Melbourne Business School Limited (MBS) engages education technology provider Keypath Education Australia Pty Ltd to support their delivery of select MBS Online courses (the Services).
It does so under an agreement requiring Keypath Education Australia Pty Ltd to comply with MBS’ privacy policy and relevant privacy laws and that agreement takes precedence over this Privacy Policy to the extent of any inconsistency.
Where Keypath Education Australia Pty Ltd collects, accesses, uses or discloses personal information in the course of providing the Services, the terms of the below Privacy Policy will apply.
Table of Contents
Melbourne Business School Privacy Policy
Our Privacy Policy is effective as of 21 March 2019 and our Alumni, Friends and Supporters’ Privacy Statement is effective as of 11 July 2023.
This policy (‘Privacy Policy’) explains how Melbourne Business School Limited (ABN 80 007 268 233) (‘MBS’) seeks to protect the Personal Information of individuals. MBS is committed to protecting the safety and security of the personal information of individuals whose information MBS has access to including students/participants, faculty and other persons with whom MBS interacts (each a ‘User’ or ‘you’).
The Privacy Policy has been developed in accordance with the Privacy Act 1988 (Cth) (‘Act’) and the European Union General Data Protection Regulation (Regulation 2016/679) (‘GDPR’). It also has regard to the Health Records Act 2001 (Vic) (‘Health Records Act’), which also regulates MBS in certain circumstances.
Under the Act, “Personal Information” is defined as: “Information or an opinion about an identified individual, or an individual who is reasonably identifiable:
(a) whether the information or opinion is true or not; and
(b) whether the information or opinion is recorded in a material form or not.”
With respect only to residents of the European Union, Schedule 1 of this Privacy Policy provides additional terms for the protection of “Personal Data” under the GDPR. Personal Data should be considered fundamentally interchangeable with the Australian expression “Personal Information” for the purposes of this Privacy Policy.
Please read this Privacy Policy carefully in order to understand how your Personal Information is collected, held, used, or otherwise processed by us.
A detailed privacy statement is set out below this Privacy Policy for alumni, friends and supporters of MBS’ with additional information about how MBS uses and manages personal information of alumni, friends and supporters.
MBS reserves the right to make changes or updates to this Privacy Policy from time to time. If this happens we will update this Privacy Policy and notify you of any changes, most likely via email. However, you should also periodically check this Privacy Policy for any updates.
1. ABOUT MBS
MBS is the graduate school in business and economics for the University of Melbourne (‘University’), and is jointly owned by the business community and the University. MBS is a tertiary education provider that specialises in Master of Business Administration (‘MBA’) programs and executive education.
MBS provides its’ services both physically on campus and through the distribution of educational content and services through online properties, assets and connected devices (together, ‘MBS Services’).
In providing the MBS Services, we are sensitive to Users’ concerns about the safety of their Personal Information.
In essence, MBS will typically only:
- collect, use or share your Personal Information with your consent (unless it is not reasonable in the circumstances to obtain your consent and it is legally permissible for us to do so) or when required by a legal obligation; and
- interact with your Personal Information in order to: (a) provide you with the MBS Services and (b) help us improve and develop the MBS Services.
MBS has developed our privacy framework to assist Users, and to comply with privacy legislation and regulations applicable to us and our management of your Personal Information.
2. HOW MBS COLLECTS YOUR PERSONAL INFORMATION
MBS collects Personal Information from individuals in one of three main ways:
a) Directly from Users, when they interact with MBS (e.g. enquire about the MBS Services or attend an event on campus);
b) Passively from Users, when they interact with our website, online platforms and digital presence;
c) From third-parties in certain, specific circumstances (e.g. in assessing whether we think the MBS Services will be suitable for a particular individual).
The specifics of Personal Information collected in each situation is discussed further below.
3. WHEN MBS COLLECTS INFORMATION FROM USERS AND WHAT WE COLLECT
(a) Personal Information collected directly
When a User makes an enquiry or sends us an expression of interest on our website or other digital property we may collect the following types of Personal Information directly and consensually:
- Basic contact information, including your name, email, and phone number; and
- Enquiry information, such as an indication of when you would be interested in studying at MBS or contributing to the development of MBS Services, or other information provided by you regarding your enquiry.
When you apply for enrolment or registration in an MBA or executive education program we may collect the following types of Personal Information directly and consensually from you:
- Student information, such as your name, address, email, phone number and emergency contact information, and if applicable, curriculum vitae, passport or citizenship details;
- Enrolment information, such as applicable academic transcripts, referee reports, as well as details of your organisation (e.g. your employer), your professional capacity and your work history;
- Payment information that is required as part of the enrolment process (e.g. credit card information); and
- Health information, such as your dietary requirements or information relating to any health conditions we need to be aware of when providing you with the MBS Services.
When students/participants submit administrative applications (e.g. applications for special considerations, or enrolment overload requests), we may directly and consensually collect the Personal Information outlined in the relevant application.
When you register or purchase a ticket for information sessions or other events (e.g. networking events for students/participants or alumni) we may collect the following types of Personal Information directly and consensually from you:
- Basic contact information, including your name, email, and phone number; and
- Any event-appropriate health information, such as your dietary requirements.
When you make a donation to MBS we may collect the following types of Personal Information directly and consensually from you:
- Contact information, such as your name, address, email and phone details;
- Donation information, such as how you would like the donation to be used; and
- Payment information you have provided in order to make the donation.
When you respond to a survey we may directly and consensually collect the Personal Information disclaimed and explained on the survey form.
When you provide MBS with unsolicited feedback or otherwise interact with MBS on your own accord we may collect any contact information you provide (including Personal Information), as well as your feedback.
