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Personal Data Processing Notification (‘Notification’)

Last updated: May 2023

UniFastTrack, a division of Keypath Education Australia Pty Ltd (who is referred to in this Notification, together with our affiliates, as “UniFastTrack,” “us,” “we,” or “our,” or “The Keypath Group,” depending on the context) provides online program management services (“Our Services”), on behalf of UNSW College, a division of UNSW Global Pty Ltd (“Partner School”).  UniFastTrack respects your privacy, and takes the privacy and security of personal data seriously.

This Notification explains:

• what Personal Data we collect and how we collect and use that Personal Data;
• when and with whom we may share the Personal Data we collect; and
• your choices and rights regarding your Personal Data.

This Notification applies to Personal Data that we collect through the websites, apps or social media platforms that link to this Notification (referred to collectively as the “Site”), as well as through any other contact you have with UniFastTrack through or on behalf of UNSW College, or another UNSW College partner, Open Learning Limited and its affiliates (“OLL”) (together, “Partners”) in connection with the UniFastTrack-supported online educational programs they offer (referred to generally as a “Program” or the “Programs”).

Our Partners have their own privacy policies, and their collection and use of your Personal Data is subject to the terms of that policy.  At the date of this Notification, those policies can be accessed as follows:

• UNSW College
• Open Learning

Who this Personal Data Processing Notification applies to

This Notification applies to those data subjects who interact with UniFastTrack, or otherwise access the Site, and provide their Personal Data when doing so.

COLLECTION AND USE OF PERSONAL DATA

A. What We Mean By “Personal Data.”

“Personal Data” means information in the form of symbols, scripts, digits, images, sounds or similar forms in the electronic environment, attached to a specific person, or, helping to identify a specific person. Personal data includes basic personal data and sensitive personal data.

“Information that helps identify a specific person” means information formed from the activities of an individual that, when combined with other data and stored information, can identify a specific person.

B. Providing Personal Data Is Your Choice.

We will collect Personal Data from you only if you voluntarily provide it to us. For example, if you decide to contact us, such as through a “Contact Us,” “Request More Information,” or similar links on the Site, if you request information about our Partner or about the Programs and other services we and they offer, if you apply for enrolment in a Program, or if you sign up to receive newsletters or other materials, you may provide us basic personal data such as your name, email address, and any other information you include with your submission. If you participate in a Program, we will obtain Personal Data from you so that we and our Partners can provide you with the services that you have signed up to receive.

If you choose not to provide certain Personal Data, that choice may make it difficult or impossible for you to access services through the Site. For example, you may not be able to enrol in or complete a Program. However, it is ultimately your choice whether you want to interact with us and the Partners, enrol in Programs, and/or participate in online learning through the Partners.

In addition, our Sites automatically collect certain information from site visitors, such as the IP address or other unique identifier of your computer or other device, and information about the browsing history and website interactions associated with that device. This device and online activity information, when combined with other data and stored information, may, at that point, identify a specific person and may therefore be considered Personal Data. We do not use this type of automatically-collected Personal Data to identify or to further interact with a particular person unless and until that user voluntarily provides other Personal Data in the manner outlined above.

C. The Type of Personal Data We Collect and the Purposes for Processing that Data.

1. Personal Data We and Our Partners Collect Directly

The Personal Data you may be asked to provide to us and/or our Partners, and how we and they may use that Personal Data, is described below. We present this information based on the categories of Personal Data 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 Data We Obtain From Third Parties

As noted above, we collect some Personal Data from third parties, including Personal Data that has been provided to us from our Partners, so that we can provide our services in relation to the Programs.

