Privacy Policy

Your privacy

At OES, we are committed to protecting your privacy as an online visitor to our website. Please read our privacy policy below carefully. It details what personal data we collect and how, what we do with it and who we share it with. It also describes your privacy rights and controls such as your choices regarding use, access and correction of your personal data.

OES Privacy Policy and Privacy Statement (UK, EU/EEA & Australia)

Last updated on 16 February, 2022

Introduction
1. We are committed to safeguarding the privacy of individuals (“you”, “your”) whose “personal data” (also called “Personal Information” under Australian laws) we collect and use. In this Privacy Policy and Privacy Statement (“Privacy Statement”), we explain how we handle your personal data. For example, what personal data we collect and how, what we do with it and who we share it with. It also describes your privacy rights and controls such as your choices regarding use, access and correction of your personal data.
2. Our Privacy Statement is part of, and is subject to, our Cookies Policies https://oes.edu.au/cookies/ and https://oes.com/cookies/ and our Website Terms https://oes.edu.au/terms/. By accessing or using https://oes.edu.au or https://oes.com (each referred to separately as the “Website”), you confirm that you accept the terms of this OES Privacy Statement.
About OES
1. OES has offices in Australia and the United Kingdom (“UK”). Our Websites https://oes.edu.au and https://oes.com/ are owned and operated by Online Education Services Pty Limited ABN 75 148 177 959 (“OES Australia”). References to “OES” (or “we”, “us” or “our”) in this Privacy Statement apply to both OES Australia and OES UK where applicable.
2. If you have any questions about anything to do with this Privacy Statement, our data processes and practices or simply to exercise your privacy rights, please contact OES Australia, OES UK or, if you are in the European Economic Area (“EEA”), EDPO (European Data Protection Office), the OES EU Representative, using the contact details below.
How to contact OES Australia
1. OES Australia is an Australian registered company with its registered office and principal place of business at Level 1, 60 Cremorne St, Cremorne, Victoria, Australia 3121. You can contact OES Australia’s Privacy Officer by (a) post, to Level 1, 60 Cremorne St, Cremorne, Victoria 3121, (b) using the Australian Website contact form, (c) telephone, on +61 (0)3 9956 0800, or (d) email, using the following email address: dataprivacy@oes.com
How to contact OES UK
1. OES UK is a company registered in England and Wales with its registered office and principal place of business at Charter Buildings, 9 Ashton Place, Sale, Manchester, United Kingdom, M33 6WTN. You can contact OES UK by (a) post, to Charter Buildings, 9 Ashton Place, Sale, Manchester, United Kingdom, M33 6WTN, (b) using the Website contact form, (c) telephone, on +44 (0)20 3890 6910, or (d) email, using the following email address: dataprivacy@oes.com
How to contact EDPO (European Data Protection Office), the OES EU Representative
1. EDPO (European Data Protection Office) is a limited liability company incorporated under the laws of Belgium, with its registered office at Avenue Huart Hamoir 71, 1030 Brussels, Belgium and is registered with the Register of the Legal Entities of Brussels under number 0689.629.220. You can contact EDPO by (a) post, to Avenue Huart Hamoir, 71, 1030 Brussels, Belgium, (b) using the EDPO website contact form (https://edpo.com/contact/), or (c) email, using the following email address: info@edpo.com.
Why does OES collect personal data?
1. Personal data is information or an opinion about an identified individual or an individual who is reasonably identifiable. OES collects personal data so that we can:
  - properly identify you and conduct applicable checks;
  - understand your requirements to provide you with our services;
  - set up, administer and manage our services;
  - gather and aggregate information for statistical, prudential, reporting and research purposes;
  - manage, train and develop our staff;
  - get a better understanding of you and your needs so that we can effectively deliver services to you.
What if OES can’t collect your personal data?
1. If OES can’t collect your personal data from you (or from other people or organisations in some cases), OES may not be able to provide you with any, all or some of the services we provide, process your application for employment, fulfil our contractual obligations to you or others, fulfil our reporting obligations and or our legal compliance obligations to government agencies.
Your privacy rights and making a complaint (Australia)
1. OES Australia – You can obtain a copy of the OES Privacy Statement via the contact details above. We have summarised your privacy rights below:
2. You have the right to request access to the Personal Information we hold about you except where we cannot reasonably co-operate with the request because of the following:
  - It might pose a threat to life, health or safety;
  - It may unreasonably impact the privacy of others;
  - The request is frivolous or vexatious;
  - It relates to legal proceedings and would not be available via legal discovery in the proceedings;
  - It would prejudice ongoing negotiations with the individual;
  - It would be unlawful;
  - Denying access is authorised by law or a court order;
  - We reasonably believe that there is, or may be, unlawful activity or serious misconduct related to its functions or activities and providing access to the Personal Information is likely to prejudice appropriate action being taken in relation to the matter;
  - Providing access would likely prejudice any legal enforcement activities; or
  - Providing access may reveal commercially sensitive decision-making information generated within OES.