When you make an application for employment at MBS, we may collect any Personal Information provided within that application, such as the contents of a personal statement made in support of your application.
If you are successfully enrolled and commence studies at MBS we may collect Personal Information regarding your subject choices and academic performance.
(b) Personal Information collected passively
As you use the online and digital components of the MBS Services (e.g. accessing our website, logging into your account on the Learning Management System (‘LMS’), or interacting with our advertisements) we may collect the following types of Personal Information about your usage:
- Content that you post and submit, including posts on our social media accounts or on forum threads in the LMS, as well as similar content that is posted about you by others;
- The following types of browser, system and device information regarding MBS’ and other devices you use to access our digital content:
- Locational information, such as in the form of the IP address from which you access the MBS Services, particularly when accessing the internal;
- Web data tracking information, such as data from cookies stored on your device, including cookie IDs and settings, as well as logs of your usage of MBS’;
- System usage information, including logs of your access to educational resources such as LMS, “Web Print” or “UniWireless”.
(c) Personal Information collected from third-parties
In certain specific situations, MBS will collect Personal Information about you from third-parties. The types of Personal Information collected include:
- Academic information, such as graduate management admission test (‘GMAT’) and English proficiency test results;
- Web data tracking information that fit certain parameters of who we think could become MBS students/participants or clients (e.g. heat maps developed through Google Analytics which track patterns of user interactions with our web pages); and
- In some isolated circumstances, publicly available wealth screening information such as indications of your philanthropic interest and ability.
4. WHY MBS COLLECTS YOUR PERSONAL INFORMATION AND WHAT WE USE IT FOR
Although MBS collects Personal Information from Users in a number of circumstances, MBS will only collect this information in order to provide and develop the MBS Services. Here are the main ways we use Personal Information to achieve these objectives:
Communicating with Users
MBS will use basic contact, enquiry and student/participant information in order to communicate with individuals about their enquiries, interest in events and for other administrative purposes related to the specific reason for which the Personal Information was collected.
If Users have consented, MBS will also use these types of Personal Information to share relevant news and updates about MBS and the MBS Services.
Finalising enrolment and registration purposes
MBS will use enrolment information and payment information to gauge the suitability of Users for MBS Services and to finalise the relevant processes. MBS may also use this information to coordinate and host events such as information sessions and alumni networking evenings.
Administration and delivery of MBS Services
MBS will use basic contact and student/participant information to engage with students/participants for administrative purposes (e.g. resetting account password or approving special consideration applications) and to effectively and efficiently provide them with the MBS Services (e.g. to set and receive assignments required under program syllabuses).
Health information is used to ensure MBS can adequately and appropriately respond to any specific needs Users might have (e.g. dietary requirements at events or special considerations for assignments).
Sometimes these types of information will also be used to facilitate student experiences such as educational trips, student exchanges or study abroad programs.
Ensuring User safety
MBS will use health and emergency information in order to ensure Users’ medical needs are appropriately met, when applicable.
MBS will also use any type of information collected to prevent and address risks to all Users (e.g. MBS will use information to investigate suspicious or threatening activity occurring on campus).
Research and development
MBS will use survey information to develop, test and improve the MBS Services. MBS’ preference will be to de-identify this information first, and then use it for this purpose in conjunction with de-identified enrolment information, and de-identified browser and device information (see section 6 below for an explanation of what we mean by “de-identified”).
MBS may also use basic contact, enquiry and past donation information to see if you would be interested in donating to the ongoing development of MBS and the MBS Services. In some cases, MBS may also use publicly available wealth screening information to assess the appropriateness of asking you whether you would like to donate or otherwise contribute to the development of MBS and the MBS Services.
If an individual wishes to make a donation, payment and donation information will be used to ensure donated funding is applied as intended. The specifics of such a donation to MBS may be used to assess the appropriateness of contacting you for future development initiatives.
Marketing
Where Users have expressly consented, MBS will use basic contact, enquiry and student/participant information to provide Users with relevant marketing materials and offers. Users can always opt out of this through the functionality provided in each marketing communication (e.g. by clicking “unsubscribe” at the bottom of an email).
MBS will also use passively collected web data tracking information to display marketing materials and offers on third-party websites (e.g. if you have visited an MBS program page, we may use cookies to later display banner advertisements to Users on LinkedIn). Users can stop or manage web data tracking information through their browser preferences.
5. MBS’ DISCLOSURE OF PERSONAL INFORMATION
Generally, MBS does not disclose Personal Information to any third-parties except:
- Service providers MBS engages to help us provide and develop the MBS Services (e.g. cloud service providers or consultants);
- In some specific circumstances, Users’ employers (e.g. the companies they work for); and
- Law enforcement agencies, or another party that has a legitimate legal right to access the information.
The above disclosures will only be made in circumstances where the recipient has provided an undertaking that they will maintain the confidentiality of the information and that they recognise the appropriate limitations placed on the use of the information. Disclosures will also always be in accordance with this Privacy Policy. In the case of Users’ organisations, MBS will seek the explicit consent of the User before disclosing their information.
Overseas Disclosure
Some of the third-parties MBS discloses Personal Information to are located overseas. This is particularly the case for our cloud service providers which are currently located in the United States and Ireland.
Sometimes we may also disclose students/participants’ Personal Information to other universities or educational organisations. Typically, the recipients of this information have been in the People’s Republic of China, the United States, New Zealand and Canada.
As with disclosures to third-party service providers, overseas disclosures are always made once MBS has taken all reasonable steps to determine the information will be treated as at least as favourably under the Act and other applicable privacy laws.
