Effective date: April 22, 2020

Open Learning Global Pty Ltd and its associated companies (“us”, “we”, or “our”) operate the https://www.openlearning.com/ website and the OpenLearning App mobile application (the “Service”).

This page informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Service and the choices you have associated with that data.

We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms of Service.

Definitions

• Service Service means the https://www.openlearning.com/ website, any website managed or hosted by OpenLearning, and the OpenLearning App mobile application operated by Open Learning Global Pty Ltd
• Personal Data Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).
• Usage Data Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
• Cookies Cookies are small pieces of data stored on your device (computer or mobile device).
• Data Controller Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed.For the purpose of this Privacy Policy, we are a Data Controller of your Personal Data.
• Data Processors (or Service Providers) Data Processor (or Service Provider) means any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively.
• Data Subject (or User) Data Subject is any living individual who is using our Service and is the subject of Personal Data.

Information Collection and Use

We collect several different types of information for various purposes to provide and improve our Service to you.

Types of Data Collected

PERSONAL DATA

While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally identifiable information may include, but is not limited to:

• Email address
• First name and last name
• Cookies and Usage Data

We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt-out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send. Users who are invited into courses via the course provider are automatically opted out of receiving these communications.We may use your Personal Data to contact you regarding important information that could impact your usage of OpenLearning and it’s related services (Critical Updates). Due to the nature of the Critical Updates, it is not possible to opt-out of these communications.

USAGE DATA

We may also collect information that your browser sends whenever you visit our Service or when you access the Service by or through a mobile device (“Usage Data”).

This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When you access the Service by or through a mobile device, this Usage Data may include information such as the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.

LOCATION DATA

We may use and store information about your location if you give us permission to do so (“Location Data”). We use this data to provide features of our Service, to improve and customise our Service.You can enable or disable location services when you use our Service at any time, through your device settings.

TRACKING & COOKIES DATA

We use cookies and similar tracking technologies to track the activity on our Service and hold certain information.

Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyse our Service.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

Examples of Cookies we use:

• Session Cookies. We use Session Cookies to operate our Service.
• Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
• Security Cookies. We use Security Cookies for security purposes.
• Advertising Cookies. Advertising Cookies are used to serve you with advertisements that may be relevant to you and your interests.

Use of Data

Open Learning Global Pty Ltd uses the collected data for various purposes:

• To provide and maintain our Service
• To notify you about changes to our Service
• To provide customer support
• To gather analysis or valuable information so that we can improve our Service
• To monitor the usage of our Service
• To detect, prevent and address technical issues
• To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information
• To personalise your experience (your information helps us to better respond to your individual needs)
• For research into learning and/or teaching and/or on-line engagement (our site is designed by educational researchers with a passion for discovering and sharing the most effective ways of facilitating learning and teaching which is engaging)

Legal Basis for Processing Personal Data Under General Data Protection Regulation (GDPR)

If you are from the European Economic Area (EEA), Open Learning Global Pty Ltd legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.

Open Learning Global Pty Ltd may process your Personal Data because:

• We need to perform a contract with you
• You have given us permission to do so
• The processing is in our legitimate interests and it’s not overridden by your rights
• For payment processing purposes
• To comply with the law

Transfer of Data

Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

If you are located outside Australia or Malaysia, and choose to provide information to us, please note that we transfer the data, including Personal Data, to Australia and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Open Learning Global Pty Ltd will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organisation or a country unless there are adequate controls in place including the security of your data and other personal information.

Disclosure of Data

Business Transaction

If Open Learning Global Pty Ltd is involved in a merger, acquisition or asset sale, your Personal Data may be transferred. We will provide notice before your Personal Data is transferred and becomes subject to a different Privacy Policy.

Disclosure for Law Enforcement

Under certain circumstances, Open Learning Global Pty Ltd may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Legal Requirements

Open Learning Global Pty Ltd may disclose your Personal Data in the good faith belief that such action is necessary to:

• To comply with a legal obligation
• To protect and defend the rights or property of Open Learning Global Pty Ltd
• To prevent or investigate possible wrongdoing in connection with the Service
• To protect the personal safety of users of the Service or the public
• To protect against legal liability

Security of Data

We implement a variety of security measures to maintain the safety of your personal information when you enter, submit, or access your personal information.

All supplied sensitive/credit information is transmitted via Secure Socket Layer (SSL) technology and then encrypted into our Payment gateway providers database only to be accessible by those authorised with special access rights to such systems and are required to keep the information confidential.

Your private financial information (credit cards, social security numbers, financials, etc.) will not be stored on our servers.

The security of your data is important to us; however, no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

“Do Not Track” Signals

We do not support Do Not Track (“DNT”). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.

You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

Your Data Protection Rights Under General Data Protection Regulation (GDPR)

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. Open Learning Global Pty Ltd aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.

If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.