3. Certain Generally Applicable Uses of Personal Data

In addition, all of the Personal Data we collect directly 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 our Partners’ internal record-keeping;
• To enable us or our Partners to contact you by e-mail, text or phone for any of the reasons listed above;
• Where necessary as part of any restructuring of the Keypath Group;
• For compliance with legal, regulatory, and other good governance obligations;
• To convert Personal Data into pseudonymous and/or anonymous data, and use it (normally on an aggregated statistical basis) for research and analysis;
• To gain insight that enables us and our Partners to measure the effectiveness of our services;
• To learn about potential and current students, their interests, needs and resources applicable to the Programs, so that we can improve the Programs and provide you and others with better services; and
• To evaluate potential and current students’ needs and resources applicable to the Programs, and to tailor our marketing messages to your and their specific interests, needs, and abilities.

When we use your Personal Data for our business purposes, those business purposes include working with our Partners to make Programs available, responding to your, our students’ and potential students’ comments and complaints, marketing our and our Partners’ products and services, improving and developing new products and services, and ensuring the productivity, functionality, and security of the Site.

HOW WE COLLECT AND USE NON-PERSONALLY IDENTIFIABLE INFORMATION

A. What Is Non-Personally Identifiable Information? 

Non-personally identifiable information refers to information that is not and cannot be used to identify a specific individual. This may include information about the statistical characteristics of the visitors to the Site or persons who enrol in Programs. 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 (without other information) to specifically identify you. This section describes how we collect and use non-personally identifiable information.

B. The Non-Personally Identifiable 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 the Site visitors 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 “Cookie Policy” section of this Notification. 

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 our Partners’ services. The analytics services we use include Google Analytics, Facebook Ads, and others. 

E. Anonymous Information.

Anonymous information refers to information that does not enable identification of an individual user, such as aggregated or demographic information. We may use anonymous information or disclose it to third party service providers to improve the Site and our and our Partner School’s services. We may also disclose anonymous information to third parties, including 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 Data 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 analyse user behaviour, 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 behavioural 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 the Partners.

We collect, use, and process your Personal Data on behalf of our Partners, and accordingly, it will be shared with the Partners for all purposes consistent with this Notification, including to process applications and enrolment materials and to fulfill our contractual relationship with the Partner School. In addition, we may also share your Personal Data with the Partners so that we can collaborate with them to develop, deploy, and deliver additional Programs and courses, and to facilitate flexible online learning.

Please note that we have no control over how the Partners uses Personal Data and other information we share with them. Our Partners have their own personal data processing notification, and their collection and use of your Personal Data is subject to their notifications, which will be different from this Notification.

B. Sharing Information with Others.

In addition to sharing information with our Partners (as discussed above), we may share information with other third parties in the following circumstances:

• We may share your information, including Personal Data, so that we or others may provide you with periodic mailings, or may contact you regarding products, services, or events.
• We may employ other companies and people to perform tasks on our behalf and we may need to share Personal Data with them to provide services to you. For example, such parties may handle our data management and/or email distribution. Unless we tell you differently, they do not have any right to use your Personal Data beyond what is necessary to assist us.
• We may share information, including Personal Data, with our corporate affiliates in the Keypath Group for our and their legitimate business purposes, including the potential expansion and promotion of our and their product and service offerings, and other uses consistent with the purposes described in this Notification.
• We may share your Personal Data with your employer, if your employer is paying for your enrolment in a Program.
• We will share Personal Data 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 Data 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 Data 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 our Partner School, (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 Data, 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 will never sell your Personal Data.

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, our Partner School, and/or the Program(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 Notification. You should always review the privacy policies of any site you visit before submitting your Personal Data.

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, you should review the privacy policies of those social networks and other third-party sites.

Our Security Measures

We use a variety of industry-standard security measures to maintain the safety of your Personal Data, including measures designed to secure your Personal Data from accidental loss and from unauthorized access, use, alteration and disclosure. We store the Personal Data 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 Data, 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 PERSONAL DATA

A. General Rights.

If you have any questions regarding this Notification or our use of your Personal Data, you can contact our Confidentiality and Security Team by email at cst@keypathedu.com. In addition, you can also contact us at any time at cst@keypathedu.com to request for access to, request for a copy of, and request that we make any edits to your Personal Data. 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 Data we collect. If you would like to request any earlier removal of your Personal Data, please contact us at cst@keypathedu.com. Please note that we may not be able to completely remove Personal Data 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. Additional Rights in relation to your Personal Data

