Privacy Policy

This privacy policy aims to give you information on how GUS Education Australia collects and processes your personal data including any data you may provide through this website when you:

• arrive on our website from a social media site such as Facebook Twitter, Instagram, Snapchat, Pinterest, VKontakte or LinkedIn;

• complete a call back / enquiry form;

• you register on our site to apply for a course or programme, corporate/ executive education, professional training, (online, distance learning or campus based) and whether you are applying for yourself or for employees or other staff at your organisation which may be or become a customer of ours;

• sign up for marketing materials; or

• you provide us with your personal data by any other means.

This website is not intended for children and we do not knowingly collect data relating to children on this website. However, where GUS Education Australia processes personal data of children in its business operations, we ensure that appropriate safeguards and consents are obtained from parents or caregivers as applicable. You may contact dataprotection@gus.global for further information about this.

It is important that you read this privacy policy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.

This privacy policy supplements the other policies and does not replace them.

Data Controller

This website is operated on behalf of Global University Systems B.V. is a company registered in The Netherlands under company number 55367453 and we have our registered office and our main trading address at Tower H, WTC Amsterdam, Zuidplein 36, 1077 XV Amsterdam, The Netherlands.

GUS Services UK Limited is registered with the Information Commissioner’s Office (ICO) with registration number ZA503946

Notification details can be accessed by searching the Data Protection Public Register.

The Global University Systems B.V. group of companies is made up of different legal entities, details of which can be found here https://www.globaluniversitysystems.com/our-institutions

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

Contact details

Our full details are:

Full name of data controller legal entity: Global University Systems

FAO Data Protection Officer

Email address: dataprotection@gus.global

Postal address: Legal Department, 30 Holborn, London, EC1N 2LX,

Telephone number: + 44 (0) 20 3435 4455

GUS Australia respects your privacy and is committed to protecting your personal information in accordance with the Australian Privacy Principles (APPs) in the Privacy Act 1988. This privacy policy tells you how we collect, handle and use information we hold. You have the right to make a complaint at any time to the Australian Privacy Principles (APPs), the Australian supervisory authority for data protection issues (www.oaic.gov.au) and the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We consider that the APPs would be the lead supervisory authority for GUS Australia since this is the place of the majority of our operations. For data protection issues in other countries, you have the right to complain at any time to the supervisory authority for that country.

We would always prefer that you come to us to help address any concerns of a privacy nature however before you go to the APPs or the ICO or other applicable supervisory authority, so please contact us in the first instance.

This version was last updated on 14 December 2021.

We may from time to time change the detail in this notice. Any changes we may make in the future will be posted on this page. Please check back frequently to see any such updates or changes.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

We may collect personal information either directly from you, or from third parties in a variety of ways including:

• if you contact us by phone, email or post

• if we engage you to provide services to us or on our behalf

• if you engage with an application developed by us

• if you complete an online form through our website

• via business partners

• referrals and recommendations

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

Personal data, or personal information, means any information about an individual from which that person can be identified. Anonymous data is therefore not treated as personal data.

We have grouped together different kinds of personal data which we may collect, use, store and transfer as follows:

• Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender, nationality, residency status, disability declaration, criminal conviction declaration, and photographic images.

• Contact Data includes residential address, country of residence, email address and telephone numbers

• Employment Data includes employment details, start date, end dates, your job title, contact details at work (email address, telephone number and postal address).

• Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.

• Profile Data includes any of your usernames and passwords, enquiries made by you, purchases or orders made by you, your interests, preferences, feedback and survey responses.

• Monitoring and Reporting Requirements Data includes data reported to third parties for regulatory purposes

• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.

• Technical Data includes your IP address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.

• Usage Data includes URL data, web analytics data in relation to how you arrived at our sites, from where, what search items you looked for, which pages you visited on our sites, the duration of your visits and such other information about how you use our websites and the information provided on them, and how you use our products and services so as to assist us to improve our website offering to you.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

Technical Data from the following parties:

1. analytics providers such as Google analytics, Google optimizer, Google Webmaster tools, Google tag manager, Facebook, Instagram and Conversant based out of Europe & Convertr Media based in UK and other similar services which we will be using in the future;

2. advertising networks such as Google Advertising Network, Facebook, Instagram, Bing and Linkedin based outside BC and similar network we will be partnering with; and

3. search information providers such as Google, Bing and other search engines based inside and outside BC, social media networks such as Facebook, Linkedin and Instagram, based inside the EU and others providing similar services.

4. Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Conversant, Google Analytics, Facebook, Instagram, Bing, Linkedin and Stripe, based outside BC and Convertr Media based inside the UK including similar services we will partner with in future.

5. Identity and Contact Data from data aggregators.

6. Academic, contact, identity, marketing and communications and technical data from (i) publishers, who are owners of private websites, and are based in and outside Europe and (ii) agents, referring organisations such as other universities.

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.

• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

• Where we need to comply with a legal or regulatory obligation.

Please see the table below to find out about the types of lawful basis that we will rely on to process your personal data.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email or SMS. You have the right to withdraw consent to marketing at any time by contacting us at adminau@gus.global or by clicking the unsubscribe link in the relevant emails.

GUS AUSTRALIA WEBSITE VISITOR

IF YOU ARE A VISITOR TO OUR WEBSITE

Types of personal information we collect

We collect, use and store different types of personal information about you, which we have grouped together as follows:

Types of personal information Description

Publicly Available Data Details about you that are publicly available, such as on Companies House or elsewhere on the internet

Marketing Data Details about your preferences in receiving marketing communications from us

Consents Data Any permissions, consents or preferences that you give us

Usage Data Information about how you use our website, products and services

How we use your information

Generally

The table below outlines how we use your personal information and our reasons. Where these reasons include legitimate Interests, we explain what these legitimate Interests are.

What we use your information for Our reasons Our legitimate Interests

• To provide you with information you may ask for • Consent

• Legitimate Interests • To fulfil enquires you might make of us

• To allow you to register for updates or for notifications of blog posts on our website • Consent

• Legitimate Interests • To provide you with information that you may request from us

• To allow you to register for events that we may be hosting • Consent

• Legitimate Interests • To hold events, such as seminars, webinars, open days or corporate hospitality to promote our business and its services

• To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) • Legitimate Interests • To provide efficient client care and services

• To ensure that our technology operates efficiently and without error

• To assess which of our services may be of Interests to you and to tell you about them

• To develop new products and services and improve existing ones

• To manage our relationship with you which will include notifying you about changes to our privacy notice and our website terms and conditions • Legitimate Interests

• Contract performance • To provide efficient client care and services

• To keep you updated about changes in the legal terms that apply to the use of our website

• For record keeping and firm management

• To manage the systems that contain our marketing database

• To manage marketing preferences and keep our records up to date • Legitimate Interests • For data management for marketing and business development purposes

• To improve our systems and services

• To seek feedback

• To seek your consent when we need it to contact you

• To use data analytics to improve our website, products/services, marketing, customer relationships and experiences • Legitimate Interests

• Consent • To improve our marketing strategy and the services that we provide

• Sharing information with third parties - to facilitate data-gathering to improve our educational services, our website, and our marketing efforts. • Legitimate Interests • For the purposes of GUS's legitimate business Interests such as managing and developing its business

Where we collect your personal information from

We may collect personal information about you from the following sources:

• Directly from you

• Cookies – see our cookie statement which can be accessed from GUS website

To improve your experience on our site, we may use ‘cookies’. Cookies are an industry standard and most major web sites use them. A cookie is a small text file that our site may place on your computer as a tool to remember your preferences. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website.

Our website may contain links to other websites. Please be aware that we are not responsible for the privacy practices of such other sites and we advise and encourage you to be aware and read their privacy policy.

• Analytics providers, such as Google Analytics

Our website uses Google Analytics, a service which transmits website traffic data to Google servers in the United States. We use reports provided by Google Analytics to help us understand website traffic and webpage usage. Google Analytics does not allow us, or give us access to identify individual users or associate your IP address with any other data held by Google.

We collect aggregate information on what pages consumers access or visit, information volunteered by the consumer, such as enquiry information and/or site registrations. The information we collect is used to improve the content of our website, and is not shared with other organisations for commercial purposes.

By using this website, you consent to the processing of data about you by Google in the manner described in Google’s Privacy Policy and for the purposes set out above. You can opt out of Google Analytics if you disable or refuse the cookie, disable JavaScript, or use the opt-out service provided by Google.

