Last updated: August 9th 2023

This Privacy Policy sets out our commitment to protecting the privacy of personal information provided to us, or otherwise collected by us, when providing our website and curriculum management system (Services) or when otherwise interacting with you. In this Privacy Policy we, us or our means CourseLoop Pty Ltd (ABN 24 167 830 275) and our United Kingdom subsidiary, CourseLoop UK Ltd, a company registered in England and Wales with company number 14123683.

This Privacy Policy takes into account the requirements of the Privacy Act 1988 (Cth) and the Australian Privacy Principle. In addition to the Australian laws, individuals located in the European Union or European Economic Area (EU) may also have rights under the General Data Protection Regulation 2016/679 and individuals located in the United Kingdom (UK) may have rights under the General Data Protection Regulation (EU) 2016/679) (UK GDPR) and the Data Protection Act 2018 (DPA 2018) (together, the GDPR). Appendix 1 outlines the details of the additional rights of individuals located in the EU and UK as well as information on how we process the personal information of individuals located in the EU and UK.

How we collect personal information  

We collect personal information in a variety of ways, including:

• Directly: We collect personal information which you directly provide to us, including when you sign up to our Services, through the ‘contact us’ form on our website or when you request our assistance via email, or over the telephone.
• Indirectly: We may collect personal information which you indirectly provide to us while interacting with us, such as when you use our website and CourseLoop platform, in emails, over the telephone and in your online enquiries.
• From third parties: We collect personal information from third parties, such as from the university you work for where they are signing you up for a CourseLoop account, details of your use of our website from our analytics and cookie providers and marketing providers. See the “Cookies” section below for more detail on the use of cookies.
• From publicly available sources: We collect personal data from publicly available resources such as the Australian Securities and Investment Commission (ASIC), Companies House and professional networking sites such as LinkedIn.

Why we collect, hold, use and disclose personal information

We have set out below, in a table format, a description of the purposes for which we plan to collect, hold, use and disclose your personal information.

Purpose of use / disclosure	Type of Personal Information
To sign you up to our Services.	• Identity Data • Contact Data
To comply with our legal obligations or if otherwise required or authorised by law.	• Any relevant Personal Information
To enable you to access and use our software, including to provide you with a login.	• Identity Data • Contact Data
To contact and communicate with you about any enquiries you make with us via our website.	• Identity Data • Contact Data
If you have applied to work with us; to consider your application.	• Identity Data • Contact Data • Professional Data
To contact and communicate with you about our Services including in response to any support requests you lodge with us or other enquiries you make with us.	• Identity Data • Contact Data • Profile Data
For advertising and marketing, including to send you promotional information about that we consider may be of interest to you.	• Identity Data • Contact Data • Technical and Usage Data • Profile Data • Marketing and Communications Data
For internal record keeping, administrative, invoicing and billing purposes.	• Identity Data • Contact Data • Transaction Data
For analytics, market research and business development, including to operate and improve our Services, associated applications and associated social media platforms.	• Profile Data • Technical and Usage Data

Our disclosures of personal information to third parties

We may disclose personal information to:

• our employees, contractors and/or related entities;
• IT service providers, data storage, web-hosting and server providers such as Amazon Web Services and ServiceNow;
• marketing or advertising providers;
• professional advisors, bankers, auditors, our insurers and insurance brokers;
• payment systems operators such as PayPal;
• our existing or potential agents or business partners;
• anyone to whom our business or assets (or any part of them) are, or may (in good faith) be, transferred;
• courts, tribunals and regulatory authorities, in the event you fail to pay for goods or services we have provided to you;
• courts, tribunals, regulatory authorities and law enforcement officers, as required or authorised by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights; and
• third parties to collect and process data, such as Google Analytics (To find out how Google uses data when you use third party websites or applications, please see www.google.com/policies/privacy/partners/ or any other URL Google may use from time to time), or other relevant analytics businesses; and
• any other third parties as required or permitted by law, such as where we receive a subpoena.

Google Analytics: We may have enabled Google Analytics Advertising Features including: Remarketing Features, Advertising Reporting Features, Demographics and Interest Reports, Google Display Network Impression reporting. We and third-party vendors may use first-party cookies (such as the Google Analytics cookie) or other first-party identifiers, and third-party cookies (such as Google advertising cookies) or other third-party identifiers together.

