Privacy

1. Introduction

1.1. Protecting your privacy

(a)
Your privacy and maintaining the confidentiality of your personal information is very important to CoUM. This page sets out how we handle your personal information including the collection, storage, use and disclosure of your personal information, as well as how you can access and change your information, provide us with feedback, or make a complaint.

(b)
As an Australian institution, CoUM is bound by the Australian Privacy Principles set out in the Privacy Act 1988 (Cth) (Privacy Act) and any other applicable Australian privacy legislation, including (but not limited to) the Health Records Act 2011 (VIC), Health Records and Information Privacy Act 2002 (NSW) and Health Records (Privacy and Access) Act 1997 (ACT).

(c)
In addition, CoUM offers online services to people based anywhere. This includes persons located in the European Union (EU) and/or United Kingdom (UK) and thus provision of services such as online courses to, or subscriptions by such persons to CoUM communications/mail outs will be governed by the General Data Protection Regulation (GDPR) of the EU. CoUM delivers services to persons located in the EU/UK in accordance with such laws and regulations.

(d)
By using our services you consent to the collection, storage, use and disclosure of your personal information in accordance with this Information Handling and Privacy Policy.

2. Collection of Your Personal Information

2.1. What kind of personal information does CoUM collect?

(a)
If you are a student member or have in the past been a student member, or enrolled to attend one of CoUM’s courses or programs, the personal information that CoUM holds about you may include:

Your name, address, telephone number and email contact details;
Your gender, date of birth and marital status;
Your billing details;
Details of courses that you have attended and other purchases that you have made on this website, including the date and amounts paid etc.

(b) 
In addition, where a customer provides CoUM with information about another person, or where another person is designated as a contact person for or to act on behalf of a customer, CoUM may hold that person’s information.

(c)
CoUM does not store financial information such as credit card numbers or personal information such as social security numbers on this website or in any of its administrative records.

2.2. Does CoUM collect sensitive information?

(a) 
CoUM may be required to collect and hold sensitive personal information. For example, if you have disclosed that you have previously suffered from a medical condition, CoUM will collect and hold that information.

2.3. Children and minors

(a)
Our online services are not directed at children under the age of 13 years. If you believe we have collected information about a child under the age of 13, we ask that you please contact us so that we may take appropriate steps to delete such information. If you are at least 13 years of age but under the age of 18 years, please get the consent of your parent or legal guardian before giving us any personal information about yourself on this site.

3. How does CoUM collect personal information?

3.1. How we collect personal information.

(a)
CoUM may collect personal information from you in a range of ways, including:

When you complete an application form or another type of form in relation to CoUM’s services;
When you enrol in or participate in a course.

(b)
CoUM will always try to collect your personal information directly from you. However there may be instances where CoUM will need to collect your information from other persons or entities.

(c)
If you have provided CoUM with information about another person, then you are required to tell that person that you have done so, that they have a right to access their information, and that they can refer to this page for information on how CoUM will handle their personal information, including their rights to request corrections to, or removal of, their information on our database.

3.2. If you do not provide CoUM with your personal information.

(a)
You always have the right to choose to provide CoUM with your personal information, or not. If you do not provide CoUM with the personal information that CoUM reasonably requests, we may be unable to provide you with the services that you are requesting.

4. Use and Disclosure of Your Personal Information

4.1. How does CoUM use your personal information?

(a)
CoUM uses your personal information to provide, manage and administer our services to you and operate an efficient business.

(b)
In addition, CoUM may use your information to:

contact you on any matter in relation to you or the services provided to you;
identify whether you are eligible for enrolment in a course offered by CoUM;
contact you in relation to course programs;
answer your enquiries and deliver customer service to you;
carry out internal functions including administration, training, accounting and information technology management;
evaluate our products and services;
administer and resolve complaints;
conduct customer research and analysis;
comply with laws and regulations.

4.2. Direct Marketing

(a)
We are committed to delivering the highest quality programs and courses designed to assist people’s health and wellbeing and understanding of the Ancient Wisdom.

(b)
If you have provided your contact information to us and opted into receiving communications from us, CoUM will from time to time contact you with information about our products or services. When we contact you it will usually be by email; occasionally it may be by telephone. After you have subscribed to any of our services, if you do not wish to receive any further marketing material from us, you can contact us at any time to let us know, and we will cease contacting you with such marketing material as you have requested us to cease. Our contact details are at the end of this page. To unsubscribe, you may also click the ‘unsubscribe’ link at the bottom of any of our newsletters.

(c)
If you request us not to contact you with marketing material, and you are a student registered with CoUM, please note that we will still contact you in relation to our on-going relationship with you as a student, unless you request that we remove your information from our contact list, in which case we will do so.

(d)
If you subscribe to any of our services and/or otherwise consent to us contacting you, we will never share, transfer, lease, rent or sell your details with or to anyone else without your consent, or cross-pollinate marketing activities across platforms without your consent. For instance, if you consent to receiving marketing material or newsletters from us via email, we will not contact you via another platform such as facebook.

4.3. Who does CoUM disclose your personal information to?

(a)
In the course of conducting our business and providing our services to you including without limitation educational courses, CoUM may disclose your information to course providers who present course(s) on behalf of CoUM.

(b)
In addition, CoUM may be required to disclose your information to third parties in the course of providing, managing and administering our services. This may include disclosure to the following people in the following circumstances:

any people employed or contracted by or volunteering their services to CoUM as CoUM team/staff members or acting on behalf of CoUM in relation to our services;
government and regulatory agencies;
any person acting on your behalf;
lawyers, auditors and/or other advisors engaged by CoUM or acting on CoUM’s behalf;
where disclosure is required by law;
where disclosure is reasonably necessary to prevent a threat to the life or health of any individual or prevent the commission of a serious crime.

