Effective Date: May 25, 2018
Please note that Nelnet International P/L (“Nelnet International”, “The Company”, “we”, “our”, or “us”) offers Services related to education, including tuition management, payment administration and processing, school management, online application, and online enrolments. To provide these Services, we must store and maintain information about educational institutions (or other entities) we serve, along with personal information regarding administrators, staff members, parents, and students. Access to the data will be restricted to authorised associates and will be used only for the purpose of providing Services to you or the Institution. The Company is committed to protecting personal information and an individual’s right to privacy. The Company collects, retains, uses and discloses certain personal information about individuals in the ordinary course of business, in accordance with the Australian Privacy Principles (APPs) as outlined in the Privacy Act 1988 (the “Act”).
This Policy details how the Company generally collects, retains, uses and discloses personal information and an individual’s rights in relation to that personal information.
The personal information the Company may collect will depend on the circumstances of collection, including whether the Company collects the information from the person as a customer, supplier, contractor, job applicant or other contact. The type of personal information which the Company collects about an individual depends on the individual’s dealings with the Company.
What personal information is collected and how it is collected?
- The Company:
- collects and holds the following categories of information from customers as appropriate to its dealings with them: name, address, e-mail address, recipient’s name, order information, telephone number, banking details, and credit card information;
- collects and holds the following kinds of personal information about contractors, service providers and suppliers: name, job title, business contact details of company representatives with whom the Company deals, financial information and banking details;
- in the context of the Company’s recruitment process for employees and contractors, collects and holds the following kinds of personal information: name, email address, telephone number, address, financial details (including banking details), date of birth, history with the Company (including communications between the Company and the individual), citizenship, employment references, civil, credit and criminal records, driver’s licence information, education, employment history, marital status, membership of a professional or trade association, membership of a trade union and health information
In most cases, the Company collects personal information about an individual directly from the individual, through online methods, telephone, or via other contact methods such as by telephone, facsimile, email and mail, or when the individual completes forms, transacts or requests further information through our website or mobile device application. Face-to-face meetings may take place as part of the employment process. The Company may also collect personal information about you from the following third parties: government agencies, publicly available records, service providers, parties to whom the individual refers us or from whom the individual authorises collection, online searches and social media.
Use and disclosure
- The Company collects, holds, uses and discloses an individual’s personal information for the following purposes:
- to provide products and services to you;
- to maintain, manage and develop our relationship with you;
- to respond to any of your questions or comments;
- to assess and consider applications from prospective job applicants, contractors and service providers;
- such purposes for which the Company may obtain consent from time to time; and
- to comply with the Company’s legal and regulatory obligations
The Company may disclose personal information to its related entities located in the United States of America.
- We may collect Non-public Personal Information about you from the following sources:
- Information from this Website or paper forms
- Information about your transactions with us or others
- Information we receive from third parties, such as your academic institution
“Non-public Personal Information” is non-public, personally identifiable financial information about you that we obtain in connection with providing a financial product or service to you. For example, Non-public Personal Information includes information regarding your account balance, payment history, and overdraft history, if applicable.
- We may collect Personally Identifiable Information about you as well, including:
- Your first and last name
- Your home address
- Your home or work telephone number
- Your financial account or credit card information
- Your email address
“Personally Identifiable Information” is individually identifiable information about an individual consumer collected by us and maintained in an accessible form.
Uses of Information
Certain Non-Identifying Information would be considered a part of your Personally Identifiable Information if it were combined with other identifiers (for example, combining your zip code with your street address) in a way that enables you to be identified. But the same pieces of information are considered Non-Identifying Information when they are taken alone or combined only with other non-identifying information (for example, your viewing preferences). We may combine your Personally Identifiable Information with Non-Identifying Information and aggregate it with information collected from other Users to attempt to provide you with a better experience, to improve the quality and value of the Services and to analyse and understand how our Website and Services are used. We may also use the combined information without aggregating it to serve you specifically, for instance, to deliver a product to you according to your preferences or restrictions.
