The table below sets out the basis on which we process different information about you and explains the purpose of that processing. 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.

In addition, we process personal information for the following additional purposes:

• for internal record keeping;
• to enable us to contact you by e-mail, text or phone for any of the above reasons;
• where necessary as part of any restructuring of the Keypath Group, sale of part of part or all of our business or other significant corporate transaction, investment or restructuring or insolvency;
• where necessary for compliance with legal, regulatory and other good governance obligations;
• to convert personal information into pseudonymous and or anonymous data and use it (normally on an aggregated statistical basis) for research and analysis to improve the quality of the Services for the University; and
• to measure the efficacy of Keypath’s services and the University’s courses and continuously improve Keypath’s services.

In each case, we consider the processing of your personal information for the above additional purposes is necessary for our legitimate business interests. Keypath has assessed its legitimate interests (as set out above), has balanced those interests against your individual rights and considers that the processing undertaken is necessary and proportionate to those rights in respect of providing and improve its services.

This list may be updated from time to time as business needs and legal requirements dictate. Some of the personal information that Keypath maintains will be kept in paper files, while other personal information will be included in computerised files and electronic databases as set out in more detail below.

When we act as a Processor on behalf of the University, the University is the Controller of your personal information and is responsible for identifying the purposes and legal bases for such use and instructing us on how to use it on their behalf.

This typically includes our processing of the following types of information:

• Course(s) and/or program(s) admittance and acceptance status;
• Official student enrolment details, timing and status;
• Subject registration details, timing, status and outcome;
• Financial records and payments for course(s) and/or program(s);
• Subject assessment details and participation; and
• Degree path plans (future subjects necessary for graduation).

We may obtain such information about you from the University, or directly from you when you interact with our Advisor. We use such information on behalf of the University for example, to provide you with information and services you have requested from that University, or to assist you and the University with your enrolment on their courses and to facilitate your flexible online learning.

We may share your information where necessary to facilitate the purposes set out above. We have provided further details of the parties with whom we may share your personal information below.

We may disclose your personal information to third parties if we are under a duty to disclose or share your personal information, in order to comply with any legal regulations or good governance obligations, or in order to enforce or to protect our rights, property, or safety, or that of other persons with whom we have a business relationship, or to purchasers, prospective purchasers or investors in relation to a disposal of or investment in our business or assets.

Sharing information with service providers:

We may use third party service providers to support our provision of the Services to the University. This could include:

• Office applications and email and other IT managed service providers (including cloud hosting and support);
• Website analytic/testing providers;
• Search engine optimisation (SEO) enquiry source providers;
• SEO link-building partners (based in USA/Canada/Australia/EU);
• Banner ad/click-through enquiry source providers;
• Marketing service enquiry source providers whom we refer to as Pay Per Insertion vendors (PPI) (based in USA/Canada/Australia/EU);
• Marketing and advertising agencies and their relevant systems (based in USA/Canada/Australia/EU);
• Media management tools;
• Marketing and email automation;
• Webinar, meeting, communication and chat services; and
• Social media businesses (including Facebook).

We may also share your personal information with other, less direct, business functions, including (without limitation) IT support, hosting our data on cloud platforms, legal, accounting, audit, consulting and other professional service providers, and providers of other services related to our business. Portions of our Services may be provided by organisations with which Keypath has a contractual relationship, including subcontractors, and, accordingly, your personal information may be disclosed to them. We only provide these organisations with the information that they need to be able to perform their services.

These companies use information about you to perform their functions on our behalf. We may disclose specific information upon lawful request by government authorities, law enforcement and regulatory authorities where required or permitted by law and for tax or other purposes. Your personal information may also be made available to third parties or partners where necessary as part of any restructuring of Keypath Group or sale of Keypath Group’s business or assets. Personal information may also be released to external parties in response to legal process, and when required to comply with laws, or to enforce our agreements, corporate policies, and terms of use, or to protect the rights, property or safety of Keypath, our employees, agents, customers, and others, as well as to parties to whom you authorise Keypath to release your personal information.

We may share personal information (and anonymised information) with directors, employees, agents and subcontractors (Personnel) of the Keypath Group as needed for the provision of the Services including in relation to taking decisions regarding the expansion and promotion of our product and service offering, order or customer request fulfilment and for use by those companies for the other purposes described in this GDPR Policy and our Privacy Policy.

The Site includes links and plugins (e.g. social media buttons) to third party websites. Some of your personal information from your browsing session may be transferred to such third party websites. Where our website contains links to websites operated by third parties (for example advertisers or affiliates of the website owner), you may provide your personal information to the owners of such third party websites without realising that the use of your data by the third party is not governed by this Policy. You should always check the privacy policies of third party websites before submitting your personal information. Please see our Cookies Policy for more information.

Please note that the University has their own Privacy Policy which will also be applicable to any dealings with your Personal Information by the University. The University’s privacy statements provide further information about how the University processes and protects personal information.

In addition to processing your personal information as a Data Processor on behalf of the University, we may also collect and share your personal information with the University for the purposes of supplying the Services to  the University. For example, we may share the following information:

• your name, address, email address, telephone number, nationality and/or country of residence;
• your preferred course(s) and/or program(s);
• duration of your preferred course(s) and/or program(s);
• enrolment details and/or time;
• demographic information collected prior to applying at the University;
• educational history, employment history (including job title or employer, career history or CV if provided in advance for admissibility feedback) and planning information collected prior to applying for enrolment at the University;
• the type and number of course(s) and/or program(s) you choose to enrol with;
• financial investment in course(s) and/or program(s);
• your motivation for enrolment;
• your reason for cancelling the course or program; and
• your reasons for not continuing the application or enrolment process (if applicable).

No.

Subject to your consent if required by applicable law, we may use your personal information to provide you with direct marketing information about our products and services as well as those of third parties, and we may permit those third parties to send their own direct marketing to you. Our direct marketing may be by email, telephone, post, electronic message or SMS or such other method(s) as may become relevant.

We will ensure that any direct marketing from us and which is sent by electronic means will provide a simple means for you to stop further communications, in accordance with applicable law. For example, in emails, 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.

You may manage your consent preferences in respect of direct marketing activities by emailing cst@keypathedu.com, or writing to:

Keypath Education Australia

Level 7, 567 Collins St, Melbourne VIC 3000

We use a variety of security measures to maintain the safety of your personal information. Your personal information is processed, stored and protected by firewalls and intrusion detection systems, plus industry standard encryption. While we take efforts to safeguard your personal information which are consistent with relevant laws, the nature of the internet is such that we cannot guarantee absolutely the security of any personal information you disclose online.

C. Your Privacy Rights

The table below sets out the specific rights you have in respect of our processing of your personal information, which may depend on the basis we process it for.