6. MBS’ TREATMENT AND STORAGE OF INFORMATION
MBS’ general approach
MBS will keep your Personal Information confidential and not sell or knowingly divulge User information to any external third-parties, unless:
- We believe, in good faith, that we are required to share the Personal Information with a third party in order to comply with legitimate legal obligations;
- The disclosure is to a third-party processor of Personal Information that acts on our behalf and/or under our instruction in order to enable us to deliver the MBS Services (e.g. a cloud service provider);
- Members of MBS (typically via the Board);
- Other entities which may acquire ownership or operation of MBS or the MBS Services; and/or
- To protect the safety of Users, and the security our MBS Services.
MBS seeks the informed and voluntary consent of individuals whenever it collects their information, or as soon as possible after.
Users can always refuse or revoke this consent, but sometimes this will affect MBS’ ability to provide them with the MBS Services. MBS will advise Users if this is the case.
De-identification
De-identified information refers to information that cannot reasonably be used to identify a particular individual.
De-identified information that will never be able to personally identify particular individuals is referred to as anonymised information (e.g. statistics that show 90% of Users were happy with the MBS Services). Additionally, de-identified information that can identify individuals only if it is combined with another, separate piece of information is referred to as pseudonymised information (e.g. student/participant ID numbers).
Where possible MBS will aim to collect, store and use anonymised information as a first preference, and if not, then pseudonymised information.
However, sometimes it will be impractical for User information to be de-identified or treated in this way, and in this case, MBS will continue to use and hold the information in a personally identifiable state. For example, if MBS needs to reply to a User enquiry we will have to use the contact information provided.
Security
MBS is committed to information security. We will use all reasonable endeavours to keep the Personal Information we collect, hold and use in a secure environment. To this end we have implemented technical, organisational and physical security measures that are designed to protect Personal Information, and to respond appropriately if it is ever breached (e.g. MBS has developed an extensive Data Breach Response Plan which we use to prepare and respond to data breaches).
When information collected or used by MBS is stored on third-party service providers (e.g. Azure or AWS cloud servers), MBS takes reasonable steps to ensure these third-parties use industry standard security measures that meet the level of information security MBS owes Users.
As part of our privacy framework we endeavour to routinely review these security procedures and consider the appropriateness of new technologies and methods.
Data Breaches
In the circumstances where MBS suffers a data breach that contains Personal Information, we will execute our Data Breach Response Plan and endeavour to take all necessary steps to comply with the Notifiable Data Breach Scheme outlined under the Act.
This means we will immediately make an objective assessment of whether a breach of Personal Information is likely to result in serious harm to individuals, and if this is the case, endeavour to notify the affected individual(s) and the Australian Information Commissioner.
7. MBS’ RETENTION OF INFORMATION
MBS retains Personal Information until it is no longer needed to provide or develop the MBS Services, or until the individual who the Personal Information concerns asks us to delete it, whichever comes first. It may take up to 30 days to delete Personal Information from our systems following a valid request for deletion.
However, MBS will retain:
- Personal Information in circumstances where we have legal and regulatory obligations to do so (e.g. for law enforcement purposes, employment law, corporate or tax record keeping, and where the information is relevant to legitimate legal proceedings, or in keeping with its’ requirements under other Australian record keeping legislation such as the Public Records Act 1973 (Vic)); and
- anonymised information for analytic and service development purposes.
The information we retain will be handled in accordance with this Privacy Policy.
8. SPECIFIC RIGHTS OF EUROPEAN RESIDENTS
Users who are habitually located in the European Union (‘EU Residents’) have additional rights in respect of their Personal Data (a term that is fundamentally interchangeable with Personal Information).
Users who are EU Residents should refer to Schedule 1 for more information regarding how MBS’ privacy practices in relation to their Personal Data.
9. MANAGING PERSONAL INFORMATION YOUR INFORMATION
Accessing and ensuring the accuracy of Personal Information
MBS takes reasonable steps to ensure that the Personal Information we collect and hold is accurate, up to date and complete.
Users have a right to access and request the correction of any of Personal Information we hold about them at any time. Any such requests should be made by directly contacting us at the details set out below. MBS will grant access to the extent required or authorised by the Act and applicable laws, and will take all reasonable steps to correct the relevant Personal Information where appropriate.
There may be circumstances in which MBS cannot provide Users with access to information. We will advise you of these reasons if this is the case.
Contacting MBS
MBS has appointed a Privacy Officer to be the first point of contact for all privacy related matters and to assist in ensuring our compliance with our privacy obligations.
Privacy Officer
Privacy Officer privacy@mbs.edu
200 Leicester Street
Carlton VIC 3053
ABN: 80 007 268 233
If you have any queries or wish to make a complaint about a breach of this policy, the Act or the Health Records Act, you can contact or lodge a complaint to our Privacy Officer using the contact details above. You will need to provide sufficient details regarding your complaint as well as any supporting evidence and/or information.
The Privacy Offer will respond to your query or complaint as quickly as possible. MBS will contact you if we require any additional information from you and will notify you in writing (which includes electronic communication via email) of the relevant determination. If you are not satisfied with the determination you can contact us to discuss your concerns or complain to the Australian Privacy Commissioner via www.oaic.gov.au.
This Privacy Policy was last updated on 15 October 2018.
SCHEDULE 1
SPECIFIC RIGHTS OF EUROPEAN RESIDENTS
MBS is committed to ensuring its compliance with the European Union General Data Protection Regulation (‘GDPR’).
Although our Privacy Policy explains how MBS meets all of its’ obligations for Australian Users, MBS also has some Users who are habitually located in the European Union (‘EU Residents’) that have additional rights in respect of their Personal Data.
Personal Data is defined as: “Any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier”. This should be considered fundamentally interchangeable with the Australian expression “Personal Information” for the purposes of this Privacy Policy.
