Effective: 4 May 2020
view previous version

Please read this privacy policy carefully before using the Enquiry Tracker Service or accessing the Enquiry Tracker Website.

Enquiry Tracker Pty. Ltd. ABN: 41 622 948 734 (‘we’, ‘our’ and ‘us’) regards personal privacy as an important part of our relationship with users of our products and services.

This Privacy Policy describes what information we collect about you, how we collect, store, use and disclose that information, and what choices you have with respect to the information.

In this Policy we refer to Service, Organisations, Users, Enquirers and other terms for those who access or use our Service; if you are not familiar with these and others terms we use in this Policy, please review our Terms of Use.

If you do not agree with our Terms of Use and this Policy, do not access or use the Service, our Website or interact with any aspect of our business.

Information collected

Enquiry Tracker Website and communications with us

  • Information you submit. We collect personal and other information you provide directly to us or submit via our Website, including when you complete forms on our Website, such as to contact us, request a demonstration of the Enquiry Tracker Service, register for a webinar or to access other content made available on our Website, or sign up to the Enquiry Tracker Service. This may include your name, details about the Organisation you are contacting us on behalf (name, phone number, physical address, size and demographic), your position within the Organisation, and your contact details (email address and phone number).
  • Cookies and similar technologies. We use Cookies and similar technologies to collect some information about your visit to our Website and use of the Enquiry Tracker Service that helps us provide a basic service and improve our features. For more information, please see our Cookie Policy.

Enquiry Tracker Service – Organisation & User Information

Where an Organisation has signed up to the Enquiry Tracker Service, we collect the following information about the Organisation, its Users and the use of the Service:

  • Enquiry Tracker Organisation Account Information. Information about the Organisation to set up and administer the Organisation’s account, including organisation name and corporate details, logo, organisation contact information including phone number and address (physical and website URL), and personal information about the nominated school representative (including name and email address).
  • User Request Information. The Service requires basic personal information about prospective Users in order for the Organisation to invite the individual to access the Enquiry Tracker Service. This includes the person’s name, job title and email address(es).
  • User Enquiry Tracker Account Information. Where a User registers to access the Service, the Service collects personal information about the individual, including their name, job title and email address(es), as well as user credentials (username and password).
  • Information provided through our Assistance services. Our Assistance services include technical support and optional data upload and download, where you may choose to submit information to us, including personal information. Where you engage with our technical support team or other personnel for Assistance services, whether by email or speaking to one of our representatives directly, you will be asked to provide contact and User information, as well as other information that would enable us to provide the relevant Assistance services.
  • Usage Information. We collect usage information in regard to any User activity related to our Service, such as the IP address from which you access the Service, date and time, information about your browser, operating system and computer or device, pages viewed and items clicked. We may also collect location information, including location information automatically provided by your computer or device. We also log all information about what has changed including, emails, changes, and communications.

Enquiry Tracker Service – Information collected from Enquirers

One of the core purposes of the Enquiry Tracker Service is to help Organisations track prospective students and understand the profile of their potential future student population. Our Service achieves this by allowing an Organisation to collect, store, access and use information obtained from Enquirers. This information is not collected by Enquiry Tracker itself, but is held in our Service in an ‘Enquirer Profile’. This may include the following personal and other information about the Enquirer and those they are responsible for (e.g. their child and other family members):

  • Identity Information. An individual’s name, location, date of birth, nationality, family details and other information that allows identification of the individual.
  • Contact Information. An individual’s email address, phone number, physical address and other information that allows the Organisation to contact the individual.
  • Other Information requested by Organisations. Any other information that an Organisation requests from an Enquirer (including via WebForms that are prepared and implemented by the Organisation and issued using the Service), as part of the Organisation tracking and understanding the profile of prospective students and their families or guardians. This may include sensitive or other personal information such as an individual’s race, ethnicity, religion, employment status, job title and school affiliation.
  • Other Information provided by Enquirers. Any additional information an Enquirer chooses to provide in the Service or to the Organisation.

The Organisation is responsible for how it collects, stores, uses and discloses personal and other information, including via the Service, and these activities are governed by the relevant Organisation’s privacy policies. If you are an Enquirer and have any concerns or queries in relation to what information is stored in the Service about you, or how the Organisation is using that information, you should contact the Organisation.

