Privacy Policy

ULLEO HOLDINGS PTY LTD (ABN: 84 661 335 173)

1. Introduction

1.1 In this Policy, Ulleo, we, our or us is a reference to Ulleo Holdings Pty Ltd (ABN: 84 661 335 173).

1.2 Personal information is any information about you where your identity is apparent, or can reasonably be ascertained, and may include Sensitive Information (defined below).

1.3 Sensitive Information is information or an opinion about a person’s racial or ethnic origin, political opinions, membership of a political association, religious beliefs or affiliations, philosophical beliefs, sexual preferences, health or medical information or criminal records.

1.4 Related Parties is any holding company or subsidiary company of Ulleo or any other business within our company group.

2. What this Policy is about

2.1 This Policy explains the key measures we have taken to implement the requirements of the Privacy Act 1988 (Act), the Australian Privacy Principles and where applicable, other data protection laws such as the European Union General Data Protection Regulations (GDPR). This Privacy Policy outlines the Personal Information collection practices utilised by Ulleo, how that information is collected, used and disclosed and your rights in relation to your Personal Information.

2.2 This Policy covers Personal Information collected directly from individuals who register to access educational courses and use certain features provided through the website Ulleo.com and through mobile applications and related services provided by us (Services).

2.3 We endorse fair information handling practices and uses of information in compliance with our obligations under the privacy laws in force in Australia from time to time. Any information provided, including identification of individuals, will be used only for the purpose(s) intended and where the intention includes confidentiality, information will be treated as such unless otherwise required by law.

2.4 This Policy represents the default position that Ulleo will take in its treatment of Personal Information. Ulleo will treat all Personal Information in a manner consistent with this Policy unless you have provided your express consent otherwise.

2.5 If there is any inconsistency between the Act and this Policy, this Policy shall be read and interpreted to comply with the Act.leo

3. Other Terms and Conditions

3.1 Your access to and use of the Services is also subject to our Terms and Conditions (Terms and Conditions). The Terms and Conditions for your use of the Services on any platform may be found on our Terms of Use page.

4. Collection of Personal Information

4.1 Ulleo collects Personal Information about you, which you provide to us as a user or prospective user of the Services, which may include your name, address, email, date of birth, telephone number and other contact details, together with financial information you provide to us.

4.2 Personal Information and Sensitive Information will be typically collected when provided directly to Ulleo by you:

• when you contact us through our website ulleo.com;
• when completing a registration form
• during phone calls or other communications between you and us;
• when you log in or register for the Services via social media platforms; and
• when you contact or communicate with us by any other means.

4.3 Our Website automatically collects anonymous usage data about visitors, including the URL that the visitor came from, the browser being used and the IP address. This data is utilised to improve the services of Ulleo and does not include any personally identifying information.

4.4 Ulleo also reserves the right to collect anonymous usage data through other websites and online systems in order to provide its customers with a better user experience. This data does not include any personally identifying information.

4.5 ‘Cookies’ are alphanumeric identifiers that are stored by the web browser on a computer’s hard-drive that enable our system to recognise a visitor to our Website. This helps Ulleo to track basic visitor information for the purposes of optimising the design of our systems and marketing activities.

4.6 Most web browsers automatically accept cookies and this function can be disabled by changing the browser settings of the user.

4.7 Please note that the Website contains links to other websites which are not hosted or operated by Ulleo. Ulleo is not responsible for the privacy policies of such other websites and you should independently review the privacy policies on such websites.

5. Use of Personal Information

5.1 Ulleo uses Personal Information in the following ways:

• to provide you with information, products or services you have requested, including providing you with information about options available;
• to provide to third parties we engage with to provide you with goods or services or to assist us in providing the Services;
• to respond to your enquiries or to register you as a registered user of the Services;
• to promote and market our products and services to you;
• to personalise and customise your experiences of the Services;
• to help us research the needs of our customers;
• to conduct research for the purposes of improving existing products or services or creating new products or services;
• to operate and improve our Services, including displaying personalised content and advertising;
• to provide you with ongoing information about Ulleo and its activities;
• to allow us to provide you with third party information and offers in which we believe you may be interested;
• to comply with regulatory or other legal requirements; and
• for any other use required or permitted by law or any other purpose communicated to you at the time that the Personal Information was collected or for which you provided your consent.

