Privacy Policy

The cyberpathways.com.au website (Website) is owned and operated by Skilligence Pty Ltd (ACN 600 600 164) of Suite 6, 19 Lang Parade, Milton QLD 4064. The terms “CyberPathways”, “we”, “us” or “our” refer to Skilligence Pty Ltd or related body corporate providing the services described below.

We operate a business to provide education and training via non-accredited and accredited pathways for teens and adults to protect businesses and individuals, upskill and train to reduce inherent human vulnerabilities against cyberattacks (Services).

This privacy policy sets out the terms upon which Skilligence Group will process any personal information that is collected through:
• the Website;
• any software and mobile application (Software) made available by us;
• from industry partners, contractors to the Skilligence Group;
• by telephone, email or other physical medium (such as a referral or form), including from you directly.

This privacy policy applies to your use of the Website, the Software or any of the Services or products accessible to you, unless you are accessing our Services via a third-party platform owned or operated by a third-party site, in which case a separate privacy policy or terms of use may apply when using that site.

We reserve the right, at our discretion, to modify or remove portions of this policy or these terms at any time. We do not make any representations about third-party web sites that may be linked to our Website.

How our Services Work
We operate independently and offer our Services mainly to educational intuitions, students, for which we may charge a fee. We do so as a service provider and not as an agent for any party.

We recognise the importance of protecting the privacy of information collected, in particular, information that is capable of identifying an individual (personal information). Should we ask you to provide any information by which you can be identified, we assure you that it will only be used in accordance with these terms and the Australian Privacy Principles.

By proceeding to use our Website, Services or other products recommended by us, you consent that we may process the personal information (including sensitive personal information) that we collect from you in accordance with these terms.
Our terms may be updated from time to time and should be reviewed periodically so that you are updated on any changes. If you think our terms fall short of your expectations or that we are failing to abide by our policy, do please tell us. Your continued use of the Website, Software or our services following any changes indicates that you accept the changes.
Except as set out below, we do not share, or sell, or disclose to a third party, any personally identifiable information collected by us.

The information we may collect includes:
• names, addresses, e-mail addresses and phone numbers and other registration information, financial information, personal description photographs, gender, employment and contact information;
• location information;
• details of your existing education institution, course of study, teachers or other students;
• web page access analytics;
• program and course attendee registration data;
• data associated with your learning, including, but not limited to progress and activity summaries (Learning Data);
• credit or debit card payment information;
• information from a third party (relevant person) given to us in the course of our business, specifically to enable you to buy or participate in a service or products offered to you;
• other information relevant to the customisation of a document or provision of the services;
• information you send to us by use of our Website, a third-party site, by email, by telephone or by other physical medium.
We may receive personal information from third parties. If we do, we will protect it as set out in these terms.
You can refuse to provide us with your personal (sensitive) information. However, if you refuse to provide us with your personal (sensitive) information, we may not be able to provide services to you.

This information is:
• used in enrolling, teaching, examining and graduating its students;
• used to provide information to other parties in the normal course of the operation of the organisation, which may include linking to your education institution, teachers and or other students and in some cases sharing Learning Data;
• used to register and administer events, promotions or competitions,
• used for verifying your identity for security purposes;
• provided to a third party for the purpose of jointly running a program, course, event or activity;
• used for internal record keeping; and
• used to carry out administrative functions such as billing or keeping you informed of events.
Information which does not identify any individual may be used in a general way by us or third parties to provide class information, for example relating to demographics or usage of a particular page or Service.
We may log information about your access and use of our Website, including through the use of Internet cookies and measurement tools, your communications with our Website, the type of browser you are using, the type of operating system you are using and the domain name of your Internet service provider. We do not presently associate such information with an identifiable person. Our Cookie Policy can be viewed here (hyperlink to cookie page)
We may contact you by a variety of measures including by telephone, email, sms or mail. If you wish to update your contact details or change the way we contact you, please contact us at the details below.

Disclosure of personal information
We may disclose personal information including:
• for the purpose of providing information, products and services listed above;
• to verify personal information details upon request from third parties;
• to comply with our legal and regulatory obligations, including disclosure and reporting to Commonwealth, State and Territory government agencies;
• to third parties, for the purposes of enhancing and assessing the student experience and providing a range of services to its staff and students including library access, health and counselling services, and recreational activities. This may include parties located, or that store data, outside of Australia;
• for users under 18, information regarding attendance, progress and general well-being may be provided in order to keep parent(s) and/or guardian(s) adequately informed. If you are under 18, you may use our site only with consent from a parent or guardian;
• to credit reporting agencies and courts, tribunals, regulatory authorities where clients fail to pay for services provided by us to them;
• to courts, tribunals, regulatory authorities, and law enforcement officers as required by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights;