3. You may request us to correct your Personal Information and we must take reasonable steps, within a reasonable period, to correct Personal Information that we hold (a) which is inaccurate, out of date, incomplete, irrelevant or misleading; or (b) that you have notified us requires correction.
4. If you require more information about your privacy rights, or if you have complained to us about treatment of your privacy data and we have not been able to resolve the complaint within 30 business days, you may contact the Office of the Australian Information Commissioner (“OAIC”) at oaic.gov.au or at GPO Box 5218, Sydney NSW 2001 (complaints must be in writing).
Your privacy rights (UK)
1. We have summarised below your privacy rights. Some of these rights are complex, and not all of the details have been included in our summaries below.
2. For more information on your privacy rights under the UK GDPR, you should read the applicable data protection laws and guidance from the UK Information Commissioner. You can do so by using this link https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.
3. You may exercise any of your rights below in relation to your personal data by contacting the OES UK Data Protection Officer using the contact details above.
4. Your principal rights under the applicable data protection laws are:
  - the right to access;
  - the right to rectification;
  - the right to erasure;
  - the right to restrict processing;
  - the right to object to processing;
  - the right to data portability;
  - the right to complain to the UK Information Commissioner; and
  - the right to withdraw consent.
5. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
6. Right to access: You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. We may also charge a reasonable fee if your request is clearly unfounded, repetitive or excessive.
7. Right to rectification: You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed. You can ask us to make any necessary changes to ensure that your personal data is accurate and kept up to date.
8. Right to erasure: In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data is no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; the processing is for direct marketing purposes; and the personal data has been unlawfully processed. However, there are certain general exclusions to the right to erasure. Those general exclusions include where processing is necessary for: exercising the right of freedom of expression and information; compliance with a legal obligation; for the establishment, exercise or defence of legal claims. The consequences of erasing your personal data could include the inability to provide academic record of attendance, results or employment history as the case may be.
9. Right to restrict processing: In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful, but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another individual or legal person; or for reasons of important public interest.
10. Right to object to processing: You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
11. Right to object to processing (direct marketing): You have the right to object to our processing of your personal data for direct marketing purposes (including, for example, profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose. You may exercise this right at any time by (a) hitting the unsubscribe button in the email footer of the newsletter we send you, or (b) by contacting us in writing using the following email address: dataprivacy@oes.com.
12. Right to object to processing (scientific, historical research or statistics): You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
13. Right to data portability: To the extent that the legal basis for our processing of your personal data is consent, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
14. Right to complain to the UK Information Commissioner: If you consider that our processing of your personal data infringes the applicable data protection laws, you have a legal right to lodge a complaint with the UK Information Commissioner (ico.org.uk) which is the UK data protection regulatory body.
15. Right to withdraw consent: To the extent that the legal basis for our processing of your personal data is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
Your privacy rights (EU/EEA)
1. As the UK GDPR is based on, and very similar to the EU GDPR, the summary of your privacy rights in respect of the UK GDPR also applies to the EU GDPR except as provided in paragraphs 2 and 3 below. As before, some of these rights are complex, and not all of the details have been included in our summaries above.
2. For more information on your privacy rights under the EU GDPR, you should read the applicable data protection laws and guidance from the European Commission for a fuller explanation of these rights. You can do so by using this link https://ec.europa.eu/info/law/law-topic/data-protection/reform/rights-citizens_en.
3. If you are in the EEA, you may exercise any of your rights in relation to your personal data by contacting the OES EU Representative, EDPO (European Data Protection Office) using the contact details above.
Changes to the OES Privacy Statement
1. We may update the OES Privacy Statement from time to time in our sole discretion by publishing a new version on our Website. If we make updates to this Privacy Statement, all updates will be effective immediately upon our posting of the modifications on this Website. Please return periodically to review this Privacy Statement.
2. If we make changes that materially alter your privacy rights, we will provide additional notice, such as via email.
3. If you continue accessing and/or using our Website, receiving our communications, contacting us, and/or signing up /attending our events etc. this will constitute acceptance of the revised Privacy Statement.