5.2 We do not pass on any Personal Information to third parties except in accordance with this Policy.

5.3 We may use your Personal Information to provide you with direct marketing materials if you would reasonably expect us to or if you consent to receive direct marketing materials. We will seek your consent to provide you with direct marketing materials if we have obtained your Personal Information from a third party. Direct marketing material may include promotional material about Ulleo and its Related Parties or the products or services offered by Ulleo and its Related Parties.

5.4 You may opt out of receiving direct marketing material by contacting us in any of the ways specified in the direct marketing materials or by contacting our Privacy Officer.

5.5 In providing the Services, we may collect your telephone number if you provide it to us. By providing your telephone number, you consent to receive calls and/or SMS, MMS, or text messages at that number as set out in the Terms and Conditions. We may share your telephone number with our affiliates or with our service providers (such as customer support, billing or collections companies, and text message service providers) who we have contracted with to assist us in pursuing our rights or providing our Services under the Terms and Conditions, our policies, applicable law, or any other agreement we may have with you. Your telephone number will be used, stored and disclosed in accordance with this policy.

5.6 You may opt out of receiving calls and/or SMS, MMS, or text messages as outlined above in any of the ways specified in the calls and/or SMS, MMS, or text messages or by contacting us or the Privacy Officer.

5.7 You may register or log in for the Services using an existing account you have with a social media network. In doing so, Personal Information that has been collected and stored by the social media network may be shared with us to enhance and personalise your experience of the Services, in accordance with the social media network’s privacy policy. We may also disclose Personal Information to the social media network in accordance with this Policy.

6. Disclosure of Personal Information

6.1 Other than disclosure to shareholders, officers and employees of Ulleo, Related Parties, service providers who assist us in our business operations or as required by law (for example, disclosure to various Government departments or to Courts), our policy is that we do not give Personal Information to other organisations unless we have disclosed the use in this Policy or you have expressly consented for us to do so.

6.2 We may also disclose your Personal Information to our website host or service providers in certain limited circumstances, for example when our website experiences a technical problem or to ensure that it operates in an effective and secure manner. To the extent that we do share your Personal Information with a service provider, we would only do so if that party has agreed to comply with our privacy standards as described in this Privacy Policy, and such access will be revoked within a reasonable timeframe of access no longer being required.

6.3 We may also share non-personal, de-identified and aggregated information for research or promotional purposes or for the purpose of improving the Services.

6.4 Unless otherwise specified in this Privacy Policy, Ulleo will not and will procure that Ulleo’s website host will not disclose any of your Personal Information to any other organisation unless the disclosure is required by law, is otherwise permitted by the Privacy Act, or is with your consent.

6.5 Ulleo uses specific systems to collect and store data, including Google Cloud in Sydney, Australia. All data stored using these specific providers is governed by each provider’s privacy policy, the Privacy Act, GDPR and any other relevant law.

7. Confidentiality and Data Security

7.1 All Personal Information collected may be transmitted overseas for the purposes of storage in offshore servers and on secure Australian servers.

7.2 We take all reasonable steps to manage data stored on our servers to ensure data security and to prevent the loss, misuse or alteration of Personal Information. Notwithstanding the above, Ulleo is not responsible for any third-party access to Personal Information as a result of:

• interception while it is in transit over the internet;
• an unpatched vulnerability, a zero-day vulnerability, or an attack within 48 hours of a vendor releasing a patch or update;
• spyware or viruses on the device (such as a computer or phone) from which you access our Website or otherwise contact us; or
• as a result of your failure to adequately protect your username or password (if applicable).

7.3 Ulleo is also not responsible for any losses, expenses, damages and costs, including legal fees, resulting from such third-party access.

