This policy addresses the following:
- what information we collect;
- if you are minor (aged under 18 years);
- how we collect it;
- why we collect it;
- how we use it;
- how we disclose it;
- opting in and out;
- how we hold it - management and security; and
- accessing and updating or correcting your information and how to contact us.
What information we collect
The personal information we collect about you includes (but is not limited to) your name, contact details (including phone numbers and addresses), gender, date of birth, occupation and other information which may assist us in conducting our business, and providing and marketing our products and services. In certain circumstances we collect financial information, including your credit card information where appropriate.
We (for example, through our Pearson Clinical and Talent Assessment division) may also collect sensitive information from you (such as health information about you) only if you consent to our collection of such information and the information is reasonably necessary for one or more of our functions or activities (or we are otherwise permitted or required by law to do so), including:
- where such information is relevant to any research project conducted by us, in which you participate or wish to participate.
- where such information is required in order for us to be able to provide our goods or services to you (including psychological testing materials or services to assess intelligence, memory, neurocognitive functioning, academic achievement, work aptitude and personality, learning and developmental delay, or speech and motor disabilities).
We also collect information about you that is not personal information. For example, we may collect data relating to your activity on our websites (including the type of internet browser you use, your operating system, address of referring site, your IP address and other clickstream information) via tracking technologies such as cookies, or we may collect information from you in response to a survey, promotion or competition. We may use Google Analytic tools from time to time including Remarketing, Google Display Network Impression Reporting, the DoubleClick Campaign Manager integration, or Google Analytics Demographics and Interest Reporting. We generally use this information to report statistics, analyse trends, administer our services, diagnose problems, advertise online, optimize our advertising and websites and target and improve the quality of our products and services.
Cookies allow your browser to utilise some of the features of our websites. We use both session ID cookies and persistent cookies, first party cookies (such as Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to inform, optimize, and serve ads based on someone's past visits to our website, to report how our ad impressions, other uses of ad services, and interactions with these ad impressions and ad services are related to visits to our site. Third-party vendors, including Google, may show our ads on sites across the Internet. Most web browsers are set by default to accept cookies. If you reject cookies you will be unable to take advantage of some of the features of our websites. To the extent this information does not constitute personal information, the Privacy Act is not applicable and we may use this information for any lawful purpose.
We generally advise that you do not publish or communicate personal information, or at least limit the personal information that you publish or communicate, to the public via our services, such as in any forums, blogs or anywhere that user generated content can be uploaded ("Non-Confidential Information"). We cannot control any third party collection or use of your Non-Confidential Information that is publicly available.
If you are a minor (aged under 18 years)
We provide subscription services to, and may conduct research projects (for example through our Pearson Clinical and Talent Assessment division) involving, children and young adults who are legally minors and may not be able to provide valid consent to our collection, use, disclosure, storage or other handling of their personal information. From time to time we may also conduct competitions and provide other services for children/minors who may or may not be subscribers to our online services or newsletters.
Parents and guardians of children/minors are personally responsible for monitoring their child's/minor's access to, and use of, our services and for providing valid approvals for their child's/minor's participation in subscription, research projects, competition and other promotional activities conducted by us.
If you are a child or young adult under the age of 18 years, you must ask your parent or legal guardian to approve your provision of personal information before you submit your personal details to us.
How we collect it
We may collect your personal information from a variety of sources, including from you, advertisers, mailing lists, recruitment agencies, contractors and business partners.
We will generally collect personal information by way of forms filled out by people, face-to-face meetings, interviews, business cards, electronic communications, telephone conversations and from third parties (including representatives, agents and credit reporting agencies). In addition, we collect personal information from our websites through receiving subscription applications, job applications, applications to participate in our research projects, competition applications and other electronic documents.
We may collect your personal information when you request, acquire or use a product or service from us, register with us as a subscriber, member or user, provide a product or service to us, complete a survey, consent form or questionnaire, complete assessment materials as part of our research projects in which you participate, enter a competition or event, contribute in a fundraising event, participate in our services (including blogs and forums) or our research projects or when you communicate with us electronically (including email and facsimile), by telephone or in writing (for example if you make a complaint or provide feedback) or where you provide personal information via social media (such as via Facebook , Twitter, Instagram, Pinterest and Tumblr).
If, at any time, you provide personal or other information about someone other than yourself, you must have that person's consent to provide such information for the purpose for which you provide it to us.
Why we collect it
The primary purpose for which we collect information about you is to conduct our business, provide and market our products and services to you, meet our legal or regulatory obligations, and also for the management of business transactions entered into with us and the administration of any accounts you have with us, and for the purposes of our research projects in which you participate or wish to participate (including data analysis purposes under our research projects and assessment of your eligibility to participate in our research projects). We may state a more specific purpose at the point we collect your information (including but not limited to any law that requires or authorises the particular information to be collected).