What personal data OES collects

We use many different kinds of personal data. They are grouped together in the table below. The groups are all listed here so that you can see what we may know about you. We don’t use all this personal data in the same way. Some of it is useful for marketing, or for providing services to you etc.

Data Types	Description
Website data	This is data on how you use our Website and may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and Website navigation paths, as well as information about the timing, frequency and pattern of your use of our Website.
Service & Systems data	This may include billing data, your name and contact details such as your email address relating to the services we provide including information held in the learning management and customer relationship systems we use (if you enquired to hire us or you decided to hire us).
Correspondence data	This may include personal data contained in or relating to any communication that you send to us (e.g. when you provide feedback, respond to a survey, or communicate with our customer support etc.), or that we use to communicate with you (e.g. updates regarding our Website, services, systems etc.).
Marketing data	This may include personal data you provide to us if you sign up to receive our newsletters and choose whether you wish to receive promotional communications (e.g. offers, invitations to promotional activities such as events, webinars etc.) from us by email.
Cookies & similar technology data	This may include personal data that we obtain about you through cookies and similar technologies. For more information, see our Cookies Policy https://oes.edu.au/cookies/.
Profile data	This may include your name and contact details and some of the other personal data set out in this table e.g. Third-Party data, Registration data.
Registration data	This may include information you provide to register for our services, events, webinars, surveys, etc. and may include your name and contact details e.g. an email address.
Applicant data	This may include your name and contact details and any other additional personal information as well as a CV when you apply for a position with OES including through our Website.
Third-Party data	This may include your name and contact details we obtain from third parties such as third-party services providers, social media, publicly available sources of information, etc.
Financial Data	This may include bank account and payment card details.
Transaction Data	This may include details about payments to and from you and other details of services you have purchased from us.
Other data	This is personal data other than the ones set out in the table above.
Aggregated Data	We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Website data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Statement.

1. How OES collects your personal data – We collect your personal data from various sources. These are as follows:
1. 1. Data you provide us about you: We collect your personal data that you provide us when you do the following:
    - fill a contact webform on our Website;
    - get in touch with us by email, telephone, letter, and/or some other means;
    - apply for our services;
    - create an account on our Website;
    - subscribe to receive marketing communications from us such as newsletters informing you of our news, events etc.;
    - enter into a contract with you;
    - apply for a job with your name and contact details;
    - provide us with your contact details via a business card or by other means), for example at (a) an event or webinar we have organised and/or attended, and/or (b) pitching events; and
    - participate in a competition, promotion, survey, market research etc.
  2. Data we collect about you automatically: We collect your personal data automatically when you access and/or use our Website and through the use of cookies and other similar technologies (see our Cookies Policy https://oes.edu.au/cookies/). The types of personal data we will collect include, for example:
    - name and address;
    - demographic data;
    - the originating IP address;
    - the site that you visited immediately prior to visiting our Website;
    - the type of browser and operating system used (if provided by the browser);
    - URL of the referring page (if provided by the browser);
    - the specific actions that you take on our Website, including, for example, the pages that you visit; and
    - the time, frequency and duration of your visits to our Website.
  3. Data we collect about you from others: We also collect personal data about you from others such as (for example):
    - online through social media we use and the internet in general;
    - employers (if you apply for a job with OES and we contact your current or previous employer);
    - organisations and or individuals (e.g. your colleagues or associates) that introduce you to us or recommend you to us;
    - Lead generation companies;
    - Events organising companies;
    - Our parent company and other companies in our corporate group; and
- if you visit other websites employing our cookies and other similar technologies.

How OES uses your personal data – UK and EU/EEA

OES may use and disclose your personal data for the purposes for which we collected it as well as for related purposes, where you would reasonably expect us to do so. Below, you find a list of the ways that we may use your data and which of the legal reasons we rely on to do so.

