TRILOGY EDUCATION SERVICES (AUSTRALIA) PTY LTD

PRIVACY POLICY

 

Last Updated: March 2019

 

This Privacy Policy is incorporated by reference into the Terms of Use (the “Terms”). The terms “Boot Camp,” “we,” and “us” means Trilogy Education Services (Australia) Pty Ltd (ABN 53 625 057 132)  and its affiliates and subsidiaries.  Capitalized terms not otherwise defined herein shall have the meaning ascribed to them in the Terms.

 

The Privacy Policy and the Boot Camp Collection Notice explains how Boot Camp may:

  • collect,
  • hold,
  • use, and
  • disclose

personal information we obtain through the Service (as defined in the Terms). It also explains how an individual may seek to access or correct their personal information or make a privacy complaint.

 

We are bound by the Australian Privacy Principles contained in the Commonwealth Privacy Act 1988. If we hold any health records, we are bound by the relevant State/Territory health records legislation (if any).

 

By using techbootcamp.sydney.edu.au (the “Site”) and the Service, you are authorizing us to collect, hold, use and disclose data related to you and the provision of the Service in accordance with this Privacy Policy.

 

“Personal Information” includes information or an opinion, whether true or not, and whether recorded in material form or not, about an identified individual, or an individual who is reasonably identifiable. It includes personal information such as your name, email address, home or other physical address, and phone number and which is not otherwise publicly available. This may include sensitive information, which is information or an opinion about an individual’s race or ethnic origin. Personal Information may include other types of information depending on the definition of that applies in your physical location.  Only the legal definition of Personal Information that applies in your location will apply to you under this Privacy Policy.

 

“Education Records” includes those records that contain information directly related to a Course participant and which are maintained by an educational agency or institution or by a party acting for the agency or institution.  For the purposes of this Privacy Policy, “Education Records” includes name, address, email, cell phone, date of birth, race, gender, previous salary information, current industry of employment, enrolment dates, classes taken, attendance, homework completion rate, grades, evaluations, pre-work, participation in career services in general as well as specific events attended, survey data, your portfolio/projects, feedback provided regarding the Service, your trainers, tutors and career services personnel.

 

Personal Information and Education Records do not include information that has been de-identified or made anonymous.

 

This Privacy Policy may change from time to time, so please check back periodically to check the most recent modification date to ensure that you are aware of any changes. If you do not agree to such changes, you must immediately stop using the Site and Services.  This privacy policy was last updated in March 2018.

 

AGREEMENT AND YOUR EXPRESS CONSENT

By using this Site and/or the Service, you accept and hereby expressly consent to our collection, use, and disclosure of your Personal information and Education Records in accordance with the terms of this Privacy Policy.  In addition, you expressly consent to the receipt of electronic messages from the Boot Camp, including emails and text messages and including promotional emails and text messages. This Consent is effective immediately and remains valid until you opt-out of receiving any further electronic messages from Boot Camp.  This Consent shall not be voided upon your completion or withdrawal from the Boot Camp or in the event your educational institution no longer does business with us, unless you opt-out of receiving any further electronic messages from Boot Camp.

 

This Privacy Policy may change from time to time, so please check back periodically to check the most recent modification date to ensure that you are aware of any changes. If we make any material changes to the collection, use or disclosure of Education Records, we will notify you by means of a notice on this Site prior to the change becoming effective and you will be required to log in and consent to the changes in order to continue to use the Site. Your continued use of the Site or the Service after any changes signifies your express consent to any such changes.   If you do not agree to such changes, you must immediately stop using the Site and the Service.  This Privacy Policy was last modified in February 2019.

 

THE INFORMATION Boot Camp COLLECTS FROM YOU

 

In order to provide our services, we collect Personal Information (such as your name, email, login and password details, registrations and applications, postal address and telephone number) when you:

  • create an account;
  • register or apply for a Course, either directly or by using your social networking credentials on the Service or a third-party website;
  • participate in our surveys, promotions and competitions;
  • sign up for a newsletter;
  • post information to the Service that includes Personal Information; and
  • communicate with us, for example to submit queries regarding the Site or the Boot Camp Service.

We also collect information, such as IP address, location data, and anonymous usage statistics, by using cookies, server logs, and other similar technology as you use the Service. See below for more information on our use of cookies on this Site.

 

Registration. To create an account, you must provide your name, email address, phone number, postal address, and date of birth. You may also provide other optional information, such as gender, previous salary information, current industry of employment.

