Privacy Policy

Candlefox Group Pty Ltd ABN 50 661 807 709 trading as training.com.au

Candlefox Group Pty Ltd and its related entities (referred to as Candlefox, we or our) are committed to the protection of your Personal Information in accordance with the Australian Privacy Principles (APPs) as set out in the Privacy Act 1988 (Cth) (Privacy Act).

This Privacy Policy describes the manner in which Candlefox collects, holds and uses Personal Information that is covered by the Privacy Act. It is not intended to cover categories of Personal Information that are not covered by the Privacy Act.  If you wish to make any inquiries regarding this Privacy Policy, you should contact Candlefox in any of the ways specified in clause 14.

Candlefox may, from time to time, review and update this Privacy Policy including to take into account new laws, regulations and technology. All Personal Information held by Candlefox will be governed by our most recent Privacy Policy, posted on our website training.com.au (Website). Our most recent Privacy Policy will apply to our collection, use and disclosure of Personal Information.

1. What information is covered by the Privacy Act?

“Personal Information” is information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information is true or not, and whether recorded in a material form or not.“Sensitive Information” is Personal Information about an individual that includes health information, genetic information, biometric information or templates, or Personal Information that is also information or an opinion about an individual’s race or ethnicity, their religious, political or philosophical beliefs, opinions or affiliations, their sexual orientation or criminal record.

2. What information do we collect and hold?

Candlefox may collect and hold Personal Information about you such as your name, gender, date of birth, contact details (including your address, phone number and email address, whether personal or for work), level of education, financial information, billing or payment details, bank account details, tax file number, products and services information and preferences.Candlefox does not collect Sensitive Information and we will only collect such information with your consent if it is reasonably necessary for one or more of our functions or activities.

3. Why do we collect Personal Information?

1. Candlefox collects Personal Information from customers, employees, contractors and other individuals that is reasonably necessary for one or more of our functions or activities, including: in order to allow us to conduct our business functions, to meet any regulatory requirements which apply to our business, to market and sell our products and services and to conduct employee related activities.
2. You have the option to deal with us anonymously or by using a pseudonym. However you acknowledge that where this is impractical (for example when you contract with us) or where the law or a court order provides otherwise we are not required to provide these options to you. If you opt to deal with us anonymously or by using a pseudonym, we may not be able to provide you with requested information, products or services unless you provide us with a valid email address.
3. If you choose not to provide your Personal Information to Candlefox, or choose to deal with us anonymously or by using a pseudonym, we may not be able to undertake certain activities for you including providing you with requested information, products or services.

4. When and how do we collect Personal Information?

1. Candlefox collects Personal Information directly from you when you: visit our Website, use our online services or buy products from us, request information about us or our products or services, provide feedback, respond to a survey, change your content or email preferences, enter into an agreement or contract with us, fill in a form on our Website (including an enquiry form or a registration form to register as a user on our Website), fill in a form or request that we forward your information to a third party service or course provider, become an employee of Candlefox, or contact us by telephone, facsimile, email, post or in person.
2. Candlefox may also collect Personal Information about you via third parties including from our course providers, training providers, Registered Training Organisations (RTOs) and other third party service providers.
3. Candlefox may also collect de-identified Personal Information from third parties, including from our course providers, training providers and RTOs. De-identified information means that all personal identifiers such as a person’s name, contact details, date of birth or other characteristics that enable identification of an individual have been removed.
4. In some circumstances we may receive Personal Information that we have not requested. If this occurs, we will comply with our obligations under the Privacy Act. You acknowledge that we may de-identify and/or destroy this information unless we are required to keep it by law.

