Privacy notice

Introduction

1. This Privacy Policy is the official privacy policy of Campion Education (Aust) Pty Ltd and its subsidiaries (“Campion”). It applies to all personal information collected by Campion, including via com.au and any related Campion website, social media page, internal website or intranet (each a Website); any Campion mobile or tablet application (each an Application); and from an individual via any other means, including physically or electronically (together, the Collection Channels).
2. In this policy we explain how and why we collect your personal information, how we use it and disclose it, and what controls you have over our use of it. We appreciate that you may have certain concerns about how your personal information is collected, used and shared. We can assure you that we will always handle your personal information securely and carefully.
3. In addition to the provisions of this Privacy Policy, there may also be specific and additional privacy and consent provisions that apply to certain Collection Channels. Because those specific and additional provisions also relate to your privacy protection, we recommend that you review them wherever they appear. In the event of any inconsistency between the provisions of this Privacy Policy and those other specific and additional provisions, the specific and additional provisions will prevail.

The Office of the Australian Information Commissioner (“OAIC”) http://www.oaic.gov.au provides further details of the Privacy Act 1988 (Cth) (The Privacy Act) and how it protects personal information in Australia.

The information that we collect

In our operations we may gather certain types of information in the course of providing our products and services to you, including information about the users of our Websites and other channels. For example we collect:

1. Personally Identifiable Information. This is provided by you when you:
   • register for services that we may offer via our Websites;
   • respond to our feedback surveys;
   • establish an account with us or through one of our externally hosted application
   • submit an after-purchase enquiry;
   • call, email or fax or otherwise communicate with our customer service team; and/or
   • apply for employment with us.
2. Aggregated Data. This information is generated by our systems as they track traffic through our sites. This information does not identify you personally and is not linked to the personally identifiable information that you may have provided.

We will only collect personal information if it is necessary for one of our functions or activities. The kinds of personal information that we collect are set out below.

Information that you provide to us

We collect personal information that you provide directly to us and information you provide to us regarding third parties (such as your children), including when you make a purchase, register for an account or subscribe to a newsletter. The personal information we collect may include:

• your name;
• your gender (if relevant);
• your contact details including your email address, delivery address, phone number;
• more detailed contact or service preferences;
• information regarding your experiences with our products and services; and
• employment and company information such as the name of your employer and your position for textbook delivery only.

Information that we collect from your use of our Websites and Applications

When you use a Website or Application, we may also collect information in the following general categories:

• Location information: if you permit a Website or Application to access location services through the permission system in your mobile device, we may collect the precise location of your device.
• Transaction information: we collect your transaction details when you place an order, including the products you have ordered, the date and time of your order and the amount charged.
• Usage and preferences: We collect information about how you interact with our Websites or Applications, including the pages you visit, your preferences and settings that you choose. We may do this through the use of cookies and other similar technologies that uniquely identify an internet service provider address or your account for example.
• Device information: We may collect information about your device such as the hardware model, operating system, preferred language, unique device identifier and mobile network.
• Other information: We may also collect and log information such as your IP address, access dates and times, browser type and pages visited when you interact with a Website or Application.

Information we collect from third parties

In addition to the information listed above, in some cases we may collect personal information about you from legitimate third party sources including social media sites and list brokers and other data providers that share data in circumstances where it is lawful and/or they have your permission to do so. This may include:

• When a third party has your consent to disclose your personal information to us, such as when you enter a competition or promotion administered by a third party on our behalf;
• When it is otherwise lawful for a third party to disclose your personal information to us, such as when we access purchasing information through our business partners or are provided data by a list broker.

Why do we collect your information?

We collect the information in order to provide the best possible service to you while you are visiting our stores and using our services, including our Websites. To this end we may use the information that you provide for the following purposes:

• to process any transactions that you might make including in our stores, by way of paper order forms, telephone orders or on our Websites including delivering your products to you;
• to make contact with you as the contact person for an educational institution that we deal with;
• to help to provide any other services that you have requested;
• to offer the most relevant information about our products and services suitable to you and your interests;
• for the purposes of collection of any debts owing to us;
• to provide customer support, including responding to your enquiries made via our Websites or otherwise;
• for any other purposes for which you have given permission;
• in order to review your application for employment and contact you regarding your application;
• for the purposes of obtaining professional advice in connection with the services provided to you; and
• to comply with our legal obligations to law enforcement, regulators and the courts.
• to offer additional products that may be relevant to your needs

You will be given an option to opt-out of our promotional emails. If you opt-in, but eventually decide to opt-out, you can do so by clicking the ‘Unsubscribe’ link in one of such promotional emails.

Who we share this information with

We will need to share your information with third parties for the purpose addressed above; including in the following circumstances:

• information may be hosted with a service provider or provided to an information technology provider for the purposes of providing technical support. Our agreements with them protect the information that we collect, from any use by them that we have not authorised;
• information may be provided to card payment service providers who operate payment platforms, though ordinarily this is done directly by you;
• address information may be provided to logistics and courier companies for the purposes of delivering your order;
• your personal information may be shared with third parties when we believe in good faith that we are required to do so by law;
• if we have asked your prior permission (which we would usually do at the time of collection), we may share the information with specified third parties;
• information may be provided to third party debt collection services for the purposes of collecting any monies owed by you;
• information may be provided to our publishers for the purposes of distributing the products they provide to you;
• information may be provided to third party providers in order to enhance the services provided to you (e.g. setting up digital access with publishers or content providers);

We will not otherwise share your information with third parties unless you would reasonably expect us to do so in connection with the purposes your information was provided to us.

Overseas Disclosure

We do not disclose any of your personal information overseas.

Anonymity and Pseudonymity

We will not collect or monitor your personal information without your express or implied consent.

Personal information is only collected for the purposes of establishing a relationship with our clients as well as providing and effectively marketing our goods and services to customers.

Use of cookies

A cookie is a small file that resides on your computer and is recognised by our server when you visit our sites. A cookie does not provide us with any personally identifiable information. It does provide details of your IP address, the computer platform that you use (e.g. Mac or Windows), the browser that you use (e.g. Chrome, Firefox, Safari, Opera, Internet Explorer), what domain you are accessing our site from, and visit duration.

We use Google Analytics to collect this data, which helps us track traffic patterns to our website, display the most relevant content, understand user behaviour on the website and therefore make informed decisions about optimising your user experience. You can find more information about Google Analytics and privacy here.

A number of Google Analytics Advertising Features, such as Remarketing and Interest-based Advertising, may also be used from time to time on Campion websites. We and third-party vendors, including Google, use first-party and third-party cookies together to inform, optimise, and serve ads based on visits to our website.

In addition, third parties may place and read cookies on your browser, or use web beacons or similar technologies to collect information, including, where applicable, for the Google Trusted Stores program.

If you wish, you can prevent your data from being used by Google Analytics by using the Opt-out Browser Add-on. You can read more about managing cookies in your browser here.

Our advertisers and business partners

This Privacy Policy relates to all of our Websites. You should be aware that we are not responsible for the practices of our advertisers or business partners. Our sites may contain links to other sites. Check their privacy policies before providing personally identifiable information to them or any other third party.

Your payment information

Campion Education does not store your credit card details for online payments. Online transactions are processed directly through our secure payment gateway. We are provided with the last 4 digits of your credit card number and the payment status for reference purposes only.

How we store this information

We take all reasonable steps to ensure all personal information stored is protected from misuse, interference and loss from unauthorised access. We hold personal information on secure databases on secure premises. Only authorised members of staff have access to this information. We will endeavour to ensure that any personal information transferred is only in an encrypted form and we monitor access to IT systems to mitigate the risk of any misuse of data.

If you have a personal password that enables you to access certain parts of our Websites or Applications, or other service we operate, do not forget your responsibility to keep this password secure and confidential.

We will destroy or de-identify personal information where it is no longer required for the purposes outlined in this policy, unless we are required or authorised by law to retain the information.

Notifiable Data Breaches

Although unlikely, if we believe there has been an unauthorised access to, or loss of, any data stored by Campion, we will attempt to remedy the situation as soon as reasonably possible to prevent any serious harm or loss of information. However, following this remedial action, if we believe that there are still grounds to believe the unauthorised access or loss will result in serious harm to individuals to whom the information concerns, we will seek to notify those individuals.

Changes to this policy

In order to reflect the fact that our business is growing constantly, we reserve the right to change this policy at any time and our updated policy will be posted on our website. In the event the policy changes significantly we will notify you of the change via appropriate channels.

Accessing & correcting your information

The Privacy Act gives you the right to access and correct the information we hold.

To obtain access to your personal information you may be required to provide you must provide proof of identity, you must be reasonably specific about the information you seek to access and we may charge you a reasonable administration fee which accurately reflects the cost of providing the access in accordance with your request.

If you do not want to receive any communication from us or would like to amend, update or access your personal information you can do so by contacting us via privacyofficer@campion.com.au or by post to:

Campion Education Privacy Officer

Unit 1, 170-180 Rooks Road

Nunawading    VIC    3131.

We will do all that we can to assist you, however if you are not satisfied with our response you may then take your complaint to the Office of the Australian Information Commissioner (http://www.oaic.gov.au).