4.4. How does CoUM store personal information and for how long?

(a)
CoUM will take all reasonable steps to ensure that your personal information is stored securely and is protected from misuse and loss from unauthorised access, modification or disclosure. This includes a range of systems and communications security measures, as well as the secure storage of hard copy documents. In addition, access to your personal information will be restricted to people properly authorised to have access.

(b)
CoUM will keep your personal information for as long as it is required to provide you with the services you requested from us and to comply with legal requirements.

(c)
If CoUM no longer requires your personal information for any purpose, including legal purposes, we will take reasonable steps to securely destroy or de-identify your personal information.

5. Rights relating to Personal Information

5.1. What rights do you have in relation to your personal information?

(a)
You have rights in relation to your information, which are important to us. These include:

the right to be informed, the right of access to your personal information, and the right to rectification or correction of your personal information (e.g. if it contains errors or needs to be updated)
the right to be forgotten (i.e. to have your data erased)
the right to data portability (i.e. the right to receive the personal data in a commonly used and machine readable format, and the right to transmit that data to another online service provider)
the right to restrict processing, the right to object, and the right to not be subject to automated decision-making including profiling.

You can contact us about any of your rights at any time and we welcome your enquiry. Please use the Contact page on our website.

6. Accessing and Correcting Your Personal Information

6.1. Can you access your personal information?

(a)
You can ask CoUM for access to the information that we hold about you at any time. Simply contact CoUM to make your request. (Our contact details are on the ‘Contact Us’ page of our website.) However in some cases we may be unable to give you access to certain information. For instance we will be unable to do so where:

we no longer hold the information;
providing access would have an unreasonable impact on the privacy of others;
the request is vexatious;
the information relates to existing or anticipated legal proceedings;
providing access would be unlawful;
denying access is mandated by law;
providing access would prejudice or be likely to prejudice the prevention, detection, investigation and prosecution of unlawful activity;
the information would involve the disclosure of commercially sensitive information; or
disclosure would pose a threat to the life or health of any individual.

6.2. Correcting your personal information

(a) 
To enable CoUM to provide you with the best possible service, it is important that the information that we hold about you is accurate.

(b)
CoUM will take reasonable steps to ensure that your information is accurate, complete and up to date. However it is your responsibility to notify us when your details change.

(c)
If you believe any information that we hold about you is inaccurate, incomplete or out of date, you should contact us and we will amend your records.

7. Security

7.1. Security of your personal information

(a)
We will take all reasonable steps to ensure that your personal information is stored securely and protected from misuse and loss and from unauthorised access, modification or disclosure. Only properly authorised staff may access personal information and all such staff are required to respect the privacy of personal information that they are handling. Authorised access to personal and sensitive information is conducted within a ‘need to know’ principle. Personal/sensitive information is only accessed by those staff members who need it to carry out their duties.

(b)
We have an ongoing commitment to periodically brief staff on their obligations and responsibilities with digital security and to ensure they are made aware of the best practices for use of common technologies like email and video conferencing. We provide a copy of this policy to staff and keep them updated on changes.

8. Withdrawing your consent

8.1. Withdrawal of consent or unsubscribing

(a)
If you have registered with CoUM as a student and/or subscribed to any of our mail outs, you may withdraw your consent to communications from us at any time, by contacting us via the contact page on our website. This website also gives users the option to update, correct, or remove their information from our database, and the option not to receive future communications.

8.2. Erasure of data

(a)
You are welcome to request that we erase your data, at any time. If we receive a request from you to erase data, this request will be processed by us within 14 days of receipt of the request. On completion of your request, we will issue confirmation to you that the data has been erased.

9. Your Privacy Online

9.1. Online data collection and use

(a) 
The information handling processes outlined above also relate to any personal information collected online via this website.

(b)
When you access this website, anonymous technical information may be collected about user activities on the website. This may include information such as the type of browser that you were using to access this website and the pages visited. This information is used by CoUM to troubleshoot server issues, and make decisions about maintaining and improving the website and online services. This information remains anonymous and is not linked in any way to personal identifying information.

9.2. Cookies

(a)
CoUM uses ‘cookies’ to collect data to help us determine which pages are most popular, peak usage times and other information which helps us make our website easier and more efficient for you to use. When you visit our website we may set a cookie on your machine so that when you next visit our website it links to your personal information that is stored on our system.

(b)
You can choose if and how a cookie will be accepted by configuring your preferences and options in your browser. However if you decided not to display cookies then you may not be able to gain access to all the content and facilities on this website.

9.3. Linked sites

(a)
This website may be linked to third party sites. CoUM is not responsible for the privacy practices or the content of third party sites. You should check the privacy policy of any third party site you visit, including how it may be amended from time to time.

10. Resolving any Concerns or Complaints

(a)
You can contact us at any time if you have any questions, concerns or complaints about anything on this page or about how your personal information has been or will be handled.

(b)
You can contact us via the contact form on this website.

(c)
If you have a complaint, and after contacting us you are still not happy with our response, or you do not feel that your complaint has been properly resolved, you can seek advice from the Office of the Australian Information Commissioner by calling (toll free) 1300 363 992. If you are located in the UK or EU you can contact the Information Commissioner’s Office on 0303 123 1113. If you are located elsewhere, please contact us and we will do our best to assist you to locate your local information commissioner/authority.

11. Amendment of this policy

(a)
We may amend this policy from time to time. Any amended form of this policy will be updated on our website, and we will include the date at which the policy was updated at the top of the policy page. We encourage you to check back to this page to see amendments.