“Personal Information” is information or an opinion, in any form and whether true or not, about an identified individual or an individual who is reasonably identifiable. Different states, countries, and laws define Personal Information (or similar terms, such as “personally identifiable information” and “personal data”) differently, but Personal Information generally includes information such as your name, mailing address, e-mail address, and phone number. It may also include the internet protocol (IP) address of your computer or mobile device, if that IP address can be linked to you from specific information we handle, or other information (such as other Personal Information accessible to us, or geo-location information) that can be used to ultimately identify you.

The kinds of Personal Information we collect and hold about you depends on the nature of your dealings with us and the circumstances of collection. For example:

• we may collect your name, telephone number, email address and other information you choose to provide to us, if you decide to contact us through a “Contact Us”, “Request More Information”, or similar links on a Site, or if you otherwise request information about the University or about the

Courses, units and other services we and they offer, including via subsequent telephone, electronic voice, or text communications with our representatives;

• if you apply for enrolment in a Course, or if you sign up to receive newsletters or other materials, we may collect your name, email address, and any other information you include with your submission, or that we or the University require to make a determination on your suitability for enrolment in the Course; and
• if you participate in a Course, we will obtain Personal Information from you so that we and the University is able to provide you with the services that you have signed up to receive, as well as to seek your feedback as to your experience in regard to the Course and the services received.

If you deal with us in some other capacity, we may collect your name and contact details and any other information you choose to provide to us. Other categories and examples of the types of Personal Information we collect are set out under “The Purposes For Which We Collect, Hold, Use and Disclose Personal Information” below.

We may collect sensitive information (such as health information) in limited circumstances (as described in more detail below under "The Purposes For Which We Collect, Hold, Use and Disclose Personal Information”), and we will only collect sensitive information about you as required to deliver the Services (unless we are otherwise required or authorised by or under law to do so).

In addition, a Site may automatically collect certain information from you when you visit it, such as your IP address or other unique identifier of your computer or other device, and information about the browsing history and website, app or social media interactions associated with that device. This device and online activity information may be considered Personal Information where it could be used to ultimately identify you (for example, where information held is able to be linked with other accessible information that could ultimately identify you). However, we will not use this type of automatically collected information to identify or to contact you, unless and until you voluntarily provide other Personal Information to us in the manner outlined above (such as via a “Request More Information” form). More information about how we use this information on an anonymous, de-identified and/or aggregate basis is described below under “How We Collect and Use Non-Personal Information”.

We routinely collect Personal Information for the purpose of providing our Services, in order for the University to provide its services to you in relation to a Course, and for our other business functions and activities, including:

The Personal Information you may be asked to provide to us, and the purpose for which we collect, hold, use and disclose that Personal Information, may include the categories described below.

In addition to the purposes specified in the table below, we also collect Personal Information so that we can operate our business and provide Services to you, and others, as described further below under "Personal Information We Obtain From Third Parties" and "Certain Generally Applicable Uses of Personal Information."

We present this information based on the categories of Personal Information collected, but please note that similar specific pieces of information may apply to multiple categories. For example, your name and email address may be included within each of the “Contact Information,” “Communication, Activity and Marketing Information,” and “Educational History Information” categories described below.

As noted above, we collect some Personal Information from third parties, including Personal Information that has been provided to us from the University, in order that we can perform our Services in relation to the Course.

The Personal Information we collect directly from you and from third parties may be used for additional purposes related to the operation of our business and our provision of Services, including:

• our and the University’s internal record-keeping;
• where necessary as part of any restructuring of the Keypath Group;
• for compliance with legal, regulatory, and other good governance obligations;
• to convert Personal Information into pseudonymous and/or de-identified data, and to use it (normally on an aggregated statistical basis) for research and analysis;
• to gain insight that enables us and the University to measure the effectiveness of our Services; and
• to learn about potential and current students, their interests, needs, and resources applicable to the Courses so that we can improve the Courses and provide you and others with better and targeted service offerings by tailoring our marketing messages to your and their specific interests, needs, and abilities. This may include by undertaking remarketing or other targeted marketing activity or building a 'lookalike audience' on social media platforms to better direct our marketing messaging.

When we use your Personal Information for our business purposes, those business purposes include working with the University to make Courses available, responding to your, other students’ and potential students’ queries or complaints, marketing the University’s products and services, improving and developing new products and services, and ensuring the productivity, functionality, and security of the Site.