If you supply us with your e-mail address, we may let you know by e-mail about other products and services and product enhancements that may be of interest to you. You will have the opportunity to tell us you do not want to receive future messages with each message you receive. If you e-mail a question or comment to us, we will use your e-mail address to reply to you, and we will temporarily store your e-mail address, your message, and our reply for quality assurance or to satisfy applicable laws and regulations. When we collect your e-mail address this way, we will not use it for marketing our products and services unless you have given us permission. If you wish to change any of your personal information, you may change it by logging into your account; by contacting Customer Service, either through email, mail, or telephone; or by contacting your Educational Institution.
What We Share
We may share your information with companies that are affiliated with us, such as our direct or indirect subsidiaries or parent or sister companies. As we continue to develop our business, we may buy or sell companies, subsidiaries, or business units. Your Personally Identifiable Information may be included as an asset in connection with mergers, acquisitions, reorganisations, or sales of assets including in the event of bankruptcy.
Sometimes the law or other circumstances also require that we disclose Non-public Personal Information and/or Personally Identifiable Information about you to non-affiliated third parties. Some examples are: when you ask or permit us to do so; in response to subpoenas or court orders; when we suspect fraud or criminal activity; to protect our property and rights or those of a third party; to protect the safety of the public or any person; or to prevent or stop activity we may consider to be, or to pose a risk of being, illegal, unethical, or legally actionable activity.
Security regarding information you provide us:
Personal information collected by the Company may be held in hard copy or digital or another format. Electronic documentation is stored within a secure network. Hard copies are stored in secure locations within an access-controlled premises. The Company will keep the personal information that it collects either at its offices in Australia or at the offices of a related entity of the Company or a service provider in the United States of America. Any personal information that is stored or used in the United States of America is subject to the laws of the United States of America, and pursuant to such laws, may be subject to disclosure to the governments, courts or law enforcement or regulatory agencies of the United States of America. Access to personal information shall be restricted to authorised associates. The company maintains physical, procedural, and electronic safeguards to protect data from being accessed by unauthorised third parties.
We are committed to providing you with a useful and enjoyable online experience. We implement reasonable and appropriate physical, procedural, and electronic safeguards to protect your information.
To access information and send e-mail via the Website, you will need a browser that supports the use of Transport Layer Security protocols. This encryption technology helps ensure the authenticity of your online sessions and secures data being transmitted over the public Internet.
We take careful steps to safeguard customer information. We restrict access to your personal and account information to those employees who need to know that information to provide Services to you, and we regularly train our employees on privacy, information security, and their obligation to protect your information. We maintain reasonable and appropriate physical, electronic, and procedural safeguards to guard your Non-public Personal Information and Personally Identifiable Information and we regularly test those safeguards to maintain the appropriate levels of protection.
You can help safeguard your Non-public Personal Information and Personally Identifiable Information by taking a few simple precautions. Protect your account numbers, passwords, and customer access numbers. Never disclose confidential information to unknown callers. You should always use a secure browser and current virus detection software, and never open email from unknown sources.
We are committed to providing you with a useful and enjoyable online experience. This Policy explains our collection and use practices regarding consumer information, including how and what we share with our related companies and with unrelated entities. Protecting your privacy is important to Nelnet International and our employees. We want you to understand what information we collect and how we use it. This Policy is subject to change from time to time, so be sure to check back occasionally to ensure you have read the most current version. It is effective as of the date listed above and applies to our Services that link to this policy. Even if you read and/or agreed to a prior privacy statement, you need to review this updated version. We reserve the right at any time, and in our sole discretion, to change or modify this Policy. If any such changes or modifications are made, we will update the “Effective Date” appearing at the top of this web page. Such changes or modifications shall be effective immediately upon posting to the Website and supersede any prior versions of this Policy.
This Policy governs the privacy policies of this Website or the Nelnet International mobile device application(s) only.