Under the GDPR, MBS is primarily a “controller” of Personal Data, as opposed to being a “processor”. As part of its’ GDPR compliance, MBS provides the MBS Services in a way that ensures:
Personal Data (i.e. Personal Information) is:
- processed fairly, lawfully and in a transparent manner; and
- collected and processed only for specified and lawful purposes.
(NB see sections 2 - 5 of this Privacy Policy).
Processed Personal Data (i.e. Personal Information that is used, held or disclosed by MBS) is:
- adequate, relevant and not excessive;
- accurate and, where necessary, kept up to date;
- kept secure, and not longer than necessary;
- not transferred to countries outside the European Union without adequate protection; and
- treated in accordance with individuals’ legal rights.
Whilst MBS strives to provide all Users with appropriate access and control over their data, individuals covered by the GDPR are also able to:
- Prescriptively restrict, limit or otherwise provide instructions to MBS regarding how we can use their Personal Data. This includes being able to object to how and why their Personal Data is used (e.g. by the removal of their consent for particular functions);
- Verbally request the erasure (i.e. deletion) of their information; and
- Request MBS provides all Personal Data held about them in a portable format, meaning in a way that is structured, commonly used and machine-readable. Users who exercise this right to data portability are also able to direct MBS to transmit this data to other entities who they intend to allow to process their Personal Data.
MBS will allow and assist Users that are EU Residents to exercise these rights, unless we have compelling and legitimate legal grounds not to (e.g. a legal obligation under Australian legislation, or if the Personal Data has been fully anonymised).
Alumni, friends and supporters’ privacy statement – Current as at 11 July 2023
The School’s global network of alumni, friends and supporters includes graduates and former students, donors and potential donors, volunteers, industry partners, and others who have expressed an interest in supporting the School or participating in School-run events and activities (called alumni, friends and supporters for the purpose of this privacy statement).
This privacy statement outlines how we manage and use the information we hold about our alumni, friends and supporters. It should be read in conjunction with the School’s Privacy Policy which further outlines how the School handles your personal information.
Our alumni, friends and supporters are very important to us. We want to stay in touch with you and keep your personal information in accordance with your wishes and our obligations. It is important that the information we hold about you is accurate and current. Please contact us to update your details at any time by:
- Sending an email to alumni@mbs.edu
- Calling the Alumni Relations office on +61 3 9349 8302
- Writing to us at 200 Leicester Street, Carlton, VIC, 3053, Australia
- Updating your details on our website at https://mbs.edu/alumni/update-your-details.
If you studied at the School, information that you provided on enrolment or which the School collected during or after your studies, is used by the School’s Alumni Office in accordance with this privacy statement.
If you do not wish to be contacted as an alum, friend or supporter of the School, or you do not wish your personal information to be used as set out in this privacy statement, you may opt out at any time by:
- Sending an email to alumni@mbs.edu
- Calling us on +61 3 9349 8302
- Writing to us at 200 Leicester Street, Carlton, VIC, 3053, Australia
- Clicking “Unsubscribe” or “Manage my subscription preference” on an email we have sent.
The personal information processed by us, or on our behalf, is necessary to foster relationships with our alumni, friends and supporters, maintain and facilitate alumni networks and benefits, and to help us engage with you and improve your experience with the School. Your personal information may also be used for the purposes of benchmarking, rankings, analysis, quality assurance, strategy and planning, and to ensure that we can provide you with the services and information requested by you. We may also process your personal information for the following purposes:
- To inform you of opportunities to engage with and support the School;
- To generate philanthropic support (for example, fundraising and/or volunteering) for School charitable projects. More specifically, these activities may include:
- sending you publications, email newsletters about the School and its fundraising projects and updates on School hosted, sponsored or affiliated events, in a way which is tailored and relevant to you;
- helping you keep in touch with other alumni and/or School supporters and donors by inviting you to alumni and School events;
- informing you of and providing benefits available to alumni (where you are interacting with us as an alum);
- through a variety of channels, such as phone, email or social media, asking you if you would like to support the School by, for example, making a donation, contributing to surveys, volunteering, or acting as a mentor;
- internal record-keeping and administration (for example, to process a donation or administer an event which you are attending).
- To validate your address and to prepare reports using maps by ‘geocoding’ your address against publicly available web mapping services. This can ensure that we tailor information that is relevant to you based on your location;
- To inform you about School news, courses or events;
- To seek feedback of your experience as an alum or supporter of the School;
- To publish photographs and videos relating to our activities and events. We will inform you about such processing at the time that the information is obtained or as soon as reasonably possible thereafter;
- To compile anonymised statistics for benchmarking in which the School participates;
- To attend to routine administrative matters, and to provide associated services such as security, parking and information technology;
- To conduct surveys in connection with our services and our rankings; and
- To use the information as required or otherwise permitted by law.
ANALYTICS
Analytics may be conducted on personal information for the purposes of determining which products or services you may be interested in, marketing, fundraising and product development.
Analytics may be conducted using information from a range of sources, such as information collected from third parties or data sources including LinkedIn. We may occasionally engage external consultants to improve our understanding of our alumni and supporters using data matching against external databases (for example Qantas, in connection with their Frequent Flyer Program) or other data enrichment processes or to carry out wealth screening.
Keypath Education Australia Pty Ltd – MBS Privacy Policy (“Privacy Policy”)
Last updated 28 January 2023
Keypath Education Australia Pty Ltd (who we refer to, together with our related bodies corporate1, as “Keypath,” “Keypath Group,” “us,” “we,” or “our,” depending on the context) respects your privacy, and takes the privacy and security of personal information seriously.
This Privacy Policy explains:
- What information we collect, how we collect that information, and how we use that information;
- When and with whom we may share information we collect; and
- Your choices and rights regarding your personal information.