Processing Type	Processing Purpose	Legal Basis
Website	To analyse your use of our Website as well as to develop, operate, improve, protect, personalise, customise and optimise our Website.	The legal reasons for this are our legitimate interest of the proper administration and operation of our business and/or to comply with a legal obligation.
Services and Systems	To provide you with information you requested about our services and systems when you are considering whether to register for our services and/or engage us. To provide you with services (e.g. provide a quote to you) and, if you decide to register and/or engage us to provide you with services, to allow you provide you with the services you engaged us for.	The legal reason for this is to perform our contract with you and/or take steps, at your request, to enter into such a contract
Communications (Non-Marketing)	To communicate with you (e.g. by email etc.) as well as to process the communications (e.g. customer support, complaints) you send to us.	The legal reasons for this are to perform our contract with you and/or our legitimate interest of the proper administration and operation of our business.
Operations	To perform general administrative and operational activities e.g. to manage our relationship with you which will include notifying you about changes to our terms or privacy policy, billing, debt recovery etc.	The legal reasons for this are to perform our contract with you, contract with you, it is necessary to comply with a legal obligation and our legitimate interest of the proper administration and operation of our business.
Marketing & Advertising	To send you newsletters and promotional communications (e.g. white papers, offers, invitations to promotional activities such as events, webinars etc.) from us by email that may be of interest to you based on your preferences as well as to market and advertise our business and services (including learning management systems) to you through a variety of different channels which may include social media.	The legal reason for this is our legitimate interest of conducting marketing including any soft opt-in to undertake direct marketing to promote our business and services (including learning management systems). To the extent that we are required to obtain consent for electronic marketing and we are not relying on your opt-in, our legal reason for this is consent.
Profiling	To create a profile of you by combining data you provided to us or we got from other sources such as social media, in order to update, expand and analyse our data records, lead generation, and create more tailored marketing (including, for example, advertising) and/or to personalise the services we provide to you.	The legal reasons for this is our legitimate interest of (a) the proper administration and/or operation of our business, and/or (b) conducting marketing (including, for example, advertising) to promote our business, and services (including learning management systems). To the extent necessary for providing our services (including learning management systems) to you, the performance of the contract between you and us.
Security, Risk & Crime	To protect our Website, services and systems (including learning management systems and customer relationship systems) and business, prevent fraud, spam, abuse, security incidents, harmful and/or illegal activity, conduct security investigations and risk assessments, and/or to verify or authenticate information.	The legal reasons for this is our legitimate interest of protecting our Website, services and systems (including learning management systems and customer relationship systems) and business, to comply with a legal obligation, to perform our contract with you, and/or the protection and assertion of our legal rights, your legal rights and the legal rights of others.
Research and Analysis	To carry out research (e.g. market research), business and statistical analysis (e.g. develop statistical models, analyse the performance of our marketing (including, for example, advertising) campaigns etc.	The legal reason for this is our legitimate interest of the proper administration, monitoring and/or operation of our business, Website, services and systems (including learning management systems and customer relationship systems).
Business improvement	To develop or improve our Website, services and systems (including learning management systems and customer relationship systems) and business.	The legal reason for this processing is our legitimate interest of the proper administration and operation of our business, Website, services and systems (including learning management systems and customer relationship systems) as well as to monitor them.
Data Retention	To retain, store, archive and/or destroy the data.	The legal reasons for this processing is the performance of a contract between you and us, our legitimate interest of the proper administration and operation of our business, to comply with a legal obligation, and/or the protection and assertion of our legal rights, your legal rights and the legal rights of others.
Audits	To carry out audits.	The legal reason for this processing is our legitimate interest of the proper administration and operation of our business as well as to monitor and improve our business, Website, services and systems (including learning management systems and customer relationship systems).
Sharing (Corporate Group)	To disclose your personal data such as your name and contact details to companies in our corporate group.	The legal reasons for this is our legitimate interest of administering, operating and/or managing our business, Website, services and systems (including learning management systems and customer relationship systems), and/or performance of a contract between you and us.
Sharing (Service Providers)	To disclose your personal data such as your name and contact details to third party service providers we use.	The legal reasons for this is our legitimate interest of administering, operating and/or managing our business, Website, services and systems (including learning management systems and customer relationship systems), and/or performance of a contract between you and us.
Sharing (Consent)	To share your data (including personal information) where you have provided consent, for the purpose(s) described at the time we ask you for your consent.	The legal reason for this is consent.
Sharing (Aggregated Data)	To share aggregated information (information about our individuals that we combine together so that it no longer identifies or references an individual) and non-personally identifiable information in order to conduct industry and market analysis, demographic profiling, marketing (including, for example, advertising).	The legal reason for this is our legitimate interests of the proper administration and operation of our business.
Sharing (Sale/Investment)	If there is (a) a sale or an asset transfer to a third party of, and/or (b) an investment in OES part of that sale, asset transfer and/or investment may include your personal data. Purchasers, investors and/or their advisers may have access to your personal data as part of the corporate due diligence they perform as part of the (a) sale or asset transfer, and/or (b) the investment.	The legal reason for this is our legitimate interest of the proper administration and operation of our business.
Sharing (Internal re-organisation & Insolvency)	To pass on to a successor in interest as part of a corporate re-organisation or in the unlikely event of an insolvency event such as a liquidation, insolvency, bankruptcy or administration.	The legal reason for this is our legitimate interest of the proper administration and operation of our business.
Sharing (Insurers & Professional Advisers)	To disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining and maintaining insurance coverage, managing risks, obtaining professional advice and/or managing legal disputes.	The legal reasons for this are our legitimate interest of the proper administration and operation of our business, to comply with a legal obligation and/or the protection and assertion of our legal rights, your legal rights and the legal rights of others.
Sharing (Legal Disclosures)	To disclose your personal data where such disclosure is necessary for compliance with any legal obligations to which we are subject (including to government regulators) and/or the protection and assertion of our legal rights, your legal rights and the legal rights of others.	The legal reasons for this are to comply with a legal obligation, and/or the protection and assertion of our legal rights, your legal rights and the legal rights of others.

