Privacy Policy

Definitions
In this Privacy Policy (Privacy Policy), the following words have the meanings set out below:

Content means any text, graphics, user interfaces, visual interfaces, photographs, trade marks, logos, sounds, music, artwork, computer code and other material used, displayed or available on the Website.

Organisation Profile means the profile created by organisations using the Website to advertise opportunities, products and services for graduates, whether through registration on the Website or through importation of profile information via a third party log-in provider such as (but not limited to) Google, Facebook, Yahoo or Hotmail.

GradConnection Contact Details means the following:
(a) Address: Level 14, 100 Pacific Highway, North Sydney, 2060
(b) Telephone: 13 64 34
(c) Email: [email protected]

Graduates refers to graduate Users of the Website.

Graduate Profile means the profile created by a Graduate in order to access the Services available through the Website, whether through completion of a registration form on the Website or through importation of profile information via a third party log-in provider such as (but not limited to) Google, Facebook, Yahoo or Hotmail.

Group means Gradconnection Pty Ltd (ACN 131 597 932) and its related bodies corporate, as defined in the Australian Corporations Act 2001 (Cth). Organisations means organisations that use the Website to advertise opportunities (such as employment or internship positions or courses) or other products or services for graduates.

Personal Information means information that identifies an individual or could reasonably identify an individual, including facts and opinions, whether they are true or not.

Privacy Laws means the applicable privacy and data protection laws as may be in force from time to time in a particular jurisdiction which regulates the collection, use, disclosure, storage of and granting of access rights to Personal Information, including without limitation the Australian Privacy Act 1988 (Cth) and the New Zealand Privacy Act 2020, in each case as may be amended or superseded from time to time.

Registered User means any User that has completed the registration or log-in requirements to create a Graduate Profile or an Organisation Profile. Related Businesses means any 'subsidiary', 'holding company', 'related body corporate' or “related entity” (as defined in the Australian Corporations Act 2001 (Cth)) of GradConnection Pty Ltd (ACN 131 597 932).

Sensitive Information means certain categories of Personal Information as defined under applicable Privacy Laws that may include information or opinion about an individual’s racial or ethnic origin, political opinion or associations, religious beliefs, trade union memberships or associations, sexual orientation, criminal record including any proceedings for any offence committed or alleged to have been committed by such individual (including the disposal or result of such proceedings), health and genetic information, or government-issued identification, provided the information or opinion otherwise meets the definition of Personal Information.

Services means the products, services, information and resources provided by us to Users through the Website or otherwise.

Third Party Websites means websites which are not owned or controlled by us. User, or you means any user of the Website and any other users (as applicable) who otherwise engage with us and/or utilise our products, services or information (and/or any entity on behalf of whom they are acting).

We, or us, or our (and related terms) means the Group unless otherwise stated and includes a reference to any of our businesses which operate under the GradConnection brand in Australia and New Zealand.