This Privacy Policy applies to information we collect through the sites that link to this Privacy Policy (referred to collectively as the “Site”), as well as through any other contact you have with Keypath through or on behalf of Melbourne Business School Ltd (MBS) in connection with the educational courses they offer (referred to generally as a “Course” or the “Courses”), as well as with MBS directly.
Keypath is a service provider of MBS and at no time seeks to represent that MBS and Keypath are in partnership, operating under a joint venture, franchise, agency, employment relationship or partnership arrangement.
If you do not agree with the terms of this Privacy Policy and would prefer that we not collect, use, or share your information as we describe, you should not use the Site or otherwise provide us with any information.
Please note that if we are unable to collect Personal Information from or about you, it may make it difficult or impossible for you to access services through the Site, or for us to be able to respond to your requests or enquiries, or engage in other dealings with you. For example, you may not be able to enrol in or complete a Course. However, it is ultimately your choice whether you want to interact with us and MBS, enrol in Courses, and/or participate in online learning through MBS.
Collection And Use of Personal Information
A. What We Mean By "Personal Information."
“Personal Information” is information or an opinion, in any form and whether true or not, about an identified individual or an individual who is reasonably identifiable. Different states, countries, and laws define Personal Information (or similar terms, such as “personally identifiable information” and “personal data”) differently, but Personal Information generally includes information such as your name, mailing address, e-mail address, and phone number. It may also include the internet protocol (IP) address of your computer or mobile device, if that IP address can be linked to you from specific information we handle, or other information (such as other Personal Information accessible to us, or geo-location information) that could be used to ultimately identify you.
B. The Kinds of Personal Information That We Collect and Hold, and How We Collect It.
The kinds of Personal Information we collect and hold about you depends on the nature of your dealings with us and the circumstances of collection. For example:
- we may collect your name, telephone number, email address and other information you choose to provide to us, if you decide to contact us through a “Contact Us,” “Request More Information,” or similar links on the Site, or if you otherwise request information about MBS or about the Courses, units and other services we and they offer;
- if you apply for enrolment in a Course, or if you sign up to receive newsletters or other materials, you may provide us with your name, email address, and any other information you include with your submission; and
- if you participate in a Course, we will obtain Personal Information from you so that we and MBS provide you with the services that you have signed up to receive.
If you deal with us in some other capacity, we may collect your name and contact details and any other information you choose to provide to us.
In addition to the Personal Information that we and MBS collect directly from you through your interaction with the Site and your participation in Courses and other services we and MBS offer, we and MBS also collect some Personal Information from third parties (our purpose for doing so is set out under "Personal Information We Obtain From Third Parties" below).
We may collect sensitive information (such as health information) and we will only collect sensitive information about you with your consent (unless we are otherwise required or authorised by or under law to do so).
If you are or have been our employee, the handling of your personal information may be exempt from the Australian Privacy Principles if it is directly related to your employment relationship with us.
In addition, our Site, like most websites, automatically collects certain information from Site visitors, such as the IP address or other unique identifier of the visitor's computer or other device, and information about the browsing history and website interactions associated with that device. This device and online activity information may be considered Personal Information where it could be used to ultimately identify an individual (for example, where information held is able to be linked with other accessible information that could ultimately identify the individual). However, we do not use this type of automatically-collected information to identify or to further interact with a particular person, unless and until that user voluntarily provides other Personal Information in the manner outlined above. More information about how we use this information on an anonymous, de-identified and/or aggregate basis is described below under “How We Collect and Use Non-Personal Information.”
C. The Purposes For Which We Collect, Hold, Use and Disclose Personal Information.
| Category of Personal Information | Our Purpose For Collecting And Holding Your Personal Information | Our Purpose for using And Disclosing Your Personal Information |
|---|---|---|
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Contact Information Examples:
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We collect this information as necessary for us or MBS to enter into and/or perform a contract with you. For example, we may need this information to verify your identity. |
To help us identify you. To provide you with information and services you have requested. This may include information that has been requested by a third party using “refer a friend” or similar referral forms. To provide relevant information to you while browsing our website or upon your request, to assist you with enrolment in a Course, and to facilitate flexible online learning. Subject to your right to opt out, to market to you by email or other electronic means. |
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Communication, Activity and Marketing Information Examples:
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We collect this information as necessary for us or MBS to enter into and/or perform a contract with you. For example, we may need to provide you with information about Courses you have enroled in. Where required by law, we will obtain your consent to collect this information (such as to use your image in photos and videos). |
To allow you to participate in interactive areas of the Site, such as participating in discussion forums or providing comments to others’ posts. To ensure the quality of our services and interactions with you. To provide you with information and services you have requested. To assist you with the enrolment in Courses and to facilitate flexible online learning. Subject to your right to opt out, to market to you by email or other electronic means. To provide the public with information about MBS, Courses, and other products and services of MBS for purposes of marketing. |
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Personal/Demographic Information Examples:
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We collect this information as necessary for MBS to enter into and/or perform a contract with you. For example, we may need this information to verify your identity and application information. In relation to sensitive information (such as your religious beliefs, or your racial or ethnic origin), we will only collect this information about you with your consent unless we are otherwise required or authorised by or under law to do so. |
To ensure the quality of our services and interactions with you. To respond to and/or address your requests and inquiries, and/or to provide requested information to you. To assist you with the enrolment in Courses and to facilitate flexible online learning. |
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Educational History Information Examples:
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We collect this information as necessary for us to enter into and/or perform a contract with you. For example, we may need this information to verify your identity and application information, and to process your application and enrolment. |