1. OES’ obligations regarding its collection of your Personal Information – Australia
1. 1. OES collects your Personal Information only where it is reasonably necessary or directly related to OES’ functions or activities.
  2. With respect to Personal Information that is Sensitive Information (e.g. medical information), OES will not collect this information unless you consent or an exception under the Australian Privacy Principles applies.
OES may provide your personal data to others
1. Group Companies: We may disclose your personal data to any member of our group of companies to help us administer, operate and/or manage our business, Website, services and systems (including learning management systems and customer relationship systems), perform a contract between you and us, or perform a contract on behalf of a third party
2. Third-party service providers: We may disclose your personal data such as your name and contact details to our third-party service providers (e.g. Salesforce, Amazon etc.) to help us administer, operate and manage our business provide services related to us, our Website and/or systems (including learning management systems and customer relationship systems) Service providers may be located inside or outside of the UK or the EEA. For example, service providers may help us provide customer service, hosting, storage, payment processing, marketing etc. These service providers have limited access to your personal data to perform these tasks on our behalf and are contractually obligated to use it consistently with this Privacy Statement.
3. Aggregated Data: We may also share aggregated information (information about our individuals that we combine together so that it no longer identifies or references an individual) and non-personally identifiable information for industry and market analysis, demographic profiling, marketing and advertising, and other business purposes.
4. Sale/Investment: If there is (a) a sale or an asset transfer to a third party of, and/or (b) an investment in OES, part of that sale, asset transfer and/or investment may include your personal data. Purchasers, investors and/or their advisers may have access to your personal data as part of the corporate due diligence they perform as part of the (a) sale or asset transfer, and/or (b) the investment. However, use of your personal data will remain subject to this Privacy Statement.
5. Insolvency: Your personal data may be passed on to a successor in interest as part of a corporate re-organisation or in the unlikely event of an insolvency event such as a liquidation, insolvency, bankruptcy or administration. In the case of an insolvency event, our customer database may be sold separately from the rest of the business, in whole or in a number of parts. It could be that the purchaser’s business is different from ours too.
6. Our insurers & professional advisers: We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining and maintaining insurance coverage, managing risks, obtaining professional advice and/or managing legal disputes.
7. Legal compliance: In addition to the specific disclosures of personal data set out in this Section 16, we may also disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another individual.
OES Marketing
1. You can sign up to receive our newsletters and choose whether you wish to receive promotional communications (e.g. offers, invitations to promotional activities such as events, webinars etc.) from us by email, that may be of interest to you based on your preferences.
2. You can opt-out of receiving our newsletters and promotional communications by following the unsubscribe instructions included in our newsletters and promotional communications or by emailing us at dataprivacy@oes.com.
3. We do not and will not sell to third parties or deal in your personal data or customer information generally.
4. We also work with partners to try and promote the reach of our adverts and use analytics and retargeting for this reason. We may use information we or others collect about you from cookies and similar tracking technologies to deliver relevant online advertising (e.g. Google Adwords), including via websites and social media (e.g. LinkedIn).
OES’ use of social media
1. We use social media accounts and pages in different ways. For example:
  - to promote, market, advertise and communicate. We use social media to promote, market and advertise our brand, services and systems (including learning management systems and customer relationship systems). We also use social media to communicate with each other.
  - to generate leads for our business: If you connect with us through your social media account and/or communicate with us through that account, the information you choose to share with us may include the basic personal data available in your social media profile and also the information you provide to us when you communicate with us e.g. name, your contact details (e.g. email address, phone number) etc. We may also add your name and contact details to the CRM, sales and marketing software we use to generate leads for our business.