We will keep your Personal Information as long as we have a business need to do so and/or as necessary to meet the purpose for which the information was collected and used, unless a longer period is required by law or by contract. For example, we will keep Personal Information for at least as long as you continue to be enroled in any Course, and, if any Site allows you to create an account, we will keep the Personal Information associated with your account for as long as you maintain it. Business needs for which Personal Information may be retained include legal, tax, accounting, risk management, and other business purposes.

All applicant, enrolment, and student details will be kept for at least as long as we continue to provide Services to the University, unless we agree otherwise with the University. Once we cease to have a relationship with the University, our practice is to de-identify (or otherwise destroy) all Personal Information we have collected in the course of that relationship.

It is important to note that some Personal Information that we collect may be made public. For example, with your consent, we may use your image and testimonials in promotional materials for the University. In these circumstances, your information will be able to be seen and republished for as long as the marketing materials continue to be posted online, or as long as the hard copies remain in existence. In addition, we or the University may make available services that enable you to post information on a Site in public forums and on message boards. In these cases, once posted, the information will be able to be seen and republished by others for as long as that web page remains active. Even if web pages, apps or platforms are deleted, they may continue to be accessed if they are archived or cached. Therefore, you should think carefully before giving your consent to the use of your name, image, and comments in any materials and, if applicable, before posting anything in any public area of a Site.

A. What Is Non-Personal Information?

Non-Personal Information refers to information that is not and cannot be used to identify a specific individual, or is Personal Information that has been de-identified so that it is no longer about an identifiable individual, or an individual who is reasonably identifiable. This may include information about the statistical characteristics of the visitors to a Site or persons who enrol in Courses. While this information may define how you fit into a particular group of people, it is not unique to you, and it cannot be used to specifically identify you. This section describes how we collect and use non-Personal Information.

B. The Non-Personal Information We Collect and Why.

When you visit a Site or interact with us electronically (such as through email), we may automatically collect standard internet and website log information, and details of patterns about how you behave. This information includes your internet service provider name, your operating system, your browser type and browser language, the IP address of your computer or other device (unless such IP address can be used to identify you), your access times, whether email correspondence from us was opened, any links that you visit from those emails, the website that referred you to a Site, the specific web pages you visit and the date and time of those visits, and links clicked as you visit a Site.

We use this information to evaluate our Services, a Site (including to find out which parts of a Site are popular or may need improvement), to inform and evaluate marketing efforts, and to enhance your and others’ experiences with us, the University and a Site.

C. Cookies and Other Tracking Technologies.

A Site, such as the Course website, utilizes “cookies”, which are anonymous identifiers and other tracking technologies such as web beacons, and which enable us to provide you with information that is customized for you, including to show you promotions on other third-party platforms. For more information, see the “Cookies Policy” section of this Privacy Policy.

D. Analytics Services.

A Site, such as the Course website, may use analytics tools and Services to collect information about your use of the Site, such as how often you visit the Site, what pages you visit, and what other sites you used prior to visiting the Site. We use the information we collect from these analytics Services to maintain and improve the Site and our and the University’s Services, to provide a better user experience, and to inform and evaluate our marketing efforts. The analytics Services we use include Google Analytics, Facebook Ads, and others.

E. Sharing Non-Personal Information.

We may use or disclose non-personal, aggregate, anonymous information to third parties (such as the third party service providers we engage in order to improve the Site and our and the University’s Services), and to market research firms.

A. What Are Cookies?

Cookies are small amounts of data that are stored on your browser, device, or the page you are viewing when you visit a website. Some cookies are deleted once you close your browser or application (session cookies), while other cookies are retained even after you exit so that you can be recognized when you return (persistent cookies). Cookies do not typically contain any information that personally identifies a user, but Personal Information that we store about you may be linked to the information stored in and obtained from cookies.

B. How We Use Cookies.

We use both session and persistent cookies on a Site. The cookies we use are generally divided into the following categories:

• Mandatory cookies: These are cookies that are required for the effective navigation of all areas of the Site.
• Functional cookies: These are cookies that remember choices that you make when you visit the Site such as language options. They help to make your visit more personal and assist your navigation of a Site.
• Analytics/Marketing cookies: These are cookies that automatically collect information about your use of a Site, such as the pages you visit, and the links you followed. These help us recognize previous visitors to the Site, understand how many people are using the Site, and how they navigate through it. As mentioned above, we use analytics Services to analyze user behavior, so these third parties will place these types of cookies on the Site, please see 'Third Party Cookies' below for further information.