To provide you with information about the MBS, Course(s), you may be interested in or that may be of interest based on your indicated preferences. To respond to your inquiries regarding MBS, Course(s) To assist you with the enrolment in Courses and to facilitate flexible online learning. |
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Employment History Information Examples:
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We collect this information as necessary for us or MBS to enter into and/or perform a contract with you. For example, we may need this information to verify your identity and application information, and to process your application and enrolment. |
To provide you with information about the MBS, Course(s), you may be interested in or that may be of interest based on your indicated preferences. To respond to your inquiries regarding MBS, Course(s). To assist you with the enrolment in Courses to facilitate flexible online learning. |
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Financial Aid-Related Information Examples:
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We collect this information as necessary for us or MBS to enter into and/or perform a contract with you. For example, we may need this information to verify your identity and application information, and to process your application and enrolment. |
To provide you with information about MBS Course(s) you may be interested in or that may be of interest based on your indicated preferences. To respond to your inquiries regarding MBS, Course(s). To assist you with the enrolment in Courses and to facilitate flexible online learning. |
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MBS Course Information Examples:
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We collect this information as necessary for us or MBS to enter into and/or perform a contract with you. For example, we may need this information to verify your identity and application information, and to process your application and enrolment. |
On behalf of MBS, to provide you with information and services you have requested from the MBS. To assist you with the enrolment in Courses and to facilitate flexible online learning. To respond to and/or address your requests and inquiries, and/or to provide requested information to you, including information that has been requested by a third party using “refer a friend” or similar referral forms. |
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Application Information Examples:
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We collect this information as necessary for us or MBS to enter into and/or perform a contract with you. For example, we may need this information to verify your identity and application information, and to process your application and enrolment. In relation to sensitive information (such as certain demographic information and criminal records), we will only collect this information about you with your consent unless we are otherwise required or authorised by or under law to do so. |
To assist you with the application process and enrolment in Courses and to facilitate flexible online learning. |
1. Personal Information We and MBS Collect Directly
The Personal Information you may be asked to provide to us and/or MBS, and the purpose for which we and/or MBS collect, hold, use and disclose that Personal Information, is described above.
In addition to the purposes specified in the table above, we also collect Personal Information so that we can operate our business and provide services to you and others, as described further below under "Personal Information We Obtain From Third Parties" and "Certain Generally-Applicable Uses of Personal Information."
We present this information based on the categories of Personal Information collected, but please note that similar specific pieces of information may apply to multiple categories. For example, your name and email address may be included within each of the “Contact Information,” “Communication, Activity and Marketing Information,” and “Educational History Information” categories described below.
2. Personal Information We Obtain From Third Parties
As noted above, we collect some Personal Information from third parties. With MBS’ prior approval, we may engage with third party data enrichment providers, for the purpose of enhancing the Personal Information we collect and share with them (as discussed in further detail below) to provide us with additional information relating to demographics, lifestyle/interests, and household income. We use this information to better understand students and potential students, so that we can tailor our marketing messaging to specific persons, so that the information we provide is meaningful and helpful to both MBS and to the recipient.
3. Certain Generally-Applicable Uses of Personal Information
The Personal Information we collect directly from you and from third parties may be used for the following additional purposes, all of which are related to the operation of our business and our provision of services:
- Our and MBS’s internal record-keeping;
- To enable us or MBS to contact you by e-mail, text or phone for any of the above reasons;
- With prior notice to MBS, where necessary as part of any restructuring of the Keypath Group;
- For compliance with legal, regulatory, and other good governance obligations;
- To convert Personal Information into pseudonymous and/or de-identified data, and use it (normally on an aggregated statistical basis) for research and analysis;
- To gain insight that enables us and MBS to measure the effectiveness of our services;
- To learn about potential and current students so that we can improve the Courses and provide you and others with better and targeted service offerings from MBS; and
- To evaluate potential and current students’ needs and resources applicable to the Courses, and to tailor our marketing messages to your and their specific interests, needs, and abilities.
When we use your Personal Information for our business purposes, those business purposes include working with MBS to make Courses available, responding to your, our students’ and potential students’ comments and complaints, marketing our and MBS’s products and services, improving and developing new products and services, and ensuring the productivity, functionality, and security of the Site.
D. How Long We Keep Personal Information.
We will keep your Personal Information as long as we have a business need to do so and/or as necessary to meet the purpose for which the information was collected and used, unless a longer period is required by law or by contract with MBS. For example, we will keep Personal Information for at least as long as you continue to be enroled in any Course. And, if any Site allows you to create an account, we will keep the Personal Information associated with your account for as long as you maintain it. Business needs for which Personal Information may be retained include legal, tax, accounting, risk management, and other business purposes.
All applicant, enrolment, and student details will be kept for at least as long as we continue to provide services to the MBS, unless we agree otherwise with MBS. Once we cease to have a relationship with MBS, our practice is to de-identify (or otherwise destroy) all Personal Information we have collected in the course of that relationship.
It is important to note that some information may be made public. For example, with your consent we may use your image and testimonials in promotional materials. Accordingly, your information will be able to be seen and republished for as long as the marketing materials continue to be posted online, or as long as the hard copies remain in existence. In addition, we or MBS may make available services that enable you to post information on the Site in public forums and on message boards. In these cases, once posted the information will be able to be seen and republished by others for as long as the web page remains active. Even if web pages are deleted, they may continue to be accessed if they are archived or cached. Therefore, you should think carefully before giving your consent to the use of your name, image, and comments in any materials and, if applicable, before posting anything in any public area of the Site.
How We Collect and Use Non-Personal Information.
