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PRIVACY POLICY

OUR COMMITMENT

Upskill Learning Management System Pty Limited ACN 151 618 364 (Upskill LMS, we, us, our) respects your privacy and is committed to maintaining the privacy and confidentiality of personal information we collect, store, manage and disclose, in accordance with the Privacy Act 1988 (Cth).

This Privacy Policy describes the ways we collect information from and about you, and what we do with such information, so that you may decide whether or not to provide personal information to us.

This Privacy Policy applies only to information collected in connection with the website and the services provided by Upskill LMS, and not to any third party websites or services that you may be able to access through any services provided by Upskill LMS (including through the website). Such third parties may have data collection and use practices and policies that differ materially from this Privacy Policy.

By visiting Upskill LMS websites, accessing or otherwise using any Upskill LMS products or services, or by otherwise providing personal information to Upskill LMS, you accept and consent to the practices described in this Privacy Policy.

INFORMATION WE COLLECT ABOUT YOU

We collect and store the personal information that is provided by you, or on your behalf, when you use this website or any of the products or services that are available through this website (including when you create an account or other registration through the website or any associated services), or when you contact or transact with us for any other purpose, including if you complete any surveys associated with the website or our services. The personal information we collect may include: your name, contact information, payment card and account details, IP addresses, product and service selections and orders or other things that identify you individually.

When you create any account or registration, or enter into any transaction, on behalf of another person on this website, we will request personal information about that individual. You must obtain the consent of other individuals prior to providing us with their personal information and you must ensure that such individuals are aware of and accept this Privacy Policy.

Wherever it is lawful and practicable, we will endeavour to provide you with the option of not identifying yourself or not providing personal information when entering into transactions with us. However, failure to provide full and complete information we request may mean that we are unable to provide the relevant product, services or assistance to you or any other person for whom you are acting.

This is a general audience website and does not offer services directed to children. Upskill LMS does not knowingly collect or maintain personal information from persons under 13 years of age. If we learn that a user of the website is under 13 years of age or if we learn that personal information of persons under 13 years of age has been collected without verifiable parental consent, we will take steps to promptly delete such personal information.

USE OF PERSONAL INFORMATION

We may use the information we collect for the following general purposes: process service requests; to deliver products and services to you and/or any other person for whom you are acting; to process payments; to communicate with you; to provide access to secure areas of the website or other Upskill LMS services; for the purposes of direct marketing, including to conduct market research and to recommend products or services that might be of interest to you; to personalise your visit to our website; and to enable us to review, develop and continually improve the products and services we provide. We also use this information to prevent or detect fraud or abuses of our website and services, and to enable third parties to carry out technical, logistical or other functions on our behalf. By providing us with your information, you consent to each of the types of use described in this Privacy Policy.

We may ask visitors to enter credit card or account information in order to process orders for products and services. Financial information provided via our website is transmitted over a secure connection. Credit card numbers are used only for processing payments and are not used for any other purposes.

We use web visit information to measure interest in and develop our web pages and marketing plans, to customise the content you view on your visits based on your activity on past visits, and to administer our website.

When you visit our website, create an account or otherwise participate in any courses, details are recorded about your visit, such as time and date, your server address, pages accessed, time spent and type of browser. This information is used in an anonymous form for statistical purposes and as such cannot identify you individually.

We use Cookies to identify your browser so that next time you visit our website we remember your log in details. A Cookie is a small file which remains on your computer and contains information enabling our website to recognise your browser. If you do not wish to use Cookies, you can adjust the settings on your browser to reject Cookies or notify you when they are being used.

DISCLOSURE OF PERSONAL INFORMATION

Personal information we gather is for internal use only, however, we may disclose your information to the following entities:

  • Third-party suppliers who provide services or functions on our behalf, including (but not limited to) credit card processing, business analytics, customer service, marketing, and fraud prevention. Third-party vendors have access to and may collect information only as needed to perform their functions and are not permitted to share or use the information for any other purpose.
  • Course providers who create, sell, or otherwise make available any courses, or access to any courses, in connection with the Upskill LMS website and services (Course Providers).
  • Business partners with whom we may jointly offer products or services.
  • Related companies within the Upskill LMS corporate group. To the extent that our related companies have access to your information, they will follow practices that are at least as restrictive as the practices described in this Privacy Policy.

By providing us with your information, you consent to each of the types of disclosure described in this Privacy Policy. Please note that we do not control the privacy practices of Course Providers or any third-party business partners.

We may also disclose personal information in the following circumstances:

  • Where required by law in the good faith belief that disclosure is necessary to comply with applicable laws or legal processes or to respond to any regulatory authority.
  • When we believe it is appropriate to investigate, prevent, or take action regarding illegal or suspected illegal activities; to protect and defend the rights, property, or safety of Upskill LMS, the website or others, and in connection with our terms of use and other agreements.
  • In connection with a corporate transaction, such as a sale of a subsidiary or a division, merger, consolidation, or asset sale.
  • To assist with industry efforts to control fraud, spam or other undesirable conduct. This may include exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

We also may share aggregate or anonymous information with third parties, including advertisers, investors and Course Providers. For example, we may tell Course Providers the number of visitors our websites receive or the number of times their courses are viewed. This information does not contain any personal information and is used to develop content and services we hope you will find of interest and to audit the efficacy of our advertising.

If we wish to give your contact or personal information to a third party under any other circumstances not described in this Privacy Policy, we will notify you and give you a chance to opt out.