C. Your Choices About Cookies.

Web browsers may automatically accept cookies, but you can usually change your settings to prevent that, such as by having your device warn you each time a cookie is being sent or choosing to turn off all cookies. On a Site, you will be able to disable all cookies other than mandatory cookies. This can be done through your web browser settings, and because each browser is different, you should look at your browser’s “Help” menu to learn how to modify your cookie settings. There are also online resources that may help you learn more how to opt out of targeted behavioral advertising from many major third-party network advertisers.

If you do disable cookies from your browser you may not be able to access certain sections of a Site that use mandatory cookies, and this may make your experiences on the Site less efficient.

D. Third Party Cookies

We may allow third parties to use analytics/marketing cookies on a Site in order for those third parties to provide their Services to us. These Services may include the provision of website analytics (for example, from Google Analytics) and marketing and promotional Services (such as those provided by Google Ads and Facebook). These third parties may use the information gathered by those cookies to assist us with personalizing content, providing a better user experience and for targeted advertising.

E. Do Not Track Requests.

Currently, certain browsers, including Firefox, Google Chrome, Safari and Microsoft Edge, offer a “do not track” (DNT) option. This option, using a technology known as a DNT header, sends a signal to websites visited by the user about the user’s DNT preference, if any, set on the browser. However, we do not currently commit to responding to browsers’ DNT signals. We cannot make this commitment because no common industry standard for DNT has been adopted by industry groups, technology companies, or regulators.

We collect, use, and process your Personal Information on behalf of the University, and accordingly, it will be shared with the University for all purposes consistent with this Privacy Policy, including to process applications and enrolment materials and to fulfill our contractual relationship with the University. In addition, we may also collect and share your Personal Information with the University so that we can collaborate with them for the purpose of undertaking research, and to develop, deploy, and deliver additional Courses and online programs, and to facilitate flexible online learning.

Please note that we have no control over how the University uses Personal Information and other information we share with them. You are reminded that the University has its own Privacy Policy and privacy notices, and their collection and use of your Personal Information is subject to the terms of their policy and relevant notices.

We may share information with other third parties in the following circumstances:

• We share your information, including Personal Information with the University in order to administer your enrolment in the Course and to otherwise provide the Services to the University and you.
• We may share your information, including Personal Information, so that we or others may provide you with periodic communications in connection with the University’s Courses, or may contact you regarding products, services, or events of the University. If you do not wish for us to share your information in this manner, please let us know by contacting us at cst@keypathedu.com.
• We may employ other companies and people to perform tasks on our behalf and we may need to share Personal Information with them to provide Services to you. For example, such third parties may handle our data management and/or email distribution. Unless we tell you differently, those third parties do not have any right to use your Personal Information beyond what is necessary to assist us.
• We may share information, including Personal Information, with our corporate affiliates in the Keypath Group for the potential expansion and promotion of product and service offerings for the University, and other uses consistent with the purposes described in this Privacy Policy.
• We may share your Personal Information with your employer, if your employer is paying for your enrolment in a Course and/or unit.
• We will share Personal Information with third parties for other purposes if we have your express “opt-in” consent to do so.
• We may disclose non-personal, aggregate, anonymous data for our legitimate business purposes.
• We may disclose Personal Information at the request of law enforcement or government agencies or in response to subpoenas, court orders, or other legal process to establish, protect, or exercise our legal or other rights or to defend against a legal claim, or as otherwise required or allowed by law.
• We may disclose Personal Information if we believe that such action is appropriate to (a) protect the rights, property, or safety of a user of the Site or any other person, (b) investigate or prevent a violation by you of any contractual or other relationship with us or the University, (c) investigate or prevent your actual or potential illegal, fraudulent, or harmful activity, or (d) detect, prevent, or otherwise address fraud, security, or technical issues.
• We may share information, including Personal Information, in connection with, during negotiations of, or as a part of the closing of any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

We may also disclose your Personal Information to third parties for other purposes where we are required or authorised by or under law to do so (including where you have provided your consent).

We will never sell your Personal Information.

Other companies in the Keypath Group and some of our service providers are located outside of Australia. As a result, Personal Information collected and held by us may be disclosed to recipients in other countries, including recipients located in the United States, the United Kingdom, Malaysia, Singapore, Israel, Japan and Canada.

We, or a Site may offer social network and similar sharing features, such as Facebook, Twitter, Instagram, and YouTube buttons, which let you share information related to a Site, the University, and/or the Course(s) you enrol in, through your preferred social network site. In addition, a Site may include links to other third party websites.