A. What Is Non-Personal Information?
Non-personal information refers to information that is not and cannot be used to identify a specific individual, or is Personal Information that has been de-identified so that it is no longer about an identifiable individual, or an individual who is reasonably identifiable. This may include information about the statistical characteristics of the visitors to the Site or persons who enroll in Courses. While this information may define how you fit into a particular group of people, it is not unique to you, and it cannot be used to specifically identify you. This section describes how we collect and use non-personal information.
B. The Non-Personal Information We Collect and Why.
When you visit the Site or interact with us electronically (such as through email), we may automatically collect standard internet and website log information, and details of patterns about how you behave. This information includes your internet service provider name, your operating system, your browser type and browser language, the IP address of your computer or other device (unless such IP address can be used to identify you), your access times, the website that referred you to the Site, the specific web pages you visit and the date and time of those visits, and links clicked as you visit the Site.
We use this information to evaluate the Site, to find out which parts of the Site are popular or that may need improvement, and to enhance your and others’ Site experiences.
C. Cookies and Other Tracking Technologies.
The Site utilizes “cookies”, anonymous identifiers and other tracking technologies such as web beacons, which enable us to distinguish you from other users and provide you with information that is customized for you. For more information, see the “Cookies Policy” section of this Privacy Policy.
D. Analytics Services.
The Site may use analytics tools and services to collect information about use of the Site, such as how often users visit the Site, what pages they visit when they do so, and what other sites they used prior to visiting the Site. We use the information we collect from the analytics services to maintain and improve the Site and our and MBS’s services. The analytics services we use include Google Analytics, Facebook Ads, and others.
E. Sharing Non-Personal Information.
We may use or disclose non-personal, aggregate, anonymous information in a de-identified format to third parties, such as third party service providers to improve the Site and our and MBS’s services, and market research firms.
Cookies Policy
A. What Are Cookies?
Cookies are small amounts of data that are stored on your browser, device, or the page you are viewing when you visit a website. Some cookies are deleted once you close your browser or application (session cookies), while other cookies are retained even after you exit so that you can be recognized when you return (persistent cookies). Cookies do not typically contain any information that personally identifies a user, but Personal Information that we store about you may be linked to the information stored in and obtained from cookies.
B. How We Use Cookies.
We use both session and persistent cookies on the Site. The cookies we use are generally divided into the following categories:
- Mandatory cookies: These are cookies that are required for the operation of the Site, such as cookies that enable you to log into secure areas.
- Functional cookies: These are cookies that remember choices that you make when you visit the Site such as language options. They help to make your visit more personal and assist your navigation of the Site.
- Analytics/Marketing cookies: These are cookies that automatically collect information about your use of the Site, such as the pages you visit, and the links you followed. These help us recognize previous visitors to the Site, and understand how many people are using the Site and how they navigate through it. As mentioned above, we use analytics services to analyze user behavior, so these third parties will place these types of cookies on the Site.
C. Your Choices About Cookies.
Most web browsers automatically accept cookies, but you can usually change your settings to prevent that, such as by having your device warn you each time a cookie is being sent or choosing to turn off all cookies. On the Site, you will be able to disable all cookies other than mandatory cookies. This can be done through your web browser settings, and because each browser is different, you should look at your browser’s “Help” menu to learn how to modify your cookie settings. There are also online resources that may help you learn more how to opt out of targeted behavioral advertising from many major third party network advertisers.
If you do disable cookies from your browser you may not be able to access certain sections of the Site that use essential cookies, and this may make your experiences on the Site less efficient.
D. Do Not Track Requests.
Currently, certain browsers, including Firefox, Google Chrome, Safari and Internet Explorer, offer a “do not track” (DNT) option. This option, using a technology known as a DNT header, sends a signal to websites visited by the user about the user’s DNT preference, if any, set on the browser. However, we do not currently commit to responding to browsers’ DNT signals. We cannot make this commitment because no common industry standard for DNT has been adopted by industry groups, technology companies, or regulators.
How We May Share Information
A. Sharing Information with MBS.
We collect, use, and process your Personal Information on behalf of MBS, and accordingly, it will be shared with MBS for all purposes consistent with this Privacy Policy, including to process applications and enrolment materials and to fulfill our contractual relationship with MBS. In addition, we may also collect and share your Personal Information with MBS so that we can collaborate with them to develop, deploy, and deliver additional Courses and online programs, and to facilitate flexible online learning.
Please note that we have no control over how MBS uses Personal Information and other information we share with them. MBS has its own privacy policy, and their collection and use of your Personal Information is subject to their policy, which will be different from this Privacy Policy.
B. Sharing Information with Others.
We may share information with other third parties in the following circumstances:
- We may share your information, including Personal Information, so that we or others may provide you with periodic mailings in connection with MBS courses, or may contact you regarding products, services, or events of MBS. If you do not wish for us to share your information in this manner, please let us know by contacting us at cst@keypathedu.com.
- We may employ other companies and people to perform tasks on our behalf and we may need to share Personal Information with them to provide services to you. For example, such parties may handle our data management and/or email distribution. After consulting with MBS, and with MBS’ prior approval, other parties may be provided with Personal Information so that they can provide the data enrichment services discussed above. Where this occurs, we ensure that such third parties have technological and organisational data protections in place, and are subject to privacy laws and obligations which meet the standard of data and privacy protection required under our agreement with MBS. Unless we tell you differently, they do not have any right to use your Personal Information beyond what is necessary to assist us.
- With MBS’ prior approval, we may share information, including Personal Information, with our corporate affiliates in the Keypath Group of companies for the potential expansion and promotion of product and service offerings for MBS, and other uses consistent with the purposes described in this Privacy Policy, in particular, our delivery of the Services.
- We may share your Personal Information with your employer, if your employer is paying for your enrolment in a Course and/or unit.
- We will share Personal Information with third parties for other purposes if we have your express “opt-in” consent to do so.