5. Information collected via our Website

1. Candlefox will not collect any Personal Information about users of our Website except when they knowingly provide it or as otherwise described below.  For example, Candlefox may collect Personal Information from users of the Website when they:
   1. complete an online form, including an enquiry form or registering to receive updates, promotional material or other information; and/or
   2. otherwise correspond with Candlefox.
2. Aggregate and Click Stream Data – When you visit and browse our Website, our Website host may collect Personal Information and non-personal information or data in aggregate form for statistical, reporting and maintenance purposes. Subject to clause 7.4, the Personal Information collected by our Website host will not be used to identify you.  The information may include:
   1. the number of users visiting our Website and the number of pages viewed;
   2. the date, time and duration of a visit;
   3. the IP address of your computer; or
   4. the path taken through our Website.
3. Candlefox’s Website host uses this information to administer and improve the performance of our Website, including to measure and analyse internet usage across our Website and to assist us with the diagnosis of and to provide support for any issues with our Website or services.
4. Cookies – Cookies are small text files that are transferred to a user’s computer hard drive by a website for the purpose of storing information about a user’s identity, browser type or website visiting patterns.
5. If you access our Website, a cookie is downloaded onto your computer’s hard drive when you first log on to our Website. You can adjust your internet browser to disable cookies, however Candlefox may not be able to provide you with all the service or functionality you require on our Website if you choose to do so.
   1. Web Beacons – Web beacons are images that originate from a third party site to track visitor activities. Candlefox may use web beacons to collect aggregate data and provides this information to our Website host to administer and improve the performance of our Website.
   2. Advertising –  We use Google and/or other third-party service providers to serve ads on our behalf across the Internet and sometimes on our Website. They may collect anonymous information about your visits to our Website (not including your name, address, email address or telephone number), and your interaction with our products and services. They may also use information about your visits to the Website and other websites to target advertisements for goods and services in order to provide more relevant advertisements about goods and services of interest to you.
   3. By using this website you accept that third party cookies may be placed on your web browser or similar technology may be used where cookies are not supported in order for us to serve related advertising in future

6. How Candlefox uses the Personal Information it collects about you

1. Candlefox uses the Personal Information it collects about you for our business functions and activities, which may include the following:
   1. to provide you with information, products or services you have requested, including providing you with information about options available, and where we engage with third parties to provide you with goods or services;
   2. to respond to your enquiries or to register you as a registered user of the Website;
   3. to promote and market our products and services to you, including to communicate with you via our email newsletters;
   4. to personalise and customise your experiences on our Website;
   5. to help Candlefox research the needs of its customers;
   6. to conduct research for the purposes of improving existing products or services or creating new products or services;
   7. to operate and improve our Website, including displaying personalised content and advertising;
   8. to provide you with ongoing information about Candlefox and its activities;
   9. to allow us to provide you with third party information and offers in which we believe you may be interested;
   10. to allow us to provide your Personal Information to third parties such as course providers, training providers or RTOs when you have consented to us doing so;
   11. to use de-identified information collected from RTOs for the purposes of data analysis, research and reporting;
   12. to comply with regulatory or other legal requirements;
   13. for purposes related to the employment of our personnel and providing internal services to our staff; and
   14. for any other use required or permitted by law or any other purpose communicated to you at the time that the Personal Information was collected or for which you provided your consent.
2. Candlefox may use your Personal Information for a secondary purpose if that secondary purpose is related to those purposes in clause 6.1, if we have your consent or if otherwise provided for under the Privacy Act.
3. Direct Marketing – Candlefox may use your Personal Information to provide you with direct marketing materials if you would reasonably expect us to or if you consent to receive direct marketing materials. We will seek your consent to provide you with direct marketing materials if we have obtained your Personal Information from a third party. Direct marketing material may include promotional material about Candlefox or the products or services offered by Candlefox.
4. You may opt out of receiving direct marketing material by contacting us in any of the ways specified in the direct marketing materials or as set out in clause 14.
5. Generally, we will only collect and use your Personal Information in accordance with this Privacy Policy. In the event that we collect or use Personal Information in ways other than as stated in this Privacy Policy, we will ensure that we do so in accordance with the Privacy Act.