In certain circumstances, you have the following data protection rights:

• The right to access, update or to delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
• The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
  
• The right to object. You have the right to object to our processing of your Personal Data.
• The right of restriction. You have the right to request that we restrict the processing of your personal information.
• The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
• The right to withdraw consent. You also have the right to withdraw your consent at any time where Open Learning Global Pty Ltd relied on your consent to process your personal information.

Please note that we may ask you to verify your identity before responding to such requests.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).

Service Providers

We may employ third party companies and individuals to facilitate our Service (“Service Providers”), to provide the Service on our behalf, to perform Service-related services or to assist us in analysing how our Service is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose. The list of third party providers below is not extensive and we may use other third parties from time to time.

Analytics

We may use third-party Service Providers to monitor and analyse the use of our Service.

• Google Analytics Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualise and personalise the ads of its own advertising network. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en
• Firebase Firebase is analytics service provided by Google Inc.You may opt-out of certain Firebase features through your mobile device settings, such as your device advertising settings or by following the instructions provided by Google in their Privacy Policy: https://policies.google.com/privacy?hl=en. We also encourage you to review Google’s policy for safeguarding your data: https://support.google.com/analytics/answer/6004245. For more information on what type of information Firebase collects, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en.
• Advertising
  
• We may use third-party Service Providers to show advertisements to you to help support and maintain our Service.
  
• • Google AdSense & DoubleClick Cookie Google, as a third-party vendor, uses cookies to serve ads on our Service. Google’s use of the DoubleClick cookie enables it and its partners to serve ads to our users based on their visit to our Service or other websites on the Internet. You may opt-out of the use of the DoubleClick Cookie for interest-based advertising by visiting the Google Ads Settings web page: http://www.google.com/ads/preferences/
  • Behavioural Remarketing
    
  • Open Learning Global Pty Ltd uses remarketing services to advertise on third party websites to you after you visited our Service. We and our third-party vendors use cookies to inform, optimise and serve ads based on your past visits to our Service.
    
  • • Google AdWords Google AdWords remarketing service is provided by Google Inc. You can opt-out of Google Analytics for Display Advertising and customise the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/adsGoogle also recommends installing the Google Analytics Opt-out Browser Add-on – https://tools.google.com/dlpage/gaoptout – for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en
    • Twitter Twitter remarketing service is provided by Twitter Inc. You can opt-out from Twitter’s interest-based ads by following their instructions: https://support.twitter.com/articles/20170405. You can learn more about the privacy practices and policies of Twitter by visiting their Privacy Policy page: https://twitter.com/privacy.
    • Facebook Facebook remarketing service is provided by Facebook Inc.You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/164968693837950. To opt-out from Facebook’s interest-based ads follow these instructions from Facebook: https://www.facebook.com/help/568137493302217. Facebook adheres to the Self-Regulatory Principles for Online Behavioral Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your mobile device settings. For more information on the privacy practices of Facebook, please visit Facebook’s Data Policy: https://www.facebook.com/privacy/explanation
    • Payments
      
    • We may provide paid products and/or services within the Service. In that case, we use third-party services for payment processing (e.g. payment processors).
      
      We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.
      
      The payment processors we work with are:
      
    • • Apple Store In-App Payments Their Privacy Policy can be viewed at https://www.apple.com/legal/privacy/en-ww/
      • Google Play In-App Payments Their Privacy Policy can be viewed at https://www.google.com/policies/privacy/
      • Stripe Their Privacy Policy can be viewed at https://stripe.com/us/privacy
      • PayPal or Braintree Their Privacy Policy can be viewed at https://www.paypal.com/webapps/mpp/ua/privacy-full

Links to Other Sites

Our Service may contain links to other sites that are not operated by us. If you click on a third party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Children’s Privacy

For courses available for public enrolment via the https://www.openlearning.com/ website or for accounts created through our Service’s publicly accessible account registration system (“Marketplace”), we do not address anyone under the age of 18.

We do not knowingly collect personally identifiable information from anyone under the age of 18 through the Marketplace. If you are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

For courses where a User is enrolled or an account is created via an institution portal or a private enrolment processes, and where the User is in a private class, the Service  supports Users who are at least 13 years of age but under 18 years of age (“Minor”) and provides the necessary tools to protect their privacy.

If you are a parent, legal guardian, school, approved teachers, facilitator, or third-party provider permitting a Minor to create an account and/or use our Service, you agree to:

• supervise the Minor’s use of the Service and their account;
• assume all risks associated with, and liabilities resulting from, the Minor’s use of the Service and their account;
• ensure that the courses that the Minor enrols in on our Service are suitable for the Minor;
• ensure all information submitted to us by the Minor is accurate; and
• provide the consents, representations, and warranties contained in the Privacy Policy and Terms of Service on the Minor’s behalf.

Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the “effective date” at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Terms and Conditions

Please also visit our Terms and Conditions section establishing the use, disclaimers, and limitations of liability governing the use of our website at coursemagic.ai/terms-of-service/

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