- We may disclose non-personal, aggregate, anonymous data in a de-identified format for any legitimate business purpose.
- We may disclose Personal Information at the request of law enforcement or government agencies or in response to subpoenas, court orders, or other legal process to establish, protect, or exercise our legal or other rights or to defend against a legal claim, or as otherwise required or allowed by law.
- We may disclose Personal Information if we believe that such action is appropriate to (a) protect the rights, property, or safety of a user of the Site or any other person, (b) investigate or prevent a violation by you of any contractual or other relationship with us or MBS, (c) investigate or prevent your actual or potential illegal, fraudulent, or harmful activity, or (d) detect, prevent, or otherwise address fraud, security, or technical issues.
- We may share information, including Personal Information, in connection with, during negotiations of, or as a part of the closing of any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
- We may also disclose your Personal Information to other third parties and for other purposes where we are required or authorised by or under law to do so (including where you have provided your consent). We will never sell your Personal Information.
C. Sharing Information to Recipients Outside Australia.
Other companies in the Keypath Group of companies and some of our service providers are located outside of Australia. As a result, Personal Information collected and held by us may be disclosed to recipients in other countries, including recipients located in the United States, the UK, Israel and Canada.
Keypath will not disclose your Personal Information to third parties outside Australia without the prior approval of MBS.
Social Sharing Features And Third Party Websites
The Site may offer social network and similar sharing features, such as Facebook, Twitter, Instagram, and YouTube buttons, which let you share information related to the Site, MBS, and/or the Course(s) you enrol in through your preferred social media platforms. In addition, the Site may include links to other third party websites. Those sites, and the third parties’ use of any data that may be collected by those sites, is not governed by this Privacy Policy. You should always review the privacy policies of any site you visit before submitting your Personal Information.
If you permit a connection between the Site and your social network page(s) or another third party site, we (and the other site operator) may be able to identify you, and associate the information we (and they) receive with information we (and they) already have about you. In addition, depending on how you use those features and your settings with the social network or other third party site, the information you share may be available to others, including your friends and/or the public. For more information about how your information may be shared through those social networks and other third party sites once it is provided to them, review the privacy policies of those social networks and other third party sites.
How We Hold Your Personal Information and Our Security Measures.
We use a variety of industry-standard security measures to maintain the safety of your Personal Information, including measures designed to secure your Personal Information from accidental loss and from unauthorised access, use, alteration and disclosure. We store the Personal Information you provide on secure (password- and firewall-protected) servers.
Unfortunately, no electronic data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we believe that we use reasonable measures to protect Personal Information, we cannot ensure or warrant the security of any information transmitted or otherwise provided to us or received from us.
If any portion of the Site allows you to create an account, it will be your responsibility for keeping your account and password confidential. We will never ask for your password (except, if applicable, when you create your account and log into the Site).
Your Rights Regarding Your Information
A. General Rights to Access, Correct and Remove Personal Information.
If you have any questions regarding this Privacy Policy or our use of your Personal Information, you can contact us by email at cst@keypathedu.com. In addition, you can also contact us at any time at cst@keypathedu.com to request that we make any corrections to your Personal Information. If, where applicable, you have an account on any Site, you can access and edit your account information online, by signing into your account and selecting the information you want to edit.
As noted above, we have standard retention practices with respect to the Personal Information we collect. If you would like to request any earlier removal of your Personal Information, please contact us at cst@keypathedu.com. Please note that we may not be able to completely remove Personal Information from the Site or our systems in certain circumstances. This will be true if the data is not in a searchable format, if it is retained in backup systems or cached or archived pages, if we need it to prevent fraud or future abuse, or if we are required by law to keep it.
B. Your Rights Regarding Direct Marketing.
As noted above in this Privacy Policy, we may use your Personal Information to provide you with marketing and promotional information about our and MBS’s products and services. These promotions may be made by mail, email, telephone, instant messaging application, or text (SMS) message, or other methods that may become relevant or available. All promotional materials that are sent by use using electronic means will include a simple means for you to stop receiving further communications. For example, we may provide you with an “unsubscribe” link, or an email address to which you can send an opt-out request. In addition, if we need your consent for direct marketing communications under applicable law, and if you provide your consent, you will be able to change your mind at any time.
Your consent will be deemed if you do not opt out when we offer you the opportunity to do so, and will remain current until you advise us otherwise. You can manage your consent preferences with respect to direct marketing activities by contacting us at cst@keypathedu.com. Please note that despite your email preferences, we may need to contact you regarding your enrolment at MBS, as required by law, or regarding legal matters. However, we will not send you marketing communications if you have opted out of receiving them.
A Note About Children
The Site is not targeted to, and we have no interest in collecting information from, children, and we do not knowingly gather any Personal Information from children under the age of 15. If you are a parent or a legal guardian who believes that your minor child provided us with any Personal Information, please contact us at cst@keypathedu.com.
Contact Us
Please contact us (at cst@keypathedu.com) if you have any concerns or complaints about the manner in which we have handled your Personal Information. We will inquire into your complaint and respond to you in writing within 30 days. If you are not satisfied with our response, you can contact us to discuss your concerns or lodge a complaint with the Office of the Australian Information Commissioner (www.oaic.gov.au).
Changes To This Privacy Policy
We may make changes to this Privacy Policy from time to time. Any changes to the manner in which Personal Information is used or shared with third parties will be subject to the approval of MBS. Any modifications will be effective when the changes are posted to the Site. You can review the most current version of this Privacy Policy at any time by accessing the section of the Site labeled Privacy Policy, and you can determine when this Privacy Policy was last revised by referring to the “Last Updated” legend at the top of this Privacy Policy. You are expected to check this Privacy Policy from time to time to take notice of any changes.