Further, if you provide your Personal Information to us via a social network (for example, by completing a “Contact Us”, “Request More Information”, or similar form in-app), your Personal Information will be collected by us (via our account on the relevant social network), and by the social network.

The social network sites, and the third parties’ use of any data that may be collected by those sites, are not governed by this Privacy Policy. You should always review the privacy policies of any site you visit before submitting your Personal Information.

If you permit a connection between a Site and your social network page(s) or another third-party site, or you otherwise provide us with Personal Information via a social network platform, we (and the social network itself) may be able to identify you, and associate the information we (and they) receive with information we (and they) already have about you. In addition, depending on how you use those features and your settings with the social network or other third-party site, the information you share may be available to others, including your friends and/or the public. For more information about how your information may be shared through those social networks and other third-party sites once it is provided to them, you should review the privacy policies of those social networks and other third party sites.

We use a variety of industry-standard security measures to maintain the safety of your Personal Information, including measures designed to secure your Personal Information from accidental loss and from unauthorised access, use, alteration and disclosure. We store the Personal Information you provide on secure (password- and firewall-protected) servers.

Unfortunately, no electronic data transmission over the internet can be guaranteed to be 100% secure. As a result, while we believe that we use reasonable measures to protect Personal Information, we cannot ensure or warrant the security of any information transmitted or otherwise provided to us or received from us.

If any portion of a Site allows you to create an account, it will be your responsibility to keep your account and password confidential. We will never ask for your password (except, if applicable, when you create your account and log into the Site).

A. General Rights to Access, Correct and Remove Personal Information.

If you have any questions regarding this Privacy Policy or our use of your Personal Information, you can contact us by email at cst@keypathedu.com. In addition, you can also contact us at any time

at cst@keypathedu.com to request access to the Personal Information that we hold about you, or to otherwise request that we make any corrections to your Personal Information. If, where applicable, you have an account on a Site, you can access and edit your account information online, by signing into your account on a Site and selecting the information you want to edit.

As noted above, we have standard retention practices with respect to the Personal Information we collect.

If you would like to request any earlier removal of your Personal Information, please contact us at cst@keypathedu.com. Please note that we may not be able to completely remove Personal

Information from the Site or our systems in certain circumstances. This will be true if the data is not in a searchable format, if it is retained in backup systems or cached or archived pages, if we need it to prevent fraud or future abuse, or if we are required by law to keep it.

B. Your Rights Regarding Direct Marketing.

As noted above in this Privacy Policy, we may use your Personal Information to provide you with marketing and promotional information about our and the University’s products and Services. These promotions may be made by mail, email, telephone, instant messaging application, or text (SMS) message, or other methods that may become relevant or available. All promotional materials that are sent by electronic means will include a simple method for you to stop receiving further communications. For example, we may provide you with an “unsubscribe” link, or an email address to which you can send an opt-out request. In addition, if we need your consent for direct marketing communications under applicable law, and if you provide your consent, you will subsequently be able to change your mind at any time.

Your consent will be deemed if you do not opt out when we offer you the opportunity to do so, and will remain current until you advise us otherwise. You can manage your consent preferences with respect to direct marketing activities by contacting us at cst@keypathedu.com. Please note that despite your email preferences, we may need to contact you regarding your enrolment with the University, as required by law, or regarding legal matters. However, we will not send you targeted marketing communications if you have opted out of receiving them.

The Site is not targeted to, and we have no interest in collecting information from, children, and we do not knowingly gather any Personal Information from children under the age of 15. If you are a parent or a legal guardian who believes that your minor child has provided us with any Personal Information, please contact us at cst@keypathedu.com.

Please contact us (at cst@keypathedu.com) if you have any questions, or if you otherwise have any concerns or complaints about the manner in which we have handled your Personal Information. We will inquire into your complaint and respond to you in writing within 30 days. If we don’t respond to your complaint within 30 days, or if you are otherwise not satisfied with our response, you can lodge a complaint with the Office of the Australian Information Commissioner (www.oaic.gov.au).

We may make changes to this Privacy Policy from time to time. Any modifications will be effective when the changes are posted to a Site. You can review the most current version of this Privacy Policy at any time by accessing the section of a Site labeled “Privacy Policy”, and you can determine when this Privacy Policy was last revised by referring to the “Last Updated” legend at the top of this Privacy Policy. You are expected to check this Privacy Policy from time to time to take notice of any changes.