7.4 If we have reasonable grounds to believe that your Personal Information that we hold may be subject to unauthorised access or disclosure (eligible data breach), we will investigate and assess the suspected eligible data breach to determine whether the eligible data breach is likely to result in serious harm to you (Notifiable Data Breach). If a Notifiable Data Breach occurs, then we will notify you and the Australian Information Commissioner as soon as practicable after we become aware of the Notifiable Data Breach in accordance with our obligations under the Act. We will comply in every way with our obligations under Part IIIC – “notification of eligible data breaches” of the Act.

8. Retention and Disposal of Personal Information

8.1 We will retain Personal Information for as long as is required for us to fulfil the purposes for which the Personal Information was collected, including where applicable to provide you with the Services and to comply with legal requirements.

8.2 If we no longer require Personal Information for any purpose, including legal purposes, we will take reasonable steps to securely destroy or permanently de-identify the Personal Information.

8.3 If you wish to have your Personal Information destroyed or de-identified of if you wish us to stop or limit processing of your Personal Information, please contact the Privacy Officer and we will take reasonable steps to do so (unless we need to keep it for legal, auditing or internal risk management reasons, or as otherwise required by law).

9. Data Portability

9.1 If you are in the EU or UK and subject to the GDPR, you may have the right to request that we help you move your Personal Information to other companies or organisations where this is technically feasible provided that the Personal Information was collected by automatic means. If you would like to make such a request, you should contact our Privacy Officer. If we are required to do so at law, we will take reasonable steps to process your request.

10. Access to Personal Information

10.1 You can request to access your Personal Information at any time by contacting our Privacy Officer.

10.2 We will always endeavour to meet requests for access. However, in some circumstances we may decline a request for access. This includes the following circumstances:

• we no longer hold or use the information;
• providing access would have an unreasonable impact on the privacy of other persons;
• the request is frivolous or vexatious;
• the information relates to existing or anticipated legal proceedings and would not normally be disclosed as part of those proceedings;
• providing access would be unlawful;
• providing access would be likely to prejudice the detection, prevention, investigation and prosecution of possible unlawful activity; and
• the information would reveal Ulleo’s commercially sensitive information.

10.3 If we decline a request for access, we will provide reasons for our decision when we respond to the request.

10.4 We reserve the right to charge you a reasonable fee for access to your Personal Information. These charges will be limited to the cost of recouping our expenses for providing you with your Personal Information, such as document retrieval, photocopying, labour and delivery.

10.5 Despite anything contained in this Policy to the contrary, if the Freedom of Information Act 1982 applies to a person whose Personal Information we hold, the access and correction requirements in the Act operate alongside and do not replace other informal or legal procedures by which an individual can be provided access to, or correction of, their Personal Information.

11. Changing or deleting Personal Information

11.1 We will take reasonable steps to ensure that Personal Information is accurate, complete and up-to-date at the time of collecting the Personal Information from you, using or disclosing the Personal Information, or during other interactions with you or service providers in accordance with this Policy.

11.2 If you believe that any Personal Information that we hold about you is inaccurate, incomplete or out-of-date, you may contact our Privacy Officer.

11.3 We will do our best to correct any Personal Information that is inaccurate, incomplete or out-of-date or dispose of it in accordance with this Policy.

12. Contact Information and Changes to Privacy Policy

12.1 If you have any further queries relating to Ulleo’s Privacy Policy, please contact our Privacy Officer. If Ulleo becomes aware of any ongoing concerns or problems with your Personal Information, we will take these issues seriously and work to address these concerns.

12.2 If you have a complaint in relation to the way your Personal Information has been handled by Ulleo, the complaint should be made in writing to our Privacy Officer in the first instance. Ulleo will investigate the complaint and prepare a response to you in writing within a reasonable period of time.

12.3 Our Privacy Officer can be contacted by email at: privacy@ulleo.com or via phone on: +61 (03) 8375 9210

12.4 From time to time, our policies will be reviewed and may be revised. Ulleo reserves the right to change this Policy at any time.

This Privacy Policy was last updated in May 2020