In addition to your General Rights above, you have the following additional rights:

• the right to know – you have the right to be made aware of the processing of your Personal Data, unless otherwise provided for by law;
• the right to consent – you have the right to consent (or not) to the processing of your Personal Data, save for certain exceptions at law;
• the right of access – you are entitled to access, in order to view, correct or request correction of, your Personal Data, unless otherwise provided by law;
• the right to withdraw consent – you are entitled to withdraw your consent to the processing of your Personal Data, unless otherwise provided by law;
• the right to erasure – you are entitled to delete or request the erasure of your Personal Data, unless otherwise provided by law, if you wish to do so, please contact us using the information provided in this Notification;
• the right to restriction of data processing – you are entitled to request the restriction of the processing of your Personal Data, unless otherwise provided for by law;
• the right to data provision – you may request that we provide your Personal Data to you, or to a third party, unless otherwise provided for by law;
• the right to object to processing – you may object to our processing of your Personal Data for advertising or marketing purposes, unless otherwise provided for by law;
• the right to complain, denounce and initiate lawsuits – you have the right to lodge complaints, denunciations or initiate lawsuits in relation to the processing of your Personal Data in accordance with the provisions of the law;
• the right to claim damages – you have the right to claim compensation in accordance with the law when a violation of the privacy law occurs, unless otherwise agreed by you and us, or otherwise provided for by law; and
• the right to self-defence – you have the right to self-protection in accordance with the provisions of statute, request the relevant agencies and organisations to take measures to protect your civil rights as prescribed under statute.

POTENTIAL CONSEQUENCES AND HARMS FROM PROCESSING

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 our Partners, may make available services that enable you to post information on the Sites 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 LONG WE KEEP PERSONAL DATA

We will keep your Personal Data from the date that you provide it to us, and for 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 our Partner School. For example, we will keep Personal Data for at least as long as you continue to be enrolled in any Program and, if any Site allows you to create an account, we will keep the Personal Data associated with your account for as long as you maintain it. Business needs for which Personal Data 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 Partner School, unless we agree otherwise with the Partner School. Once we cease to have a relationship with our Partner School, our practice is to de‑identify all Personal Data that we have learned in the course of that relationship.

YOUR RIGHTS REGARDING MARKETING SERVICES AND ADVERTISING

As noted above in this Notification, we may use your Personal Data to provide you with marketing and promotional information about our and our Partners’ 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.

By providing us with a phone number, you are giving your express consent to be called and/or texted by us or by our Partners at the number you provide. You understand that these calls may be generated using an automated technology, including, by way of example, auto-dialler and click-to-dial technologies. These calls may be recorded for quality assurance and training purposes. In cases where we need your consent for direct marketing communications under applicable law, if you provide your consent you will be able to change your mind at any time.

All promotional materials that are sent 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 any email address to which you can send an opt-out request.

You can manage your consent preferences with respect to direct marketing activities by contacting us at cst@keypathedu.com.

Please note that despite your phone and email preferences, we may need to contact you regarding your enrolment at our Partners, 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 AND MINORS

The Site is not targeted to, and we have no interest in collecting information from, children, and we do not knowingly gather any Personal Data 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 Data, please contact us at cst@keypathedu.com. You consent to us verifying your age before processing your Personal Data.

If you are aged between of 15 and 17 years old, you shall not provide your Personal Data to us without first obtaining the consent of your parent or legal guardian.

CHANGES TO THIS PERSONAL DATA PROCESSING NOTIFICATION

We may make changes to this Notification. Any modifications will be effective when the changes are posted to the Site. You can review the most current version of this Notification at any time by accessing the section of the Site labelled ‘Privacy Policy’, and you can determine when this Notification was last revised by referring to the “Last Updated” legend at the top of this Notification. You are expected to check this Notification from time to time to take notice of any changes.