  - We have also integrated social media features and plugins on our Website. These features and plugins may collect your IP address, which page you are visiting on our Website, and may set a cookie to enable the feature to function properly. Also, when you click on one of the social buttons, you will be re-directed to our social media account page on the relevant social media. If at our account page, you are logged and you click on one of the buttons (such as Facebook’s ‘Like’ button) certain information is shared with these social media providers. Your social media provider may relate this information to your social media account and possibly present your actions on your social media profile to be shared with others in your network. These social media features and plugins are governed by the privacy policies of the social media providers and not our Privacy Statement.
International transfers of your personal data by OES
1. OES Australia may transfer personal data outside Australia for the same purposes as in “Why does OES collect personal data” (above). OES Australia will do so in accordance with privacy laws.
2. OES UK may transfer personal data we collect to countries outside the UK. This may happen as follows:
  - We and our other group companies have offices and facilities in Australia. Transfers to Australia will be protected by appropriate safeguards, namely the use of standard data protection clauses approved for use in the UK which give personal data the same protection it has in the UK;
  - The hosting facilities for our Website services and systems (including learning management systems and customer relationship systems) are situated in Australia. Transfers to Australia will be protected by one or more of the following appropriate safeguards, (a) the use of standard protection clauses approved for use in the UK which give personal data the same protection it has in the UK, and/or (b) the use of binding corporate rules.
  - We use a number of providers to facilitate the dissemination and sharing of online course materials, other content and examinations. Our overseas providers are situated in Australia. Transfers to providers in Australia will be protected by the use of standard protection clauses approved for use in the UK which give personal data the same protection it has in the UK. You acknowledge and agree that if you submit personal data for publication through our Website or social media accounts, this data may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
OES’ security of personal data
1. We strive to ensure the security, integrity and privacy of your personal data. We strive to do that by maintaining administrative, technical and physical safeguards designed to protect your personal data provided to us. We periodically review these safeguards and may update them from time to time in light of the current state of technology.
2. While no system or process is full-proof (e.g. may be prone to hacking), we believe the measures implemented reduce our vulnerability to security problems to a level appropriate to the type of personal data involved and the current state of technology.
OES protecting confidentiality
1. We will use all reasonable means to protect the confidentiality of your personal data while in our possession or control. We will not knowingly share any of your personal data with any third party other than in the ways described in this Privacy Statement e.g. our service providers who assist us in providing the information and/or services we are providing to you.
2. Any non-personal data, communications and material you submit to an OES Website or to us by email, or which we obtain from third parties that is not subject to obligations of confidentiality, may be kept, used and disclosed by us on a non-confidential basis. We are free to use and reproduce any such information freely, and for any purpose whatsoever. Specifically, we will be free to use any ideas, concepts, know-how or techniques contained in such information for any purpose, including developing, manufacturing or marketing products.
OES retaining and deleting personal data
1. We have data retention policies and procedures in place, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
2. Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
3. In some cases, it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria: the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements e.g. whether (and for how long) we are required by law to retain your personal data.
4. However, we may retain your personal data
  - where such retention is necessary for (a) the performance of a contract we have with you, (b) the compliance with a legal obligation to which we are subject, and/or (c) or the establishment, exercise or defence of legal claims; and/ or
  - in order to protect your vital interests or the vital interests of another.
OES links to Third Party websites
1. Our Website may contain links to third party websites. Please note that if you follow a link to any such website, we do not accept any liability and/or responsibility, because these websites have their own terms & conditions and Privacy Policies.
2. These links are meant for your convenience only. Links to third party websites do not constitute sponsorship, endorsement and/or approval of these websites.
3. Please be aware that we are not responsible for the privacy practices of such other websites. We encourage our users to be aware, when they leave our Website, to read the privacy policies of each and every website that collects their personal data identifiable information. This Privacy Statement applies solely to information collected by this Website.