You can opt-out of Google Analytics Advertising Features including using a Google Analytics Opt-out Browser add-on found here. To opt-out of personalised ad delivery on the Google content network, please visit Google’s Ads Preferences Manager here or if you wish to opt-out permanently even when all cookies are deleted from your browser you can install their plugin here. To opt out of interest-based ads on mobile devices, please follow these instructions for your mobile device: On android open the Google Settings app on your device and select “ads” to control the settings. On iOS devices with iOS 6 and above use Apple’s advertising identifier. To learn more about limiting ad tracking using this identifier, visit the settings menu on your device.

Overseas disclosure

We may store personal information outside of the country where you are based, including in Australia and the United Kingdom. Where we disclose your personal information to the third parties listed above, these third parties may also store, transfer or access personal information outside of the country where you are based. We will only disclose your personal information overseas in accordance with applicable laws.

Your rights and controlling your personal information

Your choice: Please read this Privacy Policy carefully. If you provide personal information to us, you understand we will collect, hold, use and disclose your personal information in accordance with this Privacy Policy. You do not have to provide personal information to us, however, if you do not, it may affect our ability to provide our Services to you and your use of our Services.

Information from third parties: If we receive personal information about you from a third party, we will protect it as set out in this Privacy Policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have such person’s consent to provide the personal information to us.

Anonymity: Where practicable we will give you the option of not identifying yourself or using a pseudonym in your dealings with us.

Restrict and unsubscribe: To object to processing for direct marketing/unsubscribe from our email database or opt-out of communications (including marketing communications), please contact us using the details below or opt-out using the opt-out facilities provided in the communication.

Access: You may request access to the personal information that we hold about you. An administrative fee may be payable for the provision of such information. Please note, in some situations, we may be legally permitted to withhold access to your personal information. If we cannot provide access to your information, we will advise you as soon as reasonably possible and provide you with the reasons for our refusal and any mechanism available to complain about the refusal. If we can provide access to your information in another form that still meets your needs, then we will take reasonable steps to give you such access.

Correction: If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the details below. We will take reasonable steps to promptly correct any information found to be inaccurate, out of date, incomplete, irrelevant or misleading. Please note, in some situations, we may be legally permitted to not correct your personal information. If we cannot correct your information, we will advise you as soon as reasonably possible and provide you with the reasons for our refusal and any mechanism available to complain about the refusal.

Complaints: If you wish to make a complaint, please contact us using the details below and provide us with full details of the complaint. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take in response to your complaint. If you are not satisfied with our response, you also have the right to contact the Office of the Australian Information Commissioner.

Storage and security

We are committed to ensuring that the personal information we collect is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures, to safeguard and secure personal information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.

While we are committed to security, we cannot guarantee the security of any information that is transmitted to or by us over the Internet. The transmission and exchange of information is carried out at your own risk.

Cookies

We may use cookies on our website from time to time. Cookies are text files placed in your computer’s browser to store your preferences. Cookies, by themselves, do not tell us your email address or other personally identifiable information. However, they do recognise you when you return to our online website and allow third parties, such as Google and Facebook, to cause our advertisements to appear on your social media and online media feeds as part of our retargeting campaigns. If and when you choose to provide our online website with personal information, this information may be linked to the data stored in the cookie.

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website.

For more information about the cookies we use, please see here.

Links to other websites

Our website may contain links to other party’s websites. We do not have any control over those websites and we are not responsible for the protection and privacy of any personal information which you provide whilst visiting those websites. Those websites are not governed by this Privacy Policy.

Amendments

We may, at any time and at our discretion, vary this Privacy Policy by publishing the amended Privacy Policy on our website. We recommend you check our website regularly to ensure you are aware of our current Privacy Policy.

For any questions or notices, please contact us at:

Australia: CourseLoop Pty Ltd (ABN 24 167 830 275), Two Melbourne Quarter L2/697 Collins Street Docklands, VIC 3008 Australia, email: info@courseloop.com

United Kingdom: CourseLoop UK Ltd, a company registered in England and Wales with company number 14123683, 49 Greek Street London, W1D 4EG, United Kingdom, email: info@courseloop.com

United States: 242 Linden Street Fort Collins, CO 80424, email: info@courseloop.com

© LegalVision ILP Pty Ltd

Appendix 1: Additional rights and information for individuals located in the EU OR UK

Under the GDPR individuals located in the EU and the UK have extra rights which apply to their personal information. Personal information under the GDPR is often referred to as personal data and is defined as information relating to an identified or identifiable natural person (individual). This Appendix 1 sets out the additional rights we give to individuals located in the EU and UK, as well as information on how we process the personal information of individuals located in the EU and UK. Please read the Privacy Policy above and this Appendix carefully and contact us at the details at the end of the Privacy Policy if you have any questions.

