Last Updated [18 December 2017]
1. WHO DO WE COLLECT PERSONAL INFORMATION FROM?
We collect personal information from Clients who contract with us to provide QS Enrolment Solutions services (including, without limitation, when they access the System to review the information they have provided to us and the services we are completing on their behalf, and when we distribute our online surveys to them). We also collect personal information from Client employees who are authorised to access or use the System (each an “authorised user“), and Client Students who have provided the relevant Client with lawful and required consents to share their information with us for the purpose of us providing the services.
2. WHAT TYPES OF PERSONAL INFORMATION DO WE COLLECT AND HOW DO WE COLLECT IT?
When Clients agree to use our System, they provide us with information necessary to create their institution account and manage Student enquiries using QS Enrolment Solutions’ services. This includes the institution name, and the first name, surname and email address of each individual who the Client authorises as a user of the System.
Clients also provide information about their Students, which at a minimum includes the name, email address or phone number, nationality, country of residence, level of study and area of study of each Student. Clients use the System as their marketing record and retention system, and may choose, at their discretion, to provide us with additional information about their Students to store in the System.
Clients are contractually obligated to comply with the Privacy Act which includes obtaining all lawful and necessary permissions for all information provided to us for the purpose contemplated in those contracts, including, but not limited to, lawful permissions to market to their Students in the manner contemplated by the contract and agreed to by the Client as part of us providing the services.
Students may also provide us with information directly which we collect when they call a Client’s dedicated phone number to make enquiries and express interest in a Client. Such phone calls are managed by QS Enrolment Solutions. During the course of those phone calls, we collect information that a Student provides as is reasonably necessary to facilitate the Student’s request, such as to add them to the Client’s mailing list, respond to questions regarding the Client’s academic programs, or similar uses.
Information collected via online surveys
We send invitations to participate in our online surveys to those Students whose names and contact information have been provided to us by our Clients, as well as to application agents and Client users. If you have received an email invitation to participate in an online survey, this means that you or one or more of our Clients has indicated to us that you have opted in to receive such email invitations. Should you wish to opt out of such emails, you may do so by clicking on the “unsubscribe” link that appears at the bottom of each email invitation.
You are not required to provide additional personal information in order to participate in a survey, although you may do so at your discretion.
The survey you receive may invite you to participate in a random drawing for a chance to win select prizing. Each such drawing is subject to specific rules, which are made available for you to review prior to entry. Should you choose to participate in a random drawing, you will be required to provide your full name and email address so that we may contact you in the event that you have been awarded a prize. This information will not be combined with your survey results, and we will not use this information for any purpose except to notify you in the event that you have won a prize.
By participating in a survey, you may also opt-in to receive future surveys from us. Should you choose to do so, we may send you emails in the future inviting you to participate in additional surveys. You may opt-out of such participation by clicking on the “unsubscribe” link that appears at the bottom of each email invitation.
Information received from third parties
We collect personal information in the manner set out above. If we receive personal information about you from someone else other than as described above, we will take reasonable steps to ensure you are aware that we have collected such information and the circumstances of the collection. Where we receive information about you from a Client, such reasonable steps involve us obliging the Client to take steps to notify you that such information has been provided to us, where such notice is required by Privacy Laws.
3. WHY DO WE COLLECT PERSONAL INFORMATION?
The information we collect is stored in the System, and is used to provide our services which include:
• enabling you or the Client with whom you are associated to access and use the System;
• delivering customer services, and marketing services, including online surveys to Students as authorised by our Clients and individual users who have opted in to receive such surveys;
• awarding Students with prizing, where applicable, if a Student has chosen to participate in a random drawing and is selected as the winner;
• operating, supplying, maintaining and improving our services and the System;
• ensuring compliance with our contractual and other legal obligations to Clients; and
• otherwise administering our relationship with you, Clients and Students including by responding to enquiries,
Information that is provided by Clients or their authorised users and held in the System may also be accessed and used by Clients for their own purposes (as determined by the Client), which may include internal review, analysis and reporting of progress and success of marketing campaigns. Such information may include Student ages, visa status, location and data reflecting the individual’s engagement with marketing communications.
If you are an authorised user of a Client and you do not allow us to collect the information described above or stored in the System, we may not be able to fulfill our Main Purposes or supply the services (including access to and use of the System) to you or the Client with whom you are associated.
4. HOW DO WE USE OR DISCLOSE PERSONAL INFORMATION?
We use and disclose your personal information only in compliance with applicable Privacy Laws and our agreements with the Client with whom you are associated, and only for one of the Main Purposes or for a related purpose, unless you have consented to a different use or that is otherwise allowed by the Privacy Laws.