Website means au.gradconnection.com and/or nz.gradconnection.com, as the context requires.
General
1. By registering and creating an account with us, using our Services, visiting, accessing, viewing, browsing or using our Website in any manner or simply engaging with us over the phone, via email, in person or by any other means, the terms contained in this Privacy Policy will apply to you. You confirm that you have read and understood this Privacy Policy, you have the capacity to be bound by this Privacy Policy, and you agree to be bound by it.
2. This Privacy Policy covers our businesses which operate under the GradConnection brand in Australia and New Zealand. We may modify this Privacy Policy at any time. You should review this Privacy Policy periodically so that you are updated on any changes. In some circumstances, depending on the nature of the changes, you will be notified of the changes to this Privacy Policy prior to them taking effect if required to do so under applicable Privacy Laws. Your continued use of the Website will be deemed as acceptance of this Privacy Policy by you.
3. We respect the privacy of your Personal Information.
4. Any Personal Information collected from you will be used by us in accordance with and as described in this Privacy Policy.
5. Any non-personal information you send to us through the Website (including by way of the blog or forums), such as questions, comments, or suggestions, is not encrypted, nor will it be treated as confidential. You agree that you have provided a non-exclusive, perpetual, royalty free licence to us to use the non-personal information you upload to our Website for any purpose whatsoever.
6. You agree that we may disclose any information we, in our absolute discretion, consider we are required to disclose in order to satisfy any applicable rule of law, regulation, legal process or government request.
What Personal Information do we collect?
1. Personal Information that we may collect includes information you have provided to us when:
  i. registering with us and/or setting up your Graduate Profile or Organisation Profile, whether through completion of a registration form on the Website or through importation of profile information via a third party log-in provider such as (but not limited to) Google, Facebook, Yahoo or Hotmail; i
  i. you use any of our products and services (including when you communicate with us);
  iii. applying for specific graduate positions depending on the Organisation, we may collect additional Personal Information from you on behalf of the Organisation, such as any Personal Information that you may include within a resume or cover letters or in response to role requirement questions or selection criteria; or
  iv. otherwise visiting or using the Website.
2. This type of information includes, but is not limited to, your:
  i. contact details, for example, your name, address, phone number, email address and location; and
  ii. general and background information, for example, you may elect to disclose to us your résumé, work experience, educational background, language skills, other skills, professional qualifications, salary information, résumé;
  iii. university attended;
  iv. graduation date,
  v. gender, work rights and citizenship.
3. The information collected may also include the frequency with which you use the Services, the graduate positions or courses that you apply for, and any personal correspondence to us or correspondence to Organisations through the Website.
4. In most cases, we do not need to collect your Sensitive Information when you engage with us. You should not disclose any Sensitive Information to us which is not necessary or relevant to disclose. Graduates should be especially mindful of this during a job application process. We will only collect Sensitive Information where: i. you consent to us collecting and processing your Sensitive Information by voluntarily including such information within documents and other information provided by you to an Organisation as part of a job application process or where you voluntarily include such information within your Graduate Profile; or ii. there is another legal basis permitting us to collect such information.
Collecting information on our Users
1. We collect information on Users and the websites and apps of our Related Businesses (Related Sites), including information you provide to us directly and information we collect automatically through use of software (including cookies, tags, applets, scripts and other similar technologies (referred collectively to as “cookies” below)) that is part of or placed on your browser or on your mobile device. We may also receive or collect your Personal Information from our Related Businesses and partners from time to time in accordance with this Privacy Policy, the privacy policy of those related entities and/or relevant Privacy Laws or other relevant law (as applicable).
2. IP Addresses
  Our web servers gather your IP address to assist with the diagnosis of problems or support issues with our services, and to monitor the use of our Website, including the monitoring of the location of our Users.
3. Cookies
  Data collection devices, called “cookies”, are files placed on your hard drive or mobile browser to collect information. Your browser will generally be set to automatically accept cookies. We use cookies to provide Users with a better browsing experience. These cookies collect details such as preferences and click activity for measurement and for features such as remembering your details for ‘Auto Login’ (provided you have chosen this option), and remembering your search criteria for the ‘My Last Search’ function (if applicable).
  We use this information for a variety of purposes, including to assist us in improving website performance, to customise and improve your experience of our services (e.g. by remembering your details if you have selected the ‘Auto Login’ option on one of our apps, if applicable), to analyse, develop and test our services and new functionalities, making business decisions, aiding in error reporting, aiding online payments, and to report to our advertisers and business partners on results achieved through our Services. This information may be received from or shared with our Related Businesses and partners. This is done for the purpose of providing you with improved products and services and to tailor the advertisements from any of our Related Businesses and partners that you see on the Website, Related Sites and other Third Party Websites and apps.
4. Advertising
  We also use cookies to tailor advertisements from us, our Related Businesses, our business partners and Organisations that appear on the Website, Related Sites or other Third Party Websites and apps (“Advertising Locations”) to your interests, actions and behaviour on those Advertising Locations (which may be collected through the use of cookies on those Advertising Locations), your Graduate Profile, your Organisation Profile and/or information provided as a registered user on the Advertising Locations. Advertisements may be targeted to Graduates, Organisations, or other types of visitors to those Advertising Locations.
  You can limit the use of your information for purposes of targeted display advertising by updating your browser settings to block cookies or by updating the advertising settings in the system settings of your mobile device (see “Your Preferences” below). Even if you apply to opt-out of the use of information of advertisement targeting, we will still use the information we are able to collect for other purposes as set out in this Privacy Policy, and you may still see contextual advertising that is tailored according to other content on the pages you visit.
5. Your Preferences
  If you do not wish to have cookies active whilst you browse the Website you may be able to “opt out” by modifying the privacy options in your browser. However, doing so will prevent access to some areas of the Website and limit your use of some of our products and services.
6. Third Party Measurement
  In order to better understand our users, we utilise third party measurement companies to assess Website and mobile Website traffic. A cookie is used to collect the following information on the usage of the Website:
  i. the number of page views (or page impressions) that occur on the Website;
  ii. the number of unique visitors to the Website;
  iii. how long these unique visitors (on average) spend on the Website when they do visit; and
  iv. common entry and exit points into the Website.
  For Website visitors that are not Registered Users, this aggregated information is collated and provided to us to assist in analysing the usage of the Website. For Registered Users, this information is connected across different sessions on various devices and platforms to provide a more accurate total of the number of users prior to aggregation. This data is also accessible by media organisations and research companies, for the purpose of conducting industry comparisons with other Internet websites.
Why We Collect Your Personal Information
1. Our main purpose for collecting your Personal Information is to facilitate your use of the Services. However, we may also use the information we collect for the following:
  i. to provide, maintain, protect, customise, and improve our Services;
  ii. to develop new services for you;
  iii. for analysis of site usage;
  iv. to improve the Content offered on the Website;
  v. for sending you information about your use of our Services, marketing and promotional material related to us and our Related Businesses (and you consent to our Related Businesses sending you emails and other communications for this purