Keypath Education Australia Pty Ltd ACN 168 643 730 trading as MBA Discovery (MBA Discovery) respects the importance of information privacy and is committed to ensuring its clients’ Personal Information is managed appropriately.
We are bound by the Privacy Act 1988 (Cth) (Act), as amended from time to time, and comply with the Australian Privacy Principles (APPs) as set out in the Act. The APPs regulate the manner in which we can collect, use, keep secure and disclose Personal Information.
We collect Personal Information about visitors to our website, our clients and potential clients, students, potential students, employees, potential employees, contractors, suppliers and other personnel with whom we liaise in order for us to properly conduct our business, provide services to our clients and to carry out our business functions and activities.
Where it is reasonably practicable for us to do so, we collect Personal Information directly from you. We endeavour to only collect Personal Information that is required from you. Sometimes we receive and collect Personal Information about you from third parties, such as our business associates, where it is legally allowable for us to do so. We may also collect Personal Information from publicly available sources.
We collect Personal Information about you when you make an enquiry with us and when we are otherwise engaged us to provide our products and services.
The kinds of Personal Information we may collect includes, but is not limited to:
We rarely need to collect Sensitive Information and will not do so unless we are authorised by law or otherwise have your consent.
Prior to collection Personal Information from you, we will take reasonable steps to inform you why the information is being collected, how it will be used and to whom it will be disclosed.
Generally, you are under no obligation to provide any Personal Information to us. However, if you do not provide the Personal Information we require, we may not be able to provide you with the services you have requested from us.
You can be anonymous or use a pseudonym when dealing with us, unless it would be impracticable for us to deal with you on such basis or if the use of your true identity is a legal requirement.
For example, we may not require any Personal Information from you to respond to a simple telephone enquiry regarding our services, however, we will require your Personal Information to perform services on your behalf.
We use Personal Information to conduct our business, to carry on our marketing activities and to comply with our legal obligations. In particular, we use Personal Information to:
We may also use Personal Information that we have collected to periodically send you promotional emails about new services or courses that may be of interest to you, special offers or other information which we think may be useful to you.
We use Personal Information for the primary purpose for which it is collected. We may also use your personal information for related purposes that you would reasonably expect including our administrative and accounting functions, marketing and promotions, feedback, newsletter communications, statistical collection and website analysis.
Your Personal Information is treated by us as strictly private and confidential, and will not be disclosed to third parties unless:
We will not disclose your Personal Information to third parties for the purposes of marketing of their products or services to you, other than those parties to which you have provided us prior agreement. We do not sell or trade personal information, or allow third parties to use that personal information for their own purposes.
We may disclose your Personal information to universities and other tertiary education providers in the course of providing our services to you, including providing your Personal Information to our related companies and to education providers which may be located outside Australia.
From time to time we may employ other companies and people to perform tasks on our behalf, and we may need to share your Personal Information with them to provide services to you.
You consent to us disclosing your Personal Information to an overseas recipient for purposes of providing our services and storing data where, in addition to the matters referred to above:
All reasonable steps will be taken by us to ensure that your Personal Information is accurate, complete and up-to-date. If however, you become aware that any of the Personal Information we hold about you is not accurate, complete or up-to-date, please contact us on the details below.
We may hold your information in either electronic or hard copy form. We take reasonable steps to protect all information that we hold, including Personal Information, from misuse and loss, and from unauthorised access, modification or disclosure.
We do this by:
Personal Information is destroyed or de-identified when it is no longer needed or when we are no longer required by law to retain it (whichever is the later).
You may request access to the Personal Information we hold about you at any time by contacting our Privacy Officer on the contact details below.
We may charge a fee to cover our reasonable costs of retrieval and copying. We may deny access to Personal Information where the Act allows us to do so. If you establish that Personal Information we hold about you is not accurate, complete or up-to-date, we will take reasonable steps to correct the information.
In most cases, we expect that we will be able to comply with your request. However, if we do not agree to provide you access or to correct the information as requested, we will always provide you with reasons for the denial of access or refusal to correct or destroy Personal Information.
We do not collect, use or disclose Sensitive Information about you (such as race, ethnicity, religion, sexual preference, health or criminal record) unless it is related to the provision of our services to you and you provide your consent, or where it is otherwise allowed by law.
We will retain your Personal Information whilst it is required for our business functions, or for any other lawful purpose. We use secure methods to dispose of Personal Information when it is no longer required, and you agree that we may de-identify or destroy your Personal Information:
Whenever you interact with our website, we automatically receive and record information from your browser such as your IP address, the type of browser or application you are using to access the website, and the identity of the pages and features you are visiting.
We may use your IP address to analyse trends, administer the website, and gather broad demographic data for aggregate use. We may also collect information regarding the device(s) you use to access the website.
We also utilise marketing automation based on cookies designed to track users and then appends that tracking data to accounts that users create with an email address.
We may collect the domain name, but not the email address of visitors to our website, your email addresses if you communicate with us via email, aggregate information on what pages you access and information provided by you, such as survey information and site registrations, name and address, and telephone number.
We have procedures in place for dealing complaints and concerns about our practices in relation to the Act and the APPs. If you believe that your privacy has been breached, please contact us using the contact information below and provide details of the incident so that we can investigate it.
We will treat your complaint confidentially, investigate your complaint and aim to ensure that your complaint is resolved within a reasonable time (and in any event within the time required by the Act, if applicable).
This policy was last updated in September 2019.
For all enquiries regarding Personal Information and to access your Personal Information, please contact our Privacy Officer by emailing firstname.lastname@example.org.