Information we collect
Why We Collect Information We collect information so we can identify you as our customer, to establish, manage and protect your accounts, to complete your transactions, to create and offer you products and services you might be interested in, to personalise and improve upon your experience with us and to comply with various legal and regulatory requirements. Non-Identifying Information
We may collect information from your visit or as part of the registration and administration of your account, in order to personalise and improve upon your experience with us, such as, without limitation, age and individual preferences (“Non-Identifying Information”).
The Services may place “Cookies” on a visitor’s device. Cookies are small text files. Our Cookies save anonymised data about individual visitors, allowing our Services to recognise information about a visitor and help deliver personalised content and other services and functions. Cookies make your Internet experience quicker and more convenient. The Services use both session cookies, which terminate when a user closes his or her browser, and persistent cookies, which remain on the user’s device until they expire or are manually deleted. The Services also contain coding from our business and technology partners which generates third-party cookies. Third party cookies allow our business and technology partners to store non-Identifying Information they can access when you visit this or other websites. Accepting a cookie from a web or device browser does not give us access to any Personally Identifiable Information. Most website and mobile device browsers allow you to control cookies, including whether to accept them and provide the ability to remove them. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser. Blocking cookies may result in a lower quality experience for you while you are using our Services.
Device and Connection Information
When you use our Services, we will identify the Internet Protocol (IP) address of your computer or handheld device. The IP address does not identify you personally, but it lets us identify the device you are using. We store IP addresses in case we need to track a connection for security purposes. We may also collect other device-specific information about the device you are using, including what type of device it is and hardware model, what operating system you are using, device settings, unique device identifies, geo-location data, and crash data. Whether we collect some or all of this information often depends on what type of device you are using and its settings. Check the policies of your device manufacturer or software provider to learn more about what information your device makes available to us.
Web Beacons (1×1 Pixels or GIFS)
Our Services may contain coding known as Web Beacons that use 1×1 pixel images to capture and transmit the online activity of users on our Services. These Web Beacons typically transmit information about form completions and other activities in order to measure advertising effectiveness or store analytics information. In addition, we may use Web Beacons in HTML-based emails. This allows us to evaluate the effectiveness of our email communications and our marketing campaigns by showing how many emails recipients have opened.
Like most websites, our servers utilise log files. Log files store information including internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, platform type, date/time stamp, and number of clicks. Log files are used to analyse trends, administer the Website, track Users’ movement in the aggregate, and gather broad demographic information for aggregate use. We use log file information at times to help identify you as you browse and to gather broad technical and demographic information on who uses our website.
Google Analytics Feature
Do Not Track Signals
Do Not Track is a feature in your web browser, which enables you to opt-out of the third-party tracking of your online activities over time and across third party websites. We do not track users across third party websites to provide targeted advertising, and therefore, do not process or comply with any web browser’s “do not track” signal or other similar mechanism that indicates a request to disable online tracking of individual users who visit this Website or use our Services. Third parties cannot collect any Personally Identifiable Information from this Website unless you provide it to them directly.
The Website is not directed to children under 13. We do not knowingly collect, maintain, or use personally identifiable information from children under age 13. If a parent or guardian becomes aware that his or her child has provided us Personally Identifiable Information without their consent, he or she should contact us using the information in the “How to Contact Us” section, below. If we confirm collected such information, we will take all reasonable measures to delete that information from our system as soon as possible. For users of our learning management system and related products, we may collect and store certain information as required to provide learning management tools to schools, teachers, and students who use such tools.
