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Cookies and Electronic Marketing Policy.
Cookies and Electronic Marketing Policy (AU)
The purpose of this policy is to provide a clear and up-to-date description of how the College manages Tracking Technologies, Electronic Messages and associated Personal Information.
“College” means the College of Law Limited (ACN 138 459 015).
“DNT” means an internet browser “Do Not Track” option that lets individuals tell websites that they do not want to have online activities tracked.
“Electronic Message” means email, SMS and instant messages using any system or service.
“Marketing Message” means an electronic message that includes an offer to supply or that advertises or promotes goods or services.
“Online Information” includes IP addresses or proxy servers, device and application identification numbers, locations, browser types, internet service providers and/or mobile carriers, pages and files viewed, searches, operating systems and system configuration information and date and time stamps.
“Personal Information” has the meaning given to it by s6(1) of the Privacy Act and means information or an opinion about an identified individual, or an individual who is reasonably identifiable: whether the information or opinion is true or not; and whether the information or opinion is recorded in a material form or not.
“Learning Portal” means the College’s Learning Management System.
“Privacy Act” means the (Cth) Privacy Act 1988 including the Australian Privacy Principles in Schedule 1 of that Act.
“Related Company” means a subsidiary of the College.
“Social Media Features” means online tools that facilitate interaction with social media sites including the FaceBook “like” button, the “tweet” button and other sharing widgets.
Use of Tracking Technologies and Electronic Messages
The College uses Tracking Technologies:
- to maintain continuity in the interactions of web visitors with the College website,
- to compile information about the usage of the College website,
- to compile information about the usage of the College website including interactions with emails from the College, and
- to support targeted advertising.
The College uses Electronic Messages for administration and marketing.
In cases where a natural person is or can be identified by a Tracking Technology or an Electronic Message, the information collected may be Personal Information. The College has a responsibility to ensure that its management of Personal Information complies with the Privacy Act.
How Online Information is collected
The College uses Tracking Technologies to collect Online Information associated with individuals that visit College websites.
Individual College website users can manage the use of Tracking Technologies using settings presented by a pop-up containing general information about Tracking Technology options including where Tracking Technology is:
- required and always active
- functional and can be enabled/disabled, and
- advertising and can be enabled/disabled.
College website users may also access the Tracking Technology preference settings via the footer of the website.
Individuals can opt-out from the collection of non-essential device and usage data by managing the individual browser settings for cookies.
While some internet browsers offer a DNT option, these features are not yet uniform and there is no common standard that has been adopted by industry groups, technology companies or regulators. The College does not currently commit to responding to browsers' DNT signals with respect to College websites.
The kinds of information collected
The College collects Online Information from its website and online services.
The purpose of collection on Online Information
Online Information is used to analyse overall trends, to help the College provide and improve its websites and to guarantee the security and continued proper functioning of College websites. Individuals that block or delete cookies and similar technologies used by the College websites, may not be able to take full advantage of the services offered by the College website.
Email, Electronic Messages and Marketing Messages
The College uses Electronic Messages to communicate with Staff, students, service providers and suppliers in the ordinary course of business.
The College may also use Electronic Messages to send individuals Marketing Messages about College products and services related to the seminars, products and courses associated with, or related to seminars or courses enrolled in, or attended by, the individual and/or products ordered or purchased by the individual.
As part of the purchase process for a service or product or College promotional activity, individuals may be offered a right to “opt-in” to Marketing Messages from the College. Individuals who opt-in to Marketing Messages may be sent Electronic Messages marketing the products or services of the College and its business partners in accordance with the express terms of the opt-in, unless they unsubscribe.
The College includes details of the sender and an unsubscribe notice on all Marketing Messages. The College also uses web beacons in email communications. For example, the College may place web beacons in marketing emails that notify the College when an individual clicks on a link in the email that directs him or her to a College website.
The College websites may use Social Media Features. These buttons and other sharing widgets give users the option to post information about their activities on a website to a profile page provided by a third-party social media network to share with others within the individual’s network.
Social Media Features are either hosted by the respective social media network or hosted directly on the College website. To the extent the Social Media Features are hosted by a social media network, the latter may receive information that the individual has visited a College website from his or her IP address. If an individual is logged into his or her social media account, it is possible that the respective social media network can link his or her visit to the College websites with his or her social media profile.
Interactions with Social Media Features are governed by the privacy policies of the companies providing the relevant Social Media Features.
The College Learning Portal
The College Learning Portal is hosted in the cloud. Online Information generated automatically by use of College cloud services may include IP addresses (or proxy servers), device and application identification numbers, locations, browser types, internet service providers and/or mobile carriers, the pages and files viewed, searches and other actions taken by an individual, operating system and system configuration information and date/time stamps associated with an individual’s usage.
The information collected is used to maintain the security of the services, to provide necessary functionality, as well as to improve performance of the services, to assess and improve customer and user experience of the services, to review compliance with applicable usage terms, to identify future opportunities for development of the services, to assess capacity requirements, to identify customer opportunities and for the security of the College’s systems, products or services.
Some of the device and usage data collected within the services, whether alone or in conjunction with other data, could identify an individual and therefore may constitute Personal Information. Device and usage data is primarily used for the purposes of identifying the uniqueness of each user logging on (as opposed to specific individuals), apart from where it is strictly required to identify an individual for security purposes or as required as part of the provision of services by the College.
28 May 2020
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