PRIVACY POLICY

Your privacy is important to ACWE Pty Ltd. This privacy statement provides information about the personal information that ACWE Pty Ltd collects, and the ways in which ACWE Pty Ltd uses that personal information.

1. PERSONAL INFORMATION COLLECTION

ACWE Pty Ltd may collect and use the following kinds of personal information:

• Information regarding your use of this website
• Information you provide using for the purpose of registering with the website
• Information regarding transactions conducted over this website
• Information you provide for the purpose of subscribing to the website services
• Other information you send to ACWE Pty Ltd

Where ACWE Pty Ltd discloses your personal information to its agents or sub-contractors for these purposes, the agent or sub-contractor in question will be obligated to use personal information in accordance with the terms of this privacy statement.

In addition to the disclosures reasonably necessary for the purposes identified elsewhere above, ACWE Pty Ltd may disclose your personal information to the extent that it is required to do so by law, in connection with any legal proceedings or prospective legal proceedings, and to establish, exercise or defend its legal rights.

1.1 ACWE Pty Ltd will only collect personal information where the information is necessary for to perform one or more of its functions or activities. In this context, “collect” means gather, acquire or obtain by any means, information in circumstances where the individual is identifiable or identified.

1.2 ACWE Pty Ltd collects personal information for the primary purpose of course registrations. ACWE Pty Ltd also collects and uses personal information for secondary purposes including:

• Print and digital marketing
• Testimonials and reviews
• Direct marketing
• Event registrations and attendance
• Monitoring and analysing trends, usage, and activities in connection with the use of our site

1.3 ACWE Pty Ltd will notify individuals of the matters listed below at the time of collecting any personal information:

• The main reason that we are collecting personal information (this reason will be the primary purpose);
• Other related uses or disclosures that we may make of the personal information (secondary purposes);
• Our identity and how individuals can contact us, if this is not obvious;
• How individuals can access the personal information that ACWE Pty Ltd holds about them;
• That individuals should contact ACWE Pty Ltd (even if they are not a customer or an employee of a customer) if they wish to access or correct personal information collected by us or have any concerns in relation to personal information;
• The organisations or types of organisations to whom we usually disclose the personal information;
• Where applicable, any law that requires the personal information to be collected;
• The consequences (if any) for the individual if all or part of the personal information is not provided to ACWE Pty Ltd.

1.4 Where it is not practicable for ACWE Pty Ltd to notify individuals of all of the collection information before the collection of personal information, ACWE Pty Ltd will ensure that individuals are notified of the collection information as soon as possible after the collection. ACWE Pty Ltd will provide “post collection notification” in those circumstances where it is not practicable to notify individuals about the collection of their personal information before it is collected.

1.5 ACWE Pty Ltd will not collect sensitive information from individuals except with express consent from the individual and only where it is necessary for ACWE Pty Ltd to collect such information for an activity or function.

1.6 ACWE Pty Ltd will not collect personal information secretly or in an underhanded way. For transparency, this is how ACWE Pty Ltd automates the processing of data:

• We automatically collect certain information to track visitor activity on our websites. We use this information to improve the content of our sites as well as to provide visitors with a more relevant overall experience with our organization and our site.
• This information may include information that identifies you as an individual or relates to an identifiable individual, including name, title, company name, job function, expertise, postal address, telephone number, or email address.
• We may also collect other information that does not reveal your specific identity or does not directly relate to an identifiable individual such as browser and device information, information collected through cookies, pixel tags, and other technologies, and demographic information.
• We never share this information or information you provide us with third parties except to the extent necessary to provide our Service. See section 4. Disclosure.

• If you fill out a web form on our site, your information will be stored in our system and some amount of your past browsing on our site may be available to us to determine your interests. We may use this information to engage with you more effectively and to improve our site. However, if you use private browsing as described below, you may provide us your information without making your past browsing activity available to us. If you do not wish for us to have your personal information, please do not fill out any of the web forms on this site.
• If you provide your email address and consent, some information is collected about when/if the email was opened and what links were clicked. This information is used to assess the engagement and success of an email campaign. Clicking on a link in any of these emails may cause you to be personally identified on our site and may cause some part of your past browsing history on our site to be available to our personnel so we may more effectively engage with you and improve our site.
• If you do not wish for this tracking to occur, you can unsubscribe from our mailings or use private browsing mode to avoid tracking.
• If you do not want this site to place a cookie on your browser and track your activity, you may leave the site, or you may browse the site using privacy mode in your web browser. To learn how to use privacy mode, refer to the links below depending on the browser you use.
• InPrivate mode in Microsoft Edge
• Incognito mode in Google Chrome
• Private browsing mode in Mozilla FireFox
• Private browsing mode in Apple Safari

2. USE

2.1 ACWE Pty Ltd will obtain an individual’s consent for use of non-sensitive personal information for secondary purposes at the time of collection, unless the use is a related secondary purpose which would be within the relevant individual’s reasonable expectations.

2.2 ACWE Pty Ltd uses personal information primarily for the purposes listed in 1.2 above.

2.3 If ACWE Pty Ltd relies on the direct marketing exception to direct market to individuals it will ensure that:

• Individuals are clearly notified of their right to ‘opt out’ from further direct marketing; and
• If the individual opts out of all direct marketing, the opt out will be respected by ACWE Pty Ltd and implemented free of charge.

2.4 ACWE Pty Ltd will not use sensitive information for direct marketing.

2.5 ACWE Pty Ltd may use personal information to avoid an imminent threat to a person’s life or to public safety. It may also use personal information for reasons related to law enforcement or internal investigations into unlawful activities.

2.6 ACWE Pty Ltd will not use personal information without taking reasonable steps to ensure that the information is accurate, complete and up to date.

2.7 ACWE Pty Ltd will not attempt to match de-identified or anonymous data collected through surveys or such online devices as “cookies”, with information identifying an individual, without the consent of the relevant individual.

3. DISCLOSURE

3.1 ACWE Pty Ltd may disclose personal information to related or unrelated third parties only if consent has been obtained from the individual.

3.2 ACWE Pty Ltd may disclose personal information to unrelated third parties to enable outsourcing of functions where that disclosure or use is for a related secondary purpose and has been notified to individuals or where such disclosure is within the individual’s reasonable expectations.

3.3 ACWE Pty Ltd will take reasonable steps to ensure that its contracts with third parties include requirements for third parties to comply with the use and disclosure requirements of the Privacy Act.

3.4 In the rare event that ACWE Pty Ltd is required to disclose personal information to law enforcement agencies, government agencies or external advisors, ACWE Pty Ltd will only do so in accordance with the Privacy Act or any other relevant Australian legislation.

3.5 ACWE Pty Ltd may disclose personal information to avoid an imminent threat to a person’s life or to public safety.

3.6 If a disclosure is not for a primary purpose; is not for a related secondary purpose; or upfront consent has not been obtained, ACWE Pty Ltd will not disclose personal information otherwise than in accordance with the exceptions set out at 3.1 to 3.6 above.

3.7 ACWE Pty Ltd does not generally share its customer lists on a commercial basis with third parties but if it did, it would only do so if the appropriate consent had been given by the individual involved.

4. INFORMATION QUALITY

4.1 ACWE Pty Ltd will review, on a regular and ongoing basis, its collection and storage practices to ascertain how improvements to accuracy can be achieved.

5. INFORMATION SECURITY

5.1 ACWE Pty Ltd requires team members and subcontractors to perform their duties in a manner that is consistent with ACWE Pty Ltd legal responsibilities in relation to privacy.

5.2 ACWE Pty Ltd will take all reasonable steps to ensure that paper and electronic records containing personal information are stored in facilities that are only accessible by people within ACWE Pty Ltd who have a genuine “need to know” as well as “right to know”.

5.3 ACWE Pty Ltd will review, on a regular and ongoing basis, its information security practices ascertaining how ongoing responsibilities can be achieved and maintained.

6. ACCESS AND CORRECTIONS

6.1 ACWE Pty Ltd will allow its records containing personal information to be accessed by the individual concerned in accordance with the Privacy Act.

6.2 ACWE Pty Ltd will correct its records containing personal information as soon as practically possible, at the request of the individual concerned in accordance with the Privacy Act.

6.3 Individuals wishing to lodge a request to access and/or correct their personal information should do so by contacting ACWE Pty Ltd, as per the details on this document.

6.4 ACWE Pty Ltd will not normally charge a fee for processing an access request unless the request is complex or is resource intensive.

7. OPENNESS

7.1 Contact with ACWE Pty Ltd via phone or web inquiry will be the first point of contact for inquiries about privacy issues.

7.2 Any formal privacy-related complaints must be directed in writing to the ACWE Pty Ltd Privacy Officer, Level 6 31 Market Street, Sydney NSW 2000.

7.3 ACWE Pty Ltd will endeavour to manage any privacy-related complaint efficiently and in a timely manner.

7.4 ACWE Pty Ltd ‘s websites will contain a prominently displayed privacy policy link and will include a copy of this ACWE Pty Ltd Privacy Policy.