• GUS Australia also uses interfaces with social media sites such as Facebook, LinkedIn, Twitter and others. If you choose to “like” or “share” information from this website through these services, you should review the privacy policy of that service. If you are a member of a social media site, the interface may allow the social media site to connect your visits to this site with other Personal Information

Who we share your information with

We may share your personal information with the following third parties:

• Our agents and service providers who we use to help us with marketing.

• Event organisers (if we are organising an external event which you are attending)

• The police and other law enforcement agencies

• Relevant regulators, including the Information Commissioner's Office in the event of a personal data breach

• Other companies owned or jointly owned by Global University Systems

• Potential or actual purchasers of any part of our business or assets, or other third parties in the context of a possible transfer or restructuring of our business.

How long we keep your personal information

Where we use your personal information for marketing purposes, we will retain your personal information for so long as we have your consent to do so (where we use your personal information with your consent in order to send you marketing messages) or, in other cases, for so long as we have a legitimate business or commercial reason to do so (unless you ask us to stop).

Where you withdraw your consent to receiving marketing materials or otherwise ask us to stop marketing, we will add your details to a suppression list which ensures that we remember not to contact you again.

For further information as to how to withdraw your consent or to ask us to stop other marketing activities see Withdrawing consent using your information and Objecting to how we may use your information.

If you withdraw your consent to receiving marketing materials or ask us to stop our marketing activities, we will still communicate with you for other purposes in the normal course of any other relationship we may have with you.

International transfers

As a global company, we hold some personal information concerning our suppliers and their affairs within the United Kingdom. We do work with agents and service providers who may process your personal information on our behalf outside the UK. If your information is processed outside the UK, we will ensure that it is protected to the same standards as if it were being processed within the UK by putting in place a contract with our agents and service providers that provides adequate safeguards, such as Standard Contractual Clauses or equivalent measures.

If you require more information or have any queries, please contact our Data Protection Officer at: dataprotection@gus.global

Purposes for which we will use your personal data

We have set out below a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

We may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.

Purpose/Activity: Type of data: Lawful basis

To respond to your request for a call (or email) back, course enquiries, applications (a) Contact Data Performance of a contract with you (in our anticipation of entering into such contract with you)

Purpose/Activity: Type of data: Lawful basis

Direct marketing of or about GUS Australia activities and events or services. (a) Contact Data Consent

Direct marketing may include cookie based remarketing services intended to deliver targeted marketing to you based on your internet searches Legitimate interest

Purpose/Activity: Type of data: Lawful basis

To process your application including for the provision of services including: (a) Identity Data (a) Performance of a contract with you

(a) Manage payments, fees and charges (b) Contact Data (b) Necessary for our legitimate interests (to recover debts due to us)

(b) Collect and recover money owed to us (c) Financial Data (c) Consent

(c) accounting for GST purposes (d) Transaction Data

(e) Marketing and Communications Data

(f) Academic Data

Purpose/Activity: Type of data: Lawful basis

To manage our relationship with you which will include: (a) Identity Data (a) Performance of a contract with you

(a) Notifying you about changes to our terms or privacy policy (b) Contact Data (b) Necessary to comply with a legal obligation

(b) Asking you to leave a review or take a survey (d) Marketing and Communications Data (d) Necessary for the candidate’s legitimate interests

Purpose/Activity: Type of data: Lawful basis

Equal opportunities monitoring Gender ethnicity religion and nationality Legal Obligation

Customers (or prospective customers) of online courses and published media

Purpose/Activity: Type of data: Lawful basis

Register new customer of online materials (a) Identity Data Performance of a contract with you

(b) Contact Data

Purpose/Activity: Type of data: Lawful basis

Process / fulfil / deliver customer order (a) Identity Data (a) Performance of a contract with you

Manage payments, fees and charges (b) Contact Data (b) Necessary for our legitimate interests (to recover debts due to us or defend legal claims)

Collect/ recover monies owed (c) Financial Data (c) Necessary to comply with a legal obligation

Accounting records (d) Transaction Data

Defence of legal claims brought against us (e) Marketing and Communications Data

Clients of GUS Australia (including employer clients)

Purpose/Activity: Type of data: Lawful basis

To register you as a client of GUS Australia (a) Identity Data Performance of a contract with you

(b) Contact Data

For All:

Purpose/Activity: Type of data: Lawful basis

Recruitment (a) Identity Data Performance of a contract

(b) Contact Data

Purpose/Activity: Type of data: Lawful basis

Relationship management (a) Identity Data (a) Performance of a contract with you

Updating privacy policy and notify you of the same (b) Contact Data (b) Necessary to comply with a legal obligation

Updating terms and conditions and notify you of the same (c) Profile Data (c) Necessary for our legitimate interests (continuous improvement / updating records/ analyse customer behavior patterns)

Seeking your feedback (d) Marketing and Communications Data

Processing complaints

Purpose/Activity: Type of data: Lawful basis

To administer and protect our business and our Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity Data (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Contact Data (b) Necessary to comply with a legal obligation

(c) Technical Data

Purpose/Activity: Type of data: Lawful basis

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you (a) Identity Data Legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

(b) Contact Data

(c) Profile Data

(d) Usage Data

(e) Marketing and Communications Data

(f) Technical Data

Purpose/Activity: Type of data: Lawful basis

To use data analytics to improve our website, products/services, marketing, student and partner relationships and experiences (a) Technical Data Legitimate interests (to define customer types for our products /services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

(b) Usage Data

To make suggestions and recommendations to you about goods or services that may be of interest to you (a) Identity Data

(b) Contact Data

(c) Technical Data

(d) Usage Data

(e) Profile Data Necessary for our legitimate interests (to develop our products/services and grow our business)

In addition to our Privacy Policy GUS Australia is also committed to maintaining high standards of data protection, information security, privacy and transparency for citizens of the EU. As such, we comply with the GDPR as a processor and controller of data, and place a high priority on protecting and managing data in accordance with these standards.

GUS Australia has made every effort to ensure the accuracy of the information contained in this website. However, we make no representation concerning the content or accuracy of the information. We accept no responsibility for any error or omission and reserve the right to amend details as a result of changing circumstances for any reason and without notice. Use of the information and data contained within this site or these pages is at your sole risk. If you rely on the information on this site, you are responsible for ensuring by independent verification its accuracy, currency or completeness. Where we have provided hypertext links to certain sites as a service to our clients, this does not imply any link between GUS Australia and the owners of such sites. Those linked websites will have their own terms and conditions of use. We recommend that you familiarise yourself with their terms.

All linked websites are linked ‘as is’ and GUS Australia does not:

1. sponsor, endorse or necessarily approve of any material on websites linked from or to this site;

2. make any warranties or representations regarding the quality, accuracy, merchantability or fitness for purpose of any material on websites linked from or to this site;

3. make any warranties or representations that material on other websites to which this site is linked does not infringe the intellectual property rights of any person anywhere in the world; and

4. authorise the infringement of any intellectual property rights contained in material in other websites by linking this site to those other websites.

GUS Australia and its agents, employees, officers and contractors:

1. make no representations, express or implied, as to the accuracy of the information and data contained on this site;

2. make no representations, express or implied, as to the accuracy or usefulness of any translation of the information on this site or any linked website into another language;

3. make no representations, either expressed or implied, as to the suitability of the said information and data for any particular purpose;

4. make no representations as to the availability of the site and the availability of websites linked from or to the site;

5. accept no liability however arising for any loss resulting from the use of the site and any information and data or reliance placed on it (including translated information and data);

6. accepts no liability for any interference with or damage to a user’s computer, software or data occurring in connection with or relating to this site or its use or any website linked to this site; and

7. do not represent or warrant that applications or payments initiated through this site will in fact be received or made to the intended recipient. Users are advised to confirm the application or payment by other means.

GUS AUSTRALIA may revise this disclaimer at any time by updating this page.

If you feel that we are not following the information contained in this policy, you may contact us at dataprotection@gus.global

You may also make a complaint about our handling of your Personal Information.

We take all complaints seriously and we undertake to respond within 30 days. If the request or complaint will take longer to resolve, we will provide you with a date by which we expect to respond.

If you are dissatisfied with the handling of your complaint, you can contact the Office of the Australian Information Commissioner:

Office of the Australian Information Commissioner

GPO Box 5218

Sydney NSW 2001

Ph: 1300 363 992

Email: enquiries@oaic.gov.au

GUS Australia Contact

GUS Education Australia Pty Ltd

Level 21, 25 Grenfell Street

Adelaide SA 5000

Email: adminau@gus.global