Links to Other Websites and Services
We are not responsible for the collection and use of information by companies or individuals unaffiliated with us whose websites may contain links to the Website, including vendors where you may shop. Please remember that when you use a link to go from our Website to another website, our Policy does not apply to third party websites or services. Your browsing and interaction on any third-party website or service are subject to that third party’s own rules and policies. Please note that when you shop with a vendor who is linked to the Website, even though you may have started your visit with us, and even though our pages may still appear, your transactions are completed with a separate organisation, not with us. In addition, you agree that we are not responsible, and we do not have control over any third parties that you authorise to access your user content. If you are using a third-party website or service, and you allow such a third party access to your user content, you do so at your own risk. This Policy does not apply to information we collect by other means (including offline) or from other sources other than through the Website and applications.
How to Contact Us
If you have any questions about this Policy, please contact us at one of the following address:
Nelnet International Pty Ltd
Suite 13-15, Level 1
2 Brandon Park Drive, Wheelers Hill
Victoria, 3150, Australia
Telephone: +61 1300 635638
If you have any questions regarding this document, or if you have a complaint regarding the Company’s handling of your personal information, please contact the Company at the details above. The Company will respond to complaints within a reasonable period of time. If you disagree with the Company’s decision, you may refer the complaint to the Office of the Australian Information Commissioner by visiting www.oaic.gov.au, calling 1300 363 992 or by emailing email@example.com.
Subject to any exceptions in the Act, where the Company holds personal information about you in such a way that it can readily be retrieved, you have a right to request confirmation of whether or not the Company holds your personal information and to have access to it. Within a reasonable period after receiving your request, the Company will take reasonable steps to provide you with access, if it is reasonable and practicable to do so. If you wish to request access to or update your personal information, please contact the Company on the details provided above.
The Company takes reasonable steps to keep your personal information as accurate, complete and up to date as possible. You may assist the Company by notifying the Company if your circumstances change. You may request that we correct personal information we hold about you that is inaccurate or out of date. We will take reasonable steps to rectify the situation free of charge if we are satisfied that the information is inaccurate, out of date, incomplete, irrelevant or misleading. If we refuse to correct your personal information, we will give you written notice setting out our reasons for the refusal and the mechanisms available to complain about the refusal.
PRIVACY NOTICE FOR EUROPEAN UNION RESIDENTS:
Striving to provide superior customer service, Nelnet International P/L, (“Nelnet International”, “we”, “our”, or “us”) places great emphasis on its customers and their privacy rights. In doing so, Nelnet International will comply with European Union Privacy Directives, most notably the EU General Data Protection Regulation. By providing our services, we may from time to time collect, store, use or process your personal data for legitimate business purposes, such as improving our products and services. Nelnet International’s processing of your data is necessary for compliance with its contractual and legal obligations. Personal data means any identifier information, such as your name, social security number, identification number, location data, or other online identifiers and factors.
Although your data is generally stored within Australia, an international data transfer may occur if third-party, cloud-based storage companies that Nelnet International employs use servers located outside Australia. Nelnet International uses appropriate technical and organisational security measures including encryption of personal data and follows various industry standards and best practices to protect your personal data. Additionally, Nelnet International requires its vendors and processors to abide by the European Union General Data Protection Regulation and to apply adequate security and technical safeguards. We will not transfer your data to or store your data in countries that have not been awarded an adequacy decision by the European Commission.
For general processing purposes, Nelnet International will store your personal data for a period of seven years. However, Nelnet International may retain such information for shorter or longer periods where legally required to do so based on industry rules, contractual requirements, or other legal obligations.
You have the right to withdraw consent for processing at any time. Further, you have the right to request access to and rectification, restriction or erasure of your personal data. Nelnet International will afford you these rights, but it may not be able to do so where the processing is based on its contractual obligations, based on other legitimate interests, or carried out in the public interest. Along with these rights, if you believe that your data has been mishandled in violation of a privacy directive, you have the right to lodge a complaint with the relevant supervisory authority. If you have questions or concerns about our data processing practices, please address such inquiries to our Data Protection Officer.
Contact Details for Privacy and Data-related Inquiries
Contact Your Educational Institution or Merchant
Chief Compliance Officer
Nelnet International Pty Ltd
Phone: +61 1300 635 638