8. ANONYMOUS TRANSACTIONS

8.1 ACWE Pty Ltd will not make it mandatory for visitors to its web sites to provide personal information unless such personal information is required to answer an inquiry or provide a service. ACWE Pty Ltd may, however, request visitors to provide personal information voluntarily to ACWE Pty Ltd (for example, as part of a competition or questionnaire).

8.2 ACWE Pty Ltd will allow its customers to transact with it anonymously wherever that is reasonable and practicable.

9. SECURING YOUR DATA

ACWE Pty Ltd takes all reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information. ACWE Pty Ltd will store all the personal information you provide on its secure servers. [Information relating to electronic transactions entered via this website will be protected by encryption technology.

10. TRANSFERRING YOUR INFORMATION

Cross-border data transfers
Information which ACWE Pty Ltd collects may be stored and processed in and transferred between any of the countries in which ACWE Pty Ltd operates to enable the use of the information in accordance with this privacy policy.

[In addition, personal information you submit for publication on the website will be published on the internet and may be available around the world.] You agree to such cross-border transfers of personal information.

10.1 ACWE Pty Ltd does not send information overseas.

10.2 If personal information must be sent by ACWE Pty Ltd overseas for sound business reasons, ACWE Pty Ltd will require the overseas organisation to receive the information to provide a binding undertaking that it will handle that information in accordance with the National Privacy Principles, preferably as part of the services contract.

GLOSSARY OF TERMS

• Collection information means the information outlined in 1.3 notified to individuals prior to, or as soon as practical after, the collection of their personal information.
• Direct marketing means the marketing of goods or services through means of communication including written, verbal or electronic means. The goods or services which are marketed may be those of ACWE Pty Ltd or a Related Body Corporate or those of an independent third-party organisation.
• Disclosure generally means the release of information outside ACWE Pty Ltd, including under a contract to carry out an “outsourced function”.
• Personal Information means information or an opinion (including information or an opinion forming part of a database), whether true or not and whether recorded in a material form or not, about an individual whose identity is apparent, or can reasonably be ascertained from the information or opinion.
• Primary purpose is the dominant or fundamental reason for information being collected in a particular transaction.
• Reasonable expectation means a reasonable individual’s expectation that their personal information might be used or disclosed for the particular purpose.

• Sensitive information means information or an opinion about an individual’s:
• Racial or ethnic origin; or
• Membership of a political association; or
• Religious beliefs or affiliations; or
• Philosophical beliefs; or
• Membership of a professional or trade association; or
• Membership of a trade union; or
• Sexual preferences or practices; or
• Criminal record; that is also personal information; or
• Health information about an individual; or
• Use means the handling of personal information within ACWE Pty Ltd

PRIVACY POLICY WITH PARTNERS

We work closely with partners such as Microsoft and often provide links to their website. Please be aware of the Microsoft Privacy Statement.

Where ACWE Pty Ltd shares data with Microsoft, “Personal Data” means any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an Unique Student Identifier such as a name, identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. Personal Data includes, without limitation, a person’s address, phone number, fax number, email address, government-issued ID numbers, financial information, account numbers, and information associated or combined with Personal Data (such as a personal profile, unique identifier, biometric information, or IP address).

If a Supplier makes any Personal Data available to Microsoft, the Supplier will ensure, to the best of its knowledge and ability, it has complied with all legal requirements and industry standards applicable to the collection, use, sharing, and disclosure of such Personal Data.

These requirements include providing the appropriate notices and obtaining necessary consent to share Personal Data with Microsoft, and for Microsoft to receive and use Personal Data for the purposes of contacting individuals about products, services, events or offers. Supplier represents and warrants that the provision of Personal Data to Microsoft will not violate any agreement or obligation between Supplier and a third party and that it will comply with all applicable privacy laws, rules and regulations.

UPDATING THESE POLICY STATEMENTS

ACWE Pty Ltd may update this privacy policy by posting a new version on this website. You should check this page occasionally to ensure you are familiar with any changes.

Other websites
This website contains links to other websites. ACWE Pty Ltd is not responsible for the privacy policies or practices of any third party.

Contact ACWE Pty Ltd  
If you have any questions regarding this privacy policy or ACWE Pty Ltd treatment of your personal information, please:

• Email: admin@acwe.edu.au
• Post to P.O. Box 1554 Maroubra NSW 2034
• Phone: +61412921134

Denise Archie
CEO