How we use information

Use of information other than Enquirer Profiles

We use personal information we hold, other than information in an Enquirer Profile stored within the Service, for the following purposes:

  • To communicate with you, including responding to your queries submitted via our Website or directly to us by email, phone or other means and sending you Service notifications via email or through the Service, such as account setup confirmations, subscription renewals, billing reminders, notices of upcoming scheduled outages or Service issues or any other notice under our Terms of Use.
  • To provide our products and services to you (including the Enquiry Tracker Service and associated Assistance), including to process transactions with you, authenticate you when you log in or request support, provide training and support, and operate, maintain, administer, personalise and improve the products and services.
  • To market our products and services to you (whether you are a prospective, current or past client of ours), including notifying you of new features within the Service or new products and services, conducting market research and surveys, issuing newsletters and inviting you to upcoming events that may be of interest to you[, however we do not use personal information in an Enquirer Profile in the Enquiry Tracker Service for this purpose]. You may opt out or unsubscribe from receiving marketing communications from us as discussed in the ‘Accessing and Correcting your Personal Information’ section of this Policy.
  • For research and development, including analysing trends, monitoring usage or traffic patterns (including to track users’ movements around the Services) and use collective learnings (including feedback) to troubleshoot, identify areas for further integration and to otherwise optimise and improve our Service and to develop new features, technologies, products and services to benefit our existing and future clients. This includes collecting, developing, creating, extracting, compiling, synthesising, analysing and commercialising statistics, benchmarks, measures and other information based on your use of the Service and ‘Aggregated Data’ (being data from the Service that is (i) anonymised and not identifiable to any person or entity; (ii) combined with the data of other Organisations or additional data sources; and (iii) presented in a way which does not reveal your identity).
  • For security purposes, including verifying your identity and your account activity, and to detect, prevent, and respond to potential or actual security incidents or breaches of our Terms of Use.
  • To enforce our legal rights and protect our legitimate business interests, including using information to investigate complaints about or made by an individual, to enforce our Terms of Use and take other legal action if we have reason to suspect that a User or Organisation is in breach of our Terms of Use or has otherwise engaged in any fraudulent, deceptive or unlawful activity (in which case we may be required disclose that information to a governmental authority), for legal and regulatory audit and compliance purposes and disclosures in connection with the merger or sale of our business or assets.
  • Otherwise with your consent, where you give us consent to use your information for a specific purpose not listed above.

Use of Enquirer Profiles within the Service

We will never use personal information in an Enquirer Profile stored in the Service for any purposes other than to:

  • store, host, back up, export and make the information available to the Organisation and its authorised Users, or other individuals authorised by those User;
  • facilitate communications between Enquirers, Users, Organisations and Enquiry Tracker (including email, phone and Live Chat from the Website);
  • provide technical support and other Assistance to an Organisation and its Users (including uploading data into the Service or exporting it out of a Service on behalf of an Organisation);
  • monitor, develop and improve the Service;
  • permanently delete the information from the Service in accordance with our Terms of Use;
  • create and use Aggregated Data (as defined above); and
  • enforce our legal rights and protect our legitimate business interests.

Storage and Security of Personal Information

We, and our third party hosting providers maintain a variety of appropriate technical and organisational security measures designed to protect personal information from unauthorised access, destruction, use, modification or disclosure. Despite this, the security of online transactions and the security of communications sent by electronic means or by post cannot be guaranteed.

We use the Google Cloud Platform to host the Service and to store and process information entered into or collected by our Service. Our Security Policy, as updated from time to time, provides further information on the security measures for our Service. Our Service is User controlled and will retain personal information until an Organisation’s User uses the functionality in the Service to delete the information, or the Organisation’s subscription to the Service ends, in which case the information in the System for that Organisation will be deleted within a reasonable period of time. Users can choose to permanently delete personal information and other information in an Enquirer Profile at any time. It is the responsibility of the Organisation to delete personal information if it is no longer entitled to retain the personal information.

We also use other third-party systems to run our business and communicate with individuals, including our customer relationship management, marketing automation, accounting, email and analytics systems. These systems may be located in Australia or elsewhere, including the United States of America. We ensure only the minimum relevant personal information is stored in such systems.

Sharing of personal information

[We will not sell your personal information to third parties under any circumstances.]

Personal information may be accessed by our trusted third party service providers that help us to host, develop, provide, improve, support and market our Website, Service and Assistance and provide us with systems used to operate our business. These service providers may be located in Australia or elsewhere.
Where an Organisation has subscribed for the Service via a Reseller, we share personal information with that Reseller to allow administration of the Organisation’s account and billing.

We may share or transfer personal information in connection with any merger or sale of all or part of our assets or business. Where we transfer your personal information to a new owner of the business or our assets, we will take steps to ensure that the new owner has privacy policies reasonably consistent with this policy.