ADVERTISING OPTIONS

Online behavioural advertising (OBA) allows us to deliver customised advertising to visitors to our website. OBA allows us and our third party suppliers to deliver to you adverts that are based on your browsing patterns and other interaction with this website.

Some of the cookies we place on your computer or device may be advertising cookies so we can understand the types of pages and courses that you are interested in, and customise your experience based on that information. For example, if you search for courses about learning a language, we may show you advertisements relating to language courses that are available through our website.

Please note that the OBA techniques we may use do not require us, our business partners, or advertising networks to collect personal information such as your name, email address or telephone number.

We may also share the anonymised behavioural data with advertising partners. This may mean that when you are visiting other websites, you are served adverts based on your behaviour on our website.

If you wish to opt-out of receiving OBA, this does not mean that you will no longer receive advertising. It simply means that the advertising delivered to you will not be customised.

SHARING WITH SOCIAL NETWORKS

If we provide you with the ability to log-in or create an account using a social network, such as Facebook or Twitter, you consent to the relevant social network sharing with us your user information. This may include your name, email address, location, and your profile picture.

If we provide you with the functionality to share or otherwise publish any of your interactions with our website or a Course Provider to any social network (for example, by providing an application that allows you to post any course results to Facebook), you acknowledge and agree that such post or publication is beyond the control of Upskill LMS, and the privacy policy of the relevant social network governs the collection and use of the information shared with that site.

TRANSBORDER DATA FLOWS

Please be aware that your information may be transferred to, stored, and processed in Australia, where our servers are located and our central database is operated. In addition, some of our third party service providers are in locations outside Australia, such as countries within the European Union.

To the extent that your personal information is disclosed by Upskill LMS to locations outside Australia, you warrant that you understand that those countries may not have the same or substantially similar privacy laws to those in Australia (or the country in which you are located). By using the website and any services available through the website, you understand that your information may be transferred to our facilities and those third parties with whom we share it as described in this Privacy Policy (including facilities and third parties located in other countries), and you consent to such transfer and disclosure. By consenting to such transfer, you acknowledge that we are not required to ensure that the overseas recipient complies with all Australian Privacy Principles in relation to the relevant information.

SENSITIVE INFORMATION

We will not intentionally collect or maintain, and do not wish for you to provide to us with, any sensitive information including, but not limited to, racial or ethnic origin, religious affiliations, sexual preferences or health information.

AREAS BEYOND OUR CONTROL

Information collected by Course Providers

By enrolling or otherwise participating in any course that is made available through Upskill LMS, you acknowledge and agree that the information provided when registering, enrolling or participating is collected by the relevant Course Provider responsible for creating, selling, and/or otherwise making the course(s) available, or may be collected by the Course Provider’s principal, agents, suppliers, contractors, resellers or other representatives. Such parties may be located in a different country to you. The privacy practices of the relevant Course Provider(s) may differ from Upskill LMS’ practices and are not controlled by Upskill LMS or covered by this Privacy Policy. It is your responsibility to review their privacy practices before providing any personal information.

Links provided by Course Providers

Course Providers may provide links to their own or to other third-party websites (Course Provider Linked Sites). The privacy practices of Course Provider Linked Sites may differ from Upskill LMS practices and are not controlled by Upskill LMS or covered by this Privacy Policy. We do not make any representations about Course Provider Linked Sites. It is your responsibility to review their privacy practices before submitting your any personal information.

Links To non-Upskill LMS websites

We may provide links to third-party websites for your convenience and information. The privacy practices of those sites may differ from Upskill LMS practices and are not controlled by Upskill LMS or covered by this Privacy Policy. We do not make any representations about third-party websites. It is your responsibility to review their privacy practices before submitting your personal information.

Public forums

The website may include interactive forums such as blogs, message boards and discussion forums. Any information that is disclosed in these areas becomes public information and we strongly recommend that you exercise caution when deciding to disclose your personal information. Upskill LMS is not liable for any disclosure of your personal information or other information as a result of your use of any such public forums, that you display publicly or that becomes publicly known as a result of your actions.

SECURITY OF THE INFORMATION WE COLLECT

Upskill LMS recognises its obligations under the Privacy Act to prevent the loss, misuse, interference with, and unauthorised access, modification and disclosure of the personal information in our possession. We use various security measures to protect the personal information we collect, as appropriate to the type of information, including encryption, firewalls, and access controls.

RIGHT TO ACCESS YOUR PERSONAL INFORMATION

The Privacy Act 1988 gives you the right to request access to and correction of personal information held about you. You can access and update your contact information by visiting your account on the website or, if that does not work, by sending your request by email to info@upskilllms.com.

A reasonable fee will be charged for the processing of any data access request.

We always endeavour to make sure that the information we hold about you is accurate, up to date, and complete. If you believe that any information we are holding on you is inaccurate, incorrect or incomplete, please email us as soon as possible, at the above address. We will take reasonable steps to correct, complete, delete or block any information found to be incorrect.

COMPLAINTS PROCEDURE

If you wish to complain about the manner in which we have handled your personal information, please contact us by email at info@upskilllms.com.

GOVERNING LAW

This Privacy Policy is governed by the laws in force in New South Wales, Australia. You agree to submit to the exclusive jurisdiction of the courts of that state.

CHANGES TO THE PRIVACY STATEMENT

You are encouraged to check this Privacy Policy periodically, as we may from time to time make changes to the Privacy Policy, which will come into effect from the time of posting of an amended Privacy Policy on this website.

This Privacy Policy was last updated in August 2014.