7. Who do we disclose your Personal Information to?

1. Depending on the nature of your relationship with Candlefox, we may disclose your Personal Information to shareholders, officers and employees of Candlefox, other businesses within our group of companies, service providers who assist us in our business operations (including parties that we engage to provide you with goods or services on our behalf or who are connected with or involved in our relationship with you such as course providers, training providers or RTOs), parties involved in the purchase or sale of any of our businesses, other third parties, or otherwise as required by law.
2. When you submit an enquiry about a course on our Website you consent to Candlefox sharing your Personal Information with the third party institution that provides the course you enquired about. You consent to and understand that the third party institution may contact you directly in relation to that course.
3. Candlefox may also disclose your Personal Information to our Website host or service providers in certain limited circumstances, for example when our Website experiences a technical problem or to ensure that it operates in an effective and secure manner.  To the extent that we do share your Personal Information with a service provider, we would only do so if that party has agreed to comply with our privacy standards as described in this Privacy Policy.
4. We may also share non-personal, de-identified and aggregated information for research or promotional purposes or for the purpose of improving our services.
5. Unless otherwise specified in this Privacy Policy, Candlefox or Candlefox’s Website host will not disclose any of your Personal Information to any other organisation unless the disclosure is required by law, is otherwise permitted by the Privacy Act, or is with your consent.

8. Disclosure of your Personal Information overseas

Candlefox does not currently disclose Personal Information outside of Australia.

9. Employee Records

Employee records are not generally subject to the Privacy Act.  As such this Privacy Policy may not apply to the handling of employee related information. Please contact us directly for information about our employee information handling practices.

10. Storage and security of Personal Information held by Candlefox

1. Candlefox will take reasonable steps to protect your Personal Information from misuse, interference and loss and from unauthorised access, modification or disclosure.
2. Candlefox aims to keep your Personal Information secure and up to date.  We will comply with our obligations under the Privacy Act in relation to any Personal Information that we handle, including information which is held on Candlefox’s computer systems.
3. Personal Information that is held by Candlefox in hard copy is stored securely on its premises and is only disclosed or used for the purposes described in this Privacy Policy.

11. Updating and correcting your Personal Information

We will take reasonable steps to ensure that the Personal Information that we hold is accurate, up-to-date and complete.  You can update your Personal Information at any time by contacting Candlefox in any of the ways specified in clause 14or if you are a registered Candlefox user by logging in and updating your profile.  Candlefox welcomes any changes to your Personal Information so as to keep our records up to date.

12. How long will Candlefox keep your Personal Information?

1. We will keep your Personal Information only for as long as required for our business purposes and otherwise as required by Australian law.
2. Where we no longer need to keep your Personal Information in accordance with clause 12.1, we will take reasonable steps to destroy or de-identify your Personal Information.
3. If you wish to have your Personal Information destroyed or de-identified, please let us know and we will take reasonable steps to do so (unless we need to keep it for legal, auditing or internal risk management reasons, or as otherwise required by law).

13. Finding out what Personal Information Candlefox holds about you

1. You are entitled to access Personal Information that Candlefox holds about you.  If you request access to your Personal Information, we will grant your request unless providing you with access would unreasonably impact upon the privacy of others or is not otherwise permitted under the Australian Privacy Principles or at law.  If we refuse your request to access your Personal Information, we will provide you with written reasons for the refusal.
2. A request for access can be made by contacting Candlefox in any of the ways specified in clause 14.

14. How to contact us and more information

1. If you feel that your privacy has not been respected or that Candlefox has conducted itself inconsistently with this Privacy Policy, the Australian Privacy Principles, a registered APP Code and/or the Privacy Act in respect of your Personal Information, or for any other queries, problems, complaints or communication in relation to this Privacy Policy, please contact us in any of the following ways:

   Email: privacy@candlefox.com

   Write To:
   Att: Privacy Officer
   Candlefox Pty Ltd, 127 Erskine Street, Middle Park, Victoria 3206 Australia

2. You can find out more information about the Privacy Act and the Australian Privacy Principles from the Office of the Australian Information Commissioner. The Information Commissioner may be contacted at www.oaic.gov.au (email – enquiries@oaic.gov.au).

Last updated: July 2017