By providing us with personal information, you consent to this disclosure. Where we disclose your personal information to third parties, we will request or otherwise seek to get comfortable that the third-party follows the Australian Privacy Principles regarding handling your personal information. However, if you provide information to us with a view to it being read, copied, downloaded or used by other people, we accept no responsibility for what that third party may do with it. It is up to you to satisfy yourself about the privacy level of every person who might see your information. If it is available to all the world, you have no control whatever as to how it is used.
If there is a change of control of our business or a sale or transfer of business assets, we reserve the right to transfer to the extent permissible at law, our user databases, together with any personal information and non-personal information contained in those databases. This information may be disclosed to a potential purchaser. We would seek to only disclose information in good faith and where we have sought to maintain confidentiality.
We do not typically or routinely disclose personal information to overseas recipients unless consent has been given, or an exception under the Australian Privacy Principles applies. We will only disclose personal information to overseas recipients where reasonable steps have been taken to ensure the overseas recipient does not breach the Australian Privacy Principles in relation to your personal information. In circumstances where information is disclosed to overseas recipients, those recipients are likely to be located in countries in the regions in which we operate.
We are committed to ensuring that the information you provide to us is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure that information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.
No information transmitted over the Internet can be guaranteed to be secure. We cannot guarantee the security of any information that you transmit to us or receive from us. The transmission and exchange of information is carried out at your own risk. Although we take measures to safeguard against unauthorised disclosures of information, we cannot assure you that personal information that we collect will not be disclosed in a manner that is inconsistent with these Terms of Use.

Financial information relating to your credit / debit cards
We may collect billing and account information for credit cards, payment cards or other payment systems from clients of paid versions of our Service and share this information with our billing and payment processors. We do not store credit card or payment card numbers after they have been forwarded to our billing and payment processors.
This information is sometimes taken by us either through our Website or Software. If you are accessing our Services or a Product made available through a third-party hosting site, you should satisfy yourself as to the security of that site as that site it is not controlled by us.
When you have agreed to set up a direct debit arrangement, the information you have given to us is passed to our own bank for processing per our instructions. We do keep a copy.

Complaining
When we receive a complaint, we record all the information you have given to us. We use that information to resolve your complaint. If your complaint reasonably requires us to contact some other person, we may decide to give to that other person some of the information contained in your complaint. We do this as infrequently as possible, but it is a matter for our sole discretion as to whether we do give information, and, if we do, what that information is.
We may also compile statistics showing information obtained from this source to assess the level of service we provide, but not in a way that could identify you or any other person.
The Skilligence Group will manage the process of dealing with an actual or suspected breach in accordance with its Data Breach and Response Plan. You may obtain a copy of this plan, apply to access personal information or to seek correction of personal information held by us by contacting the Privacy Officer at [email protected]

Removal of your information
If you wish us to remove personally identifiable information from our web site, you may contact the Privacy Officer at [email protected] . To better safeguard your information, we will also take reasonable steps to verify your identity before granting access or making corrections to your information.

Data may be “processed” outside Australia
While our Website is hosted in Australia, other sites or platform-based Services are often hosted abroad. Accordingly, data obtained within Australia may be “processed” outside Australia and data obtained in any other country may be processed within or outside that country.

Complaints procedure
• If you have a complaint about how we have collected or handled your personal information, please contact us. We will endeavour in the first instance to deal with your complaint and take action to resolve the matter.
• If your complaint cannot be resolved at the first instance, we will ask you to lodge a formal complaint in writing, explaining the circumstances of the matter that you are complaining about, how you believe your privacy has been interfered with and how you believe your complaint should be resolved.
• We will acknowledge receipt of your formal complaint and indicate the timeframe in which you can expect a response. We will endeavour to resolve the complaint as quickly as possible, but if the matter is complex and our investigation may take longer, we will let you know when we expect to provide our response.
• If you are unhappy with our response, you may refer your complaint to the Office of the Australian Information Commissioner.
• For more information about privacy issues in Australia and protecting your privacy, visit Office of the Information Commissioner’s web site: www.oaic.gov.au

If you have any questions regarding this privacy policy, please contact us through the Privacy Officer at [email protected]

Limitation of liability
Skilligence Group shall not be liable in contract (including under any indemnity), tort (including in negligence or for breach of statutory duty) or otherwise, for:
a. any loss of profit, loss of revenue, loss of business, loss of contracts or loss of anticipated savings, loss of property, alternative accommodation costs, costs of delay, lost data, or any indirect, incidental, special, exemplary, punitive or consequential damages related to or otherwise resulting from any use of the Website and/or the provision of the Services, even if we have been advised of the possibility of such damages;
b. any damages, liability or losses arising out of: (i) your use of, or reliance on, the Services, or your inability to access or use the Services; or (ii) any transaction or relationship between you and any third-party provider, even if we have been advised of the possibility of such damages;
c. any delay or failure in performance resulting from the provision of the Services.
d. The limitations of liability do not purport to limit liability or alter your rights as a consumer that cannot be excluded under applicable law. To the extent you have a statutory right under Australian Consumer Laws which cannot be excluded by these Terms of Use and:
e. For any minor problems with the Service provided by us which falls short of the contracted obligations to you, we will use reasonable endeavours (at our discretion) to resolve this to your reasonable satisfaction; and
f. To the extent you have a major problem the Services provided directly by us, we will use reasonable endeavours (at our discretion) to resolve this to your reasonable satisfaction but in all cases your sole remedy will be to reperformance of the Services, to receive compensation for the drop-in value in the Services received below the price paid, or a full refund.

How you can contact us
Emailing Privacy Officer at [email protected]
Sending a letter: Attn: Privacy Officer, Skilligence Pty Ltd ACN 600 600 164 of Suite 6, 19 Lang Parade, Milton QLD 4064

Last updated: May 2023