What personal information is relevant?

This Appendix applies to the personal information set out in the Privacy Policy above. This includes any Sensitive Information also listed in the Privacy Policy above which is known as ‘special categories of data’ under the GDPR.

Purposes and legal bases for processing

We collect and process personal information about you only where we have legal bases for doing so under applicable laws. We have set out below, in a table format, a description of all the ways we plan to use your personal information, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal information for more than one lawful ground depending on the specific purpose for which we are using your data. Please reach out to us if you need further details about the specific legal ground, we are relying on you to process your personal information where more than one ground has been set out in the table below.

Purpose of use / disclosure	Type of Data	Legal Basis for processing
To sign you up to our Services	• Identity Data • Contact Data	Performance of a contract with you
To enable you to access and use our software, including to provide you with a login.	• Identity Data • Contact Data	Performance of a contract with you
To contact and communicate with you about our Services including in response to any support requests you lodge with us or other enquiries you make with us.	• Identity Data • Contact Data • Profile Data	Performance of a contract with you
To contact and communicate with you about any enquiries you make with us via our website.	• Identity Data • Contact Data	Legitimate interests: to ensure we provide the best client experience we can offer by answering all of your questions
For internal record keeping, administrative, invoicing and billing purposes.	• Identity Data • Contact Data • Transaction Data	• Performance of a contract with you • To comply with a legal obligation • Legitimate interests: to recover debts due to us and ensure we can notify you about changes to our contracts and any other administrative points
For analytics including profiling on our website, market research and business development, including to operate and improve our Services, associated applications and associated social media platforms.	• Profile Data • Technical and Usage Data	Legitimate interests: to keep our website updated and relevant, to develop our business, improve our Services and to inform our marketing strategy
For advertising and marketing, including to send you promotional information about our events and experiences and information that we consider may be of interest to you.	• Identity Data • Contact Data • Technical and Usage Data • Profile Data • Marketing and Communications Data	Legitimate interests: to develop our Services and grow our business
If you have applied to work with us; to consider your application.	• Identity Data • Contact Data • Professional Data	Legitimate interests: to consider your employment application
To comply with our legal obligations or if otherwise required or authorised by law.	All relevant personal information	To comply with a legal obligation

If you have consented to our use of data about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place. Where we are using your data because we or a third party have a legitimate interest to do so, you have the right to object to that use though, in some cases, this may mean no longer using our services. Further information about your rights is available below.

Data Transfers

The countries to which we send data for the purposes listed above may be less comprehensive that is what is offered in the country in which you initially provided the information. Where we transfer your personal information outside of the country where you are based, we will perform those transfers using appropriate safeguards in accordance with the requirements of applicable data protection laws and we will protect the transferred personal information in accordance with this Privacy Policy and Appendix 1. This includes:

only transferring your personal information to countries that have been deemed by applicable data protection laws to provide an adequate level of protection for personal information; or
including standard contractual clauses in our agreements with third parties that are overseas.
Data retention
We will only retain your personal information for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Extra rights for EU and UK individuals

You may request details of the personal information that we hold about you and how we process it (commonly known as a “data subject request”). You may also have a right in accordance with applicable data protection law to have your personal information rectified or deleted, to restrict our processing of that information, to object to decisions being made based on automated processing where the decision will produce a legal effect or a similarly significant effect on you, to stop unauthorised transfers of your personal information to a third party and, in some circumstances, to have personal information relating to you transferred to you or another organisation.

If you are not happy with how we are processing your personal information, you have the right to make a complaint at any time to the relevant Data Protection Authority based on where you live. We would, however, appreciate the chance to deal with your concerns before you approach the Data Protection Authority, so please contact us in the first instance using the details set out above in our Privacy Policy above.

For any questions or notices, please contact us using the details in our Privacy Policy above.