Clause 1 - Introduction
Sub-clause 1(a): ivyO is a global organization offering a complete range of services, including ivyO Strategic Consultation, ivyO BaseCamp, ivyO Compass and ivyO Summit.
Sub-clause 1(b): ivyO, its subsidiaries and affiliates in Australia (collectively referred to as ivyO) are committed to managing personal information pursuant to the Australian Privacy Principles (APPs) under the Privacy Act 1988 (Cth) (Privacy Act) and in accordance with other applicable privacy laws.
Clause 2 - Collecting Your Information
Sub-clause 2(a): When you enquire about our services or when you become a client/customer a record is made which includes your personal information.
Sub-clause 2(b): The type of personal information that we collect will vary depending on the circumstances of collection and the type of service you request from us, but will typically include: your name, e-mail, postal address and other contact details; your professional details; third-party account credentials (for example, your log-in credentials for Facebook or other third-party sites) transmitted into your account with us; and any additional personal information you provide to us, or authorize us to collect, as part of your interaction with ivyO.
Sub-clause 2(c): ivyO may also collect personal information about other individuals who are not ivyO customers/clients. This includes: individuals that make use of ivyO’s; members of the public who participate in events we are involved with; individual service providers and contractors to ivyO; and other individuals who interact with ivyO on a commercial basis.
Sub-clause 2(d): If you are participating in an event we are managing or delivering, we may take images or audio-visual recordings which identify you.
Sub-clause 2(e): In limited circumstances, ivyO may collect information which is considered sensitive information. For example, if you are injured at an event promoted or delivered by ivyO we may collect health information about you in an emergency or otherwise with your consent.
Sub-clause 2(f): We may also collect personal information about children. Where children do not have sufficient maturity and understanding to make decisions about their personal information, we will require their parents or guardians to make decisions on their behalf. ivyO does not knowingly collect or solicit personal information from anyone younger than the age of thirteen (13) or knowingly allow such persons to register.
Sub-clause 2(g): If you are under the age of thirteen (13), please do not attempt to register for the ivyO or send any information about yourself to us, including your name, address, telephone number, or email address. No one under age thirteen (13) may provide any personal information to ivyO or on the ivyO Sites.
Sub-clause 2(h): Should we learn we have collected personal information from someone under age thirteen (13) without verification of parental or guardian consent, we will delete that information as soon as possible. If you believe that we might have any information from or about a child under thirteen (13), please contact us as soon as possible.
Sub-clause 2(i): You may always decline to give ivyO any personal information we request, but that may mean we cannot provide you with some or all of the services you have requested.
Clause 3 - Collection and storage of your personal information
Sub-clause 3(a): ivyO may use and share the information you supply to us in the ways described in this Clause 3.
Sub-clause 3(b): ivyO may use your contact information to send you e-mail messages regarding updates to the Site, such as the publication of latest information and content, promotional offers, or to communicate with you about your use of the Sites. The frequency of these messages will vary depending upon your profile. You may opt-out of receiving these emails at any time via the unsubscribe link contained in the email message.
Sub-clause 3(c): The Sites may invite you to participate in surveys, contests, and other promotions relevant to your college search process. If you participate, your personally identifiable information may be shared with third party marketing partners to process entries and send you promotional material. Survey information may be used to monitor or improve the Site, but we will not share individual responses to a survey without your consent.
Sub-clause 3(d): Information you have entered into our registration forms are maintained in association with a user profile. We use that information in order to customize your experience on the Site based on your profile and interests. We use various methods to recognize you, including cookies and requesting your e-mail address and password before accessing our site.
Sub-clause 3(e): We may use anonymous information about how you use the Site (e.g., the schools in which you are interested in, schools to which you apply, etc.) to improve the functionality of the Site and improve our service offerings, including using this data at an aggregate level to create data analytics to analyse trends.
Sub-clause 3(f): ivyO may use your contact information to send you e-mail messages regarding updates to the Site, such as the publication of new ivyO information and content, promotional offers, or to communicate with you about your use of the Site. The frequency of these messages will vary depending upon your profile. You may opt-out of receiving these emails at any time via the unsubscribe link contained in the email message.
Sub-clause 3(g): We use third party vendors to perform operational functions related to the Site. Some of these vendors (e.g., marketing automation vendors, email vendors or hosting providers) may have access to your personally identifiable information, but only as necessary to provide services to the Site. ivyO has agreements in place with these vendors requiring them to keep your information confidential and use reasonable data security measures to protect it.
Sub-clause 3(h): The Site may use third party analytics services to help improve usability and the customer experience. These services may record mouse clicks, page views, mouse movements and scrolling activity and are used by us to analyse trends and oversee the administration of the Site.
Sub-clause 3(j): We will release your personal information if required by law, for example, if we receive a subpoena or otherwise believe in good faith that the law requires us to release your information.
Clause 4 - How does ivyO interact with you via the internet?
Sub-clause 4(e): You can use the appropriate settings in your browser to control how your browser deals with cookies. However, in doing so, you may be unable to access the full functionality of this website.
Sub-clause 4(f): ivyO's websites may contain links to third-party websites. ivyO is not responsible for the content or privacy practices of websites that are linked to our website.
Clause 5 - Dealing with ivyO Anonymously
Sub-clause 5(a): ivyO will provide individuals with the opportunity of remaining anonymous or using a pseudonym in their dealings with us where it is lawful and practicable (for example, when making a general enquiry).