We do not use personal information collected through the System for commercial purposes that are not part of the QS Enrolment Solutions marketing purposes delivered on behalf of our Clients. In addition, we do not disclose, distribute, access or reference any personal information except as noted at the time that we collect the information or in the following circumstances:
• when directed or as agreed by the Client that provided (or whose authorised user provided) the information to us (“relevant Client“);
• if we believe it is necessary to provide the relevant Client or its authorised users with access to or use of the System;
• to our third party service partners to permit them to provide features and services on our behalf and as requested by the relevant Client (see Third Party Services section);
• to resolve a problem or support issue on behalf of the relevant Client;
• to protect the rights, property or personal safety of any Client or Client’s authorised user, a Student, any member of the public, or to protect our interests;
• as may be required by law or as ordered by a court, in which event we shall notify the relevant Client and shall work with them to seek to limit the scope of the required disclosure; and
We may use or disclose information that is not personal information, including aggregated, de-identified data, for a variety of purposes subject to applicable law, including:
• to share results with the applicable Client and to inform creation of future marketing campaigns for the applicable Client;
• to develop and improve our products and for customizing the product experience for each user; and
• to demonstrate the effectiveness of QS Enrolment Solutions, including in our marketing materials, industry and Client reports.
We will, if practicable, allow you to use a pseudonym or to not identify yourself (unless this is impractical or against the law). In many instances, if you do not provide us with certain personal information we may not be able to provide you (including a Client) with the relevant product, service or information.
5. USAGE INFORMATION AND TRACKING TECHNOLOGIES
When a Client or any of its authorised users use the System, our servers automatically collects the Internet Protocol (“IP“) address associated with the user’s computer. We may also collect additional information such as the login timestamp, the user’s browser type and version, and the operating system of the user’s computer. This information is logged to help us to diagnose technical problems and to administer the System.
We and our third party partners operating QS Enrolment Solutions services on our behalf, also use pixel tags (also known as “clear GIFs” or “web beacons”.) A pixel tag is a tiny image, typically just one pixel – that can be placed on a Web page or in an email to tell us when you have displayed that page or opened that email.
By using the System, you agree to the use of these tracking technologies.
6. THIRD PARTY SERVICE PROVIDERS
We use third party service providers to facilitate delivery of the QS Enrolment Solutions services and the System on our behalf, and may share personal information with those parties as is reasonably necessary for delivery of those services.
7. HOW YOU MAY ACCESS OR MODIFY YOUR INFORMATION
Clients and their authorized users may update or change their institution or Student information by contacting us at firstname.lastname@example.org. For your protection, we may require you to confirm your identity before access to your personal information is granted. In most cases, we can provide you with a summary of your personal information free of charge. However, in some circumstances, reasonable costs may be charged to you in accessing your personal information, subject always to the Australian Privacy Principles.
Students may opt-out of receipt of emails, or other commercial messages delivered by us on behalf of our Clients by clicking on the “unsubscribe” button that appears on the bottom of each email. Students may also contact the Client whose information they have received to request further access to, modification of, or deletion of their information provided to us by the Client.
Should you require assistance from us in accessing, modifying or otherwise controlling your personal information that is hosted by QS Enrolment Solutions, please contact us at email@example.com.
We are committed to protecting the security, integrity and confidentiality of the data we hold through the use of physical and technical safeguards. We use SSL (this is a standard security technology for establishing an encrypted link between a web server and a browser) and server authentication technology to protect data when the System is accessed using a supported web browser.
We host the data that we collect in secure server environments that use a firewall and other industry-standard technology in an effort to prevent interference or access from outside intruders. The Internet, however, is not perfectly secure and we are not responsible for security breaches not reasonably within our control.
9. DATA RETENTION
We retain information gathered through the online surveys and from managing customer service enquiries at the sole discretion of our Clients, and in accordance with our contractual obligations with those Clients. We delete personal information collected from a Client and their associated individuals when the Client’s agreement with us terminates and the relevant Client has complied with all of its obligations as a consequence of termination, other than as required by law. We may retain de-identified information for the purposes described in section 4 above.
10. DISCLOSURE OF INFORMATION TO OUTSIDE JURISDICTION OF COLLECTION
Information we collect or receive via our online surveys is stored in the EU, but may be processed in the UK, Australia and Malaysia. All other information we collect or receive may be temporarily stored and processed in UK, Malaysia or Australia. By providing us with your information, you consent to your information being used, stored and disclosed overseas (and acknowledge that no additional obligations that may apply to the overseas disclosure of personal information under Australian Privacy Laws will apply). You also acknowledge that the privacy laws of those countries in which we disclose information may not provide the same level of protection as the privacy laws of the country from which the personal information was collected. However, this does not change our commitments to safeguard your privacy and we will comply with all applicable laws relating to the cross-border data disclosure.
11. UPDATES TO THIS POLICY
In most cases we will ask that you put your request in writing to us. We will investigate your complaint and will use reasonable endeavors to respond to you in writing within a reasonable period after receiving the written complaint. If we fail to respond to your complaint within a reasonable period or if you are dissatisfied with the response that you receive from us, you may have the right, depending on the jurisdiction, to make a complaint to the applicable regulator. In Australia, the applicable regulator is the Office of the Australian Information Commissioner.