 

Using the Service.  If you post Personal Information in a comment or to a chat room, blog or other public area of the Site, we may collect the information you post.   Posted information is also available for viewing and disclosure by other users of the Site, and we have no control over such use.  We discourage posting sensitive or Personal Information in comments as they are viewable by the public.

 

Social Log-In. When you use your social media credentials to register for a Course or to post a comment to the Service, we collect Personal Information from the social media website. For example, when you log in with your Facebook credentials, we may collect the Personal Information you have made publicly available in Facebook, such as your name and profile picture or logo. We may also collect your email address.  Please note that our Site is not sponsored or endorsed by any social media sites, which are trademarked and owned by third parties and not by us and which have their own privacy policies and terms of use.

 

From Third Parties. We may use third parties to perform certain tasks for us, such as facilitating your purchase of a Course. Such third parties will provide us with Personal Information, such as your name, address, and email address, which you provide to them so that we have your information for Course rosters.

 

Customer Support. We may collect Personal Information through your communications with our customer-support, marketing, admissions, Course participant support, career services and sales teams.  This information will be used to send you information you have requested from us and to send you promotional email messages.  You may unsubscribe from promotional emails by clicking “unsubscribe” on the emails you receive from us.

 

Making Payments. When you make payments to pay for a Course, you must provide Personal Information to our third-party service providers, including first and last name, email address, phone number, mailing address and credit card information.

 

Promotions and competitions.  If you choose to participate in a promotion or competition, we may collect, use and disclose information as described in the promotion or competition.

 

Surveys.  In most cases, information from surveys will be used on an anonymous basis to help us improve the Service.  In certain limited cases, we may disclose information collected by a survey to trainers, tutors, or career coaches in order to provide educational or career support such as tutoring or career counseling.

It is always your choice whether or not to provide us with such information.  If you do provide information to the Site, you are giving your express consent to the collection, use, retention and disclosure of the information as described in this Privacy Policy. If you choose not to provide the requested information you may not be able to access the Service or certain features of this Site.  You may access or change your information as described below.

 

Cookies, Automatic Data Collection, and Related Technologies. The Service collects and stores information that is generated automatically as you use it, including your preferences and usage statistics. When you visit the Service, we and our third-party service providers receive and record information on our server logs, including your IP address, the type of internet browser or device you use any website you have come to the Site from and your operating system. The Site also uses cookies and similar technology. Cookies are small text files that include a unique reference code placed in a visitors’ device to store their preferences and sometimes track information. A number of cookies we use last only for the duration of your web session and expire when you close your browser. Other cookies are used to remember you when you return to our Site and will last for longer.

 

We use cookies for the following reasons:

 

Strictly necessary cookies: These cookies are essential in order to enable you to move around the Site and use its features, such as accessing the secure areas of the Site. They also enable us to deliver services you have asked for.

  • Examples of strictly necessary cookies set by us are cookies that keep you logged in during your visit on the Site and that enable you to navigate between pages during a browser session so that you can use the Site most efficiently.

 

Performance cookies: These cookies collect statistical information on how visitors use our Site so that we can make improvements to the Site, how it works and our services. These cookies don’t collect information that identifies visitors. The information that is collected is aggregated and therefore anonymous.

  • Examples of performance cookies set by us are cookies that track website traffic and help us collect data about what users are doing on our Site so that we can improve our website and enhance your overall experience.

 

Functionality cookies: These cookies allow the Site to remember choices you make such as your user name when you login to your account or the language or region you are in. They may also be used to help you watch a video or comment on a blog and are intended to improve your online experience.

  • Examples of functionality cookies set by us are cookies that may serve a different version of the Site to you as compared to other users to determine which version works better, cookies that prevent you from seeing different homepages or other split tests in the future, and bookmarking cookies that help us retrieve and display information you stored on our Site for your next visit.

 

Internet-based advertising Cookies: Our advertising partners use cookies that gather information about the pages you visit on the Site and also other information about other websites that you visit, so as to place you in a “market segment”. This information is then used to place interest-based advertisements, which it is believed will be relevant to your market segment. For more information about this type of interest based advertising, and about how to turn this feature off please visit www.youronlinechoices.com. Without these cookies, advertisements you encounter will be less relevant to you and to your interests.

  • Examples of internet-based advertising cookies set by us are cookies that tell us where you came from so that we can evaluate marketing and advertising campaigns, cookies that help us determine where you are located so that we can serve you advertisements that are relevant to you based on your location and cookies that help us group you into interest groups with other users so that we can show you advertisements that are relevant to you while you’re on our Site and on other websites.

 

Some of the cookies on our Site are set by us (first party cookies) and some are set by third parties who are delivering services on our behalf.

Most computer and some mobile web browsers automatically accept cookies but, if you prefer, you can use your browser to notify you each time a cookie is set or to block and delete cookies from your browser. However, please note that if you do that, the Service may not work properly and you may not be able to take full advantage of the Site or our services. You can learn more about cookies by visiting www.allaboutcookies.org which includes additional useful information on cookies and how to block cookies using different types of browser.

 

 

HOW WE USE YOUR INFORMATION

 

We use your Personal Information for the following purposes:

 

  • Identify you and your account;
  • Provide and improve our services;
  • To communicate with you; and
  • For our marketing purposes;

 

You can opt out of promotional or marketing emails by clicking on “unsubscribe” at the bottom of the emails you receive from us.  You can stop text messages by texting “STOP” to text messages you receive from us.

 

INFORMATION SHARING AND DISCLOSURE

We may disclose your Personal Information and Education Records to (i) business partners (including providers of technology platforms) involved in the fulfillment of the program so that they can assist us in delivering the Service and other services we provide to you, (ii) potential employers so that they may make a determination as to whether to hire you, and (iii) The University of Sydney (ABN 15 211 513 464)  so that they can collaborate with us to: provide the Service, track your progress, work with us to assist you in the event that you are dissatisfied or need assistance, and provide you with a Statement upon completion.  These third parties are contractually obligated to maintain the confidentiality of your Personal Information consistent with the terms of this policy and to comply with the applicable data or privacy protection laws.

 

Displaying to Other Users. If you post content to the Service it may be displayed on the Service. Other users of the Service may be able to view and use information you post, such as information contained in comments posted in a chat room or on a blog post.  We do not have responsibility or liability for information you post.  You should exercise caution when using public forums and not disclose your personal information.

 

Social Networking and Other Websites.  Our Site includes features from third party social media platforms such as Facebook, Twitter, Instagram and Pinterest and allows for social sign-on from social media platforms that run on our Site.  Please note that our Site is not sponsored or endorsed by any of these, which are trademarked and owned by third parties and not by us.  These features may collect your IP address, which page you are visiting on our Site, and may set a cookie to enable the feature to function properly. Social media features are either hosted by a third party or hosted directly on our Site.  The Service may allow you to post information to social networking websites.  Any information you post will be viewed and used by others and we have no control over such information.  If you direct the Service to share your information with social media or other websites, we will share that information.  Any information you share from or with social media is governed by the privacy policy and other policies of the social media platform and not by this Privacy Policy.

 

Disclosure to Advertisers and Marketers. If you have given us permission to send you information about the products and services of third parties we may disclose your Personal Information and Education Records to advertisers whose content we publish or display; with third party ad servers to serve you advertisements; and with companies who may resell, exchange or provide your information to others for their marketing purposes, including sending you promotional emails or text messages on their own behalf  or on behalf of other companies. This will be in accordance with legislation including the Spam Act 2003 (Cth), the Do Not Call Register Act 2006 (Cth) and the Privacy Act 1988 (Cth).

We will also disclose your information in response to valid legal process, for example, in response to a court order, a subpoena or other legal request for information, and/or to comply with applicable legal and regulatory reporting requirements.  We also may disclose your information in response to a law enforcement agency’s request or other request for information from the U.S. or other government entities, or where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, or to verify or enforce compliance with the policies governing our products and/or services and with applicable laws, or as otherwise required or permitted by law or consistent with legal requirements.  In addition, we may transfer your information to an entity or individual that acquires, buys, or merges with us, or our other business units.

 

We may also disclose your Personal Information or Education Records with your permission, for example, with potential employers.

 

Merger, Sale, or Other Asset Transfers and Investors. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, your information which we have collected may be used, sold or transferred to third parties such as venture capital or private equity groups, investment banks, or successor companies as part of such a transaction as permitted by law and/or contract. We cannot control how such entities may use or disclose such information.

 

 

PAYMENTS

Payments made on the Site are made through our third-party payment vendor.  If you enrol through the Site, you will be providing payment and/or or credit card information, including your name, billing address and other payment information, directly to our payment vendor which operates a secure server to process payments details, encrypting your credit/debit card information and authorize payment. If you enrol over the phone, our agents will enter your information into our payment vendor’s terminal and a copy of such information will be stored in on our servers.  We collect and store payment information in order to verify payment and resolve payment disputes.  Payment information is subject to each of our payment vendors’ own privacy policy and terms and conditions.

 

LINKS TO OTHER SITES

The Site may contain links to other sites that are not owned or controlled by us. Please be aware that we are not responsible for the privacy practices of these other sites. We encourage you to review the privacy policies and statements of other sites to understand their information practices. Our Privacy Policy applies only to information collected by our Site and the Service.

 

SECURITY OF YOUR INFORMATION

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration and disclosure. All information you provide to us is stored on secure servers located in the U.S., and may be accessed from our offices in the U.S., Canada, U.K., Ireland and Mexico All information provided and transactions conducted on our Site, including payment transactions, will be encrypted using SSL technology.

 

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Site, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Site like message boards. The information you share in public areas may be viewed by any user of the Site.

 

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Site. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site.

 

DESTRUCTION OF PERSONAL INFORMATION

If you enrol in and complete a Boot camp course we, and our business partners and education partners, will keep your relevant Personal Information, to confirm completion records and details if required. If you make an enquiry about a Boot Camp course we will keep your name and contact details for 3 years, and if after this time you do not enrol in a Boot Camp course, we will destroy our record of your Personal Information. If you ask that we do not keep your Personal Information for this 3 year period, and you ask us to stop providing our marketing information to you, we agree to destroy our record of your Personal Information.

 

CHILDREN’S PRIVACY

We do not knowingly collect information from children under 13. We will take steps to delete such information if we become aware that we have collected it.

 

We do not knowingly collect, maintain, or use Personal Information from children under 13 years of age, and no part of the Service is directed to children under the age of 13. If you learn that your child has provided us with Personal Information without your consent, you may alert us using the contact information below. If we become aware that we have collected any Personal Information from children under 13, we will promptly take steps to delete such information and terminate the child’s account.

 

GOVERNING LAW/INTERNATIONAL USERS

 

By choosing to visit the Service or otherwise provide information to us, you agree that any dispute over privacy or the terms contained in this Privacy Policy will be governed by the Privacy Act 1988 (Cth)and the Australian Privacy Principles (APPs) the adjudication of any disputes arising in connection with Boot Camp or the Service will be in accordance with the Terms.

 

The Site and the Service are based in the U.S.   Any data or Personal Information provided to the Site or the Service will be processed and stored in the U.S., and may be accessed from our offices in the U.S., Canada, U.K., Ireland and Mexico where our servers are located.  By using the Site or the Service, you expressly consent to the collection, retention, use, disclosure and transfer, including international transfer of your Personal Information to the U.S., Canada, U.K., Ireland and Mexico in accordance with this Privacy Policy, regardless of your physical location, and understand that Boot Camp can’t ensure that overseas recipients of your Personal Information and/or Education Records will comply with the APPs.

 

ACCESS, CORRECT OR UPDATE YOUR INFORMATION; QUESTIONS; COMPLAINTS OR POSE A QUESTION OR SUGGESTION

You have the right to request to access and/or correct your Personal Information. If you would like to obtain a copy of the Personal Information and/or Education Records held about you by us, update, amend or correct any information that you have provided to us through your use of the Service or otherwise, or if you have any questions or suggestions for improving this Privacy Policy, please contact us using the information below.   We may ask you to provide evidence or your identity before we deal with your request. If you have a question or complaint regarding your Personal Information or Education Records, or if you wish to exercise any rights to your information please contact us using the information provided below.  In the event of a conflict between this Privacy Policy and any law that applies to you, we will follow the applicable law.

 

We will deal with your request to access and/or correct your Personal Information and/or Education Record as soon as is practicable after we receive it. While we will not charge you for making a request to access your Personal Information, we may require you to pay our reasonable costs of providing you with that information.  We will not charge you for making a request to correct your Personal Information and/or Education Record with that information.  We will not charge you for making a request to correct your Personal Information and/or for our costs of correcting your Personal Information and/or Education Record.

 

COMPLAINTS

 

If you would like to make a complaint about our handling of your Personal Information, or have a query or concern about our handling of your Personal Information, please contact us using the contact details at the end of this privacy policy.

 

We may ask you to put your complaint in writing. We will investigate and respond to your complaint as soon as is practicable after we receive it.

 

If you are not satisfied with our response to your complaint, you can refer it to the Office of the Australian Information Commissioner (https://www.oaic.gov.au).

 

 

TERMS OF USE

Please also review our Terms of Use section establishing the use, disclaimers and limitations of liability governing the use of our website at techbootcamp.sydney.edu.au

 

CONTACT INFORMATION

If you have any questions about our handling of your Personal Information and/or Education Record, wish to request access to or correct your information, or wish to make a privacy complaint, please contact us using one of the methods below:

 

Boot Camp

bootcamp@trilogyed.com