If you do not provide us with all or some of the information that we request, we may not be able to provide you with our products or services or include you as a participant in our research projects. For example, if you do not register as a member of a website, you will not be able to access features or services that are reserved for members or subscribers only.
How we use it
In addition to the primary purpose outlined above, we may use the personal information we collect, and you consent to us using your personal information:
- to provide you with news and information about our products and services, and opportunities that we believe you may be interested in;
- for purposes necessary or incidental to the provision of products or services to you;
- to personalise and customise your experience purchasing or using our products or services;
- to manage and enhance our products and services;
- to communicate with you, including by email, mail, telephone or via social media;
- to conduct competitions or promotions;
- to verify your identity;
- to investigate any complaints about or made by you, or if we have reason to suspect that you are in breach of any of our terms and conditions or that you are or have been otherwise engaged in any unlawful activity;
- as part of any investigation in relation to you or your activity which we suspect to be a breach of any of our terms and conditions, serious misconduct or unlawful;
- as part of a sale (or proposed sale) of all or part of our business; and/or
- as required or permitted by any law or regulation (including without limitation the Privacy Act).
How we disclose it
We may disclose personal information, and you consent to us disclosing your personal information, to other members of the Pearson Group located in other countries including the United States of America, Canada, the United Kingdom, Singapore, Hong Kong, the Ukraine and China.
We may also disclose personal information, and you consent to us disclosing your personal information, to third parties:
- engaged by us to perform functions or provide products and services on our behalf, such as processing of credit card information, mailouts, debt collection, marketing, research, advertising and hosting of customer relationship management (CRM) systems. Such third parties include Rocket Science Group LLC (including MailChimp), SurveyMonkey Inc (including Wufoo) and Salesforce;
- engaged by us as contractors (for example, assessment administrators or examiners, or project managers) to assist with our research projects in which you participate or wish to participate;
- that are our agents, business partners or joint venture entities or partners;
- that sponsor or promote any competition that we conduct or promote via our services;
- authorised by you to receive information held by us;
- as part of any investigation in relation to you or your activity which we suspect to be a breach of any of our terms and conditions, serious misconduct or unlawful (including disclosure to the police, any relevant authority or enforcement body, or your Internet Service Provider or network administrator);
- that are our external advisers or potential or actual bidders or their external advisers as part of a sale (or proposed sale) of all or part of our business; and/or
- as required or permitted by any law or regulation (including the Privacy Act).
Some of these third parties to which we may disclose your personal information may be located in other countries including United States of America, Canada, the United Kingdom, Singapore, Hong Kong, the Ukraine, China and Luxembourg.
We hereby expressly inform you that if you consent to the disclosure of personal information about you by us to a third party who is not in Australia or an external Territory, subclause 8.1 of the Privacy Act 1988 (Cth) will not apply to the disclosure. After being so informed, you hereby consent to the disclosure.
Opting in or out
You will be given the opportunity to "opt out" from receiving communications from us or from third parties that send communications to you in accordance with the Privacy Act and other applicable privacy laws. For example, you will be given the option to unsubscribe to emails or newsletters sent by us.
You may also opt-out of Google Analytics and customise your Google Display Network ads by using the Ads Settings. You can also access Google Analytics' currently available opt-outs for the web.
How we hold it - management and security
Other than in relation to Non-Confidential Information, we will take all reasonable steps to protect the personal information that we hold from misuse, interference and loss, and from unauthorised access, modification or disclosure including by means of secure premises, locked cabinets, firewalls, password access, secure servers and encryption of credit card transactions.
However, you acknowledge that the security of online transactions and the security of communications sent by electronic means or by post cannot be guaranteed. You provide information to us via the internet or by post at your own risk. We cannot accept responsibility for misuse, interference or loss, or unauthorised access, modification or disclosure in respect of your personal information where the security of the information is not within our control.
If you suspect any misuse, interference or loss, or unauthorised access, modification or disclosure in respect of your personal information, or any other privacy breach please let us know immediately.
Accessing and updating or correcting your information and how to submit a complaint
Subject to the exceptions set out in the Privacy Act and other applicable privacy laws, you may request to access, update or correct the personal information we hold about you. We will require you to verify your identity and to specify the information that you wish to access, update or correct. A fee may be charged for providing access however we will advise you of the likely cost in advance.
Subscribers or members of our websites will generally be able to access, update and correct their membership and contact details online.
We request that you keep your information as current as possible so that we may continue to improve our service to you.
If you wish to access, update or correct any personal information that we hold about you, or if you have any questions or would like to submit a complaint about how we collect, use, disclose, store or otherwise handle your personal information, you can contact the department that collected your personal information in the first instance, or write to our Privacy Officer at the contact details below. We will acknowledge your complaint promptly and use best endeavours to work with you to resolve your complaint.
The Privacy Officer
Pearson Australia Group Pty Ltd
707 Collins Street
Melbourne VIC 3008