies on our Site from time to time. Cookies are text files placed in your computer’s browser to store your preferences. Cookies, by themselves, do not tell us your email address or other personally identifiable information. However, they do allow third parties, such as Google and Facebook, to cause our advertisements to appear on your social media and online media feeds as part of our retargeting campaigns. If and when you choose to provide our Site with personal information, this information may be linked to the data stored in the cookie.

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our Site. Your personal password to access the Site protects your privacy. We recommend that you do not disclose, share or reveal this password to any other individual.

We may use web beacons on our Site from time to time. Web beacons (also known as Clear GIFs) are small pieces of code placed on a web page to monitor the visitor’s behaviour and collect data about the visitor’s viewing of a web page. For example, web beacons can be used to count the users who visit a web page or to deliver a cookie to the browser of a visitor viewing that page.

We may use Google Analytics to collect and process data. To find out how Google uses data when you use third party websites or applications, please see https://policies.google.com/technologies/partner-sites/ or any other URL Google may use from time to time.

Links to other websites

Our Site may contain links to other websites. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not have any control over those websites and we are not responsible for the protection and privacy of any personal information which you provide whilst visiting those websites. Those websites are not governed by this Privacy Policy. We strongly recommend you read the privacy policy of every website you visit.

Controller

We are the controller responsible for your personal data. We have appointed a privacy officer who is trained and is responsible for overseeing issues of privacy. If you have any questions about this Privacy Policy, including requests to exercise your legal rights relating to this policy, please contact the privacy officer at michael.tsai@icanstudy.com.au. Records of your requests will be maintained by us.

Credit Card Information

We do not permanently store credit card information.

Standards of Privacy

We have established internal policies and procedures (including an IT and cyber security policy; an information and data retention and disposal policy; data protection by default and design and a privacy complaint and investigation procedure) to administer this Privacy Policy and we provide awareness and training to our employees and privacy officer in relation to it. We update such policies and procedures to maintain the integrity and standards required.

For high-risk data processing, we conduct Data Protection Impact Assessment.

In the event of a data breach which we are aware of, we will provide a breach notification to you within 72 hours.

Amendments

To the extent permitted by law, we may, at any time and at our discretion, vary this Privacy Policy by publishing the amended Privacy Policy on our Site. We recommend you check our Site regularly to ensure you are aware of our current Privacy Policy.

Contact Us

For any questions or notices, please contact our Privacy Officer at:

ICANSTUDY PTY LTD (ACN 644 853 967)

Email: help@icanstudy.com

Last update: 13 December 2021