We may also share personal information where we believe that this is necessary to comply with laws or regulations, or to enforce our Terms of Use and Policies.

We take appropriate steps aimed to protect any personal information we share, including where we transfer this outside of Australia.

Third Party Links and Content

Our Website may contain links to sites operated by third parties. Our Service also relies on certain Third Party Content (as described in our Terms of Use) and may provide you the ability to integrate or access and use other Third Party Content with the Service. We will allow the third party providers of Third Party Content to access or use your personal information as required for the interoperation of their products and services with the Service. This may include transmitting, transferring, modifying or deleting personal information, or storing personal information on systems belonging to the third party providers or other third parties.

We are not responsible for the privacy or security practices of any third party (including third parties that we are permitted to disclose an individual’s personal information to in accordance with this policy or any applicable laws). The collection and use of an individual’s information by such third parties may be subject to separate privacy and security policies, which you should review before accessing and using their sites and services.

Data Breach Policy

If an individual suspects any misuse or loss of, or unauthorised access to their personal information, they should let us know immediately (by contacting us via the contact details in the ‘Contacting Us’ section of this Policy).
If we become aware of any unauthorised access to an individual’s personal information held in the Service, we will inform the Organisation at the earliest opportunity as per our Data Breach Policy.

Accessing and correcting your Personal Information

We take reasonable steps to ensure the personal information that we hold is accurate, complete and up-to-date, and may contact you from time to time for this purpose.

You may request a copy of the information that we hold, or to change it where you believe that is out of doubt, incomplete or inaccurate. You may also request that we delete your personal information where we no longer have a legitimate reason to hold it. You may do this by submitting your request in writing to the contact details in the ‘Contacting Us’ section of this Policy; however if you are a (i) User or Enquirer and your request relates to information held in the Service, you should contact the applicable Organisation in the first instance, as outlined in the ‘Notice to Users and Enquirers’ section below; or (ii) an Organisation and your request relates to changing or deleting information held in your account in the Service, you may do this by logging into the Service and accessing existing functionality within the Service. There is no fee for your request, and we will endeavour to resolve all requests within a reasonable time.

Opting out or unsubscribing

You may opt out of receiving marketing communications from us by clicking on the unsubscribe link in each email or by contacting us in writing via the contact details in the ‘Contacting Us’ section of this Policy and asking to be removed from our mailing list for the relevant communications.

Notice to Users and Enquirers

The Service is intended for use by Organisations, who administer the sites and information stored within the Service that relate to that Organisation, its Users and Enquirers. We are not responsible for the privacy or security practices of an Organisation, which may differ from this Policy.

  • Users. Where an Organisation (including another User) has made the Service available to you, that Organisation is the administrator of the Service and is responsible for the User accounts and other information about you that is stored in the Service. Please direct your enquiries about your personal information to your Organisation as your use of the Service is subject to their policies. [You may also use the Service to access and update certain information about you that is held in the System, including the profile information and user credentials associated with your User account.]
  • Enquirers. The Organisation you engaged or interacted with is responsible for how it collects, stores, uses and discloses your personal and other information, including where you have submitted information into the Service via a web form made available by the Organisation, or the Organisation has submitted information about you into the Service. These activities are governed by the relevant Organisation’s privacy policies. If you want to access or correct your personal information, or have any concerns or queries in relation to what information is stored in the Service about you, or how the Organisation is using that information, you should contact the relevant Organisation. You should also contact that Organisation if you want to opt-out or unsubscribe from receiving communications from the Organisation or the Service.

Complaints

If you have a complaint about our handling of your personal information, you should submit it in writing to the contact details in the ‘Contacting Us’ section of this Policy. We will review all complaints and endeavour to respond to you within a reasonable time.

Changes to this Policy

We may change our Privacy Policy from time to time. If we make changes, we will post them on our Website and will indicate on this page the policy’s new effective date. If there are material changes to this Privacy Policy we will send an email and/or provide in-app notifications. For Organisations with an active subscription to the Service, please refer to the Terms of Use for when a change to this Privacy Policy comes into effect for you, and your rights in relation to that change. For all other individuals, you agree to the changes where you continue to access our Website or communicate with us.

Contacting Us

All correspondence with regards to privacy and security should be addressed to:
The Data Protection Department
Enquiry Tracker Pty. Ltd.
P.O. Box 182
Malvern VIC 3144
Australia

Email: [email protected]

You may contact the Data Protection Department by email in the first instance.