Sub-clause 5(b): Without limiting sub-clause 5(a), it is not practicable for ivyO to deal with individuals anonymously or pseudonymously on an ongoing basis. If we do not collect personal information about you, you may be unable to use our services or participate in our events, programs, or activities we manage or deliver.
Clause 6 - Data Quality
Sub-clause 6(a): ivyO takes full responsibility to ensure that any personal information held by us is protected from misuse, loss and unauthorized modification or disclosure.
Sub-clause 6(b): To safeguard the privacy of personal information we collect from you, ivyO maintains numerous internal quality systems and safeguards. We hold personal information in a combination of secure electronic and hard copy formats. We restrict access to your personal data on a strict ‘need to know bases amongst our employees and affiliates, and train them to fully appreciate the importance of confidentiality and maintaining the privacy and security of your personal information. We commit to taking appropriate disciplinary measures to enforce our employees' privacy responsibilities.
Sub-clause 6(c): ivyO will keep information for as long as required to be able to provide our services or by law. We will take reasonable steps to permanently de-identify or securely destroy personal information no longer required, or upon request from you for any purpose except in limited permitted circumstances.
Clause 7 - Use and disclosure of your personal information
Sub-clause 7(a): ivyO may use or disclose your personal information for the purpose of informing you about our services, upcoming promotions and events, or other opportunities that may interest you. If you do not want to receive direct marketing communications, you can opt-out at any time by contacting us using the contact details below.
Sub-clause 7(b): If you opt-out of receiving marketing material from us, ivyO may still contact you in relation to its ongoing relationship with you.
Sub-clause 7(c): Without limiting the operation of clauses 7(a) and 7(b), we do not disclose or sell your personal information to third parties.
Clause 8 - Does ivyO disclose your personal information overseas?
Sub-clause 8(a): ivyO is a global organization and collaborates with clients, service providers, sponsors, and commercial interests across the globe. It is likely that your personal information will be disclosed to overseas recipients.
Sub-clause 8(b): Unless we have your consent, or an exception under data protection law applies, we will only disclose your personal information to overseas recipients where we have taken reasonable steps to ensure that the overseas recipient does not breach the APPs in relation to your personal information.
Sub-clause 8(c): Entities which are related entities of ivyO, or are otherwise affiliated with ivyO, have operations in Australia. In circumstances where your information is disclosed to overseas recipients, those recipients are likely to be located in countries in the regions in which ivyO and its related entities and affiliates operate.
Sub-clause 9(a): You are entitled to access your personal information held by ivyO on request. To request access to your personal information please contact our Privacy Officer using the contact details set out below.
Sub-clause 9(b): We will take reasonable steps to ensure that the personal information we collect, use, or disclose is accurate, complete, and up to date. You can help us to do this by letting us know if you notice errors or discrepancies in information, we hold about you and letting us know if your personal details change.
Sub-clause 9(c): However, if you consider any personal information, we hold about you is inaccurate, out-of-date, incomplete, irrelevant, or misleading you are entitled to request correction of the information. After receiving a request from you, we will take reasonable steps to correct your information.
Sub-clause 9(d): We may decline your request to access or correct your personal information in certain circumstances in accordance with the APPs. If we do refuse your request, we will provide you with a reason for our decision and, in the case of a request for correction, we will include a statement with your personal information about the requested correction.
Clause 10 - Data Subject Rights
Sub-clause 10(a): The European Union’s General Data Protection Regulation and other countries’ privacy laws provide certain rights for data subjects. For more information on these rights, consult the following website provided by the United Kingdom’s Information Commissioner’s Office: https://ico.org.uk/for-organisations/data-protection-reform/overview-of-the-gdpr/individuals-rights/the-right-to-be-informed/
Sub-clause 10(b): If you live in the EU, the following rights apply to you: You may also request information about the purpose of the processing, the categories of personal data concerned, who else outside IvyO might have received the data from IvyO, what the source of the information was (if you didn’t provide it directly to IvyO) and how long it will be stored; you have a right to correct (rectify) the record of your personal data maintained by IvyO if it is inaccurate; you may request that IvyO erase that data or cease processing it, subject to certain exceptions; you may also request that IvyO cease using your data for direct marketing purposes. In many countries, you have a right to lodge a complaint with the appropriate data protection authority if you have concerns about how IvyO processes your personal data; and when technically feasible, IvyO will—at your request—provide your personal data to you or transmit it directly to another controller.
Clause 11 - Complaints Process
Sub-clause 11(b): You may make a complaint about privacy to the Privacy Officer at the contact details set out below:
ivyO Privacy Officer
GPO Box 69, Sydney NSW 2001, Australia
The Privacy Officer will first consider your complaint to determine whether there are simple or immediate steps which can be taken to resolve the complaint. We will generally respond to your complaint within a week.
If your complaint requires more detailed consideration or investigation, we will acknowledge receipt of your complaint within a week and endeavor to complete our investigation into your complaint promptly. We may ask you to provide further information about your complaint and the outcome you are seeking. We will then typically gather relevant facts, locate, and review relevant documents and speak with individuals involved.
In most cases, we will investigate and respond to a complaint within 30 days of receipt of the complaint. If the matter is more complex or our investigation may take longer, we will let you know.
If you are not satisfied with our response to your complaint, or you consider that ivyO may have breached the APPs or the Privacy Act, a complaint may be made to the Office of the Australian Information Commissioner (OAIC). The OAIC can be contacted by telephone on 1300 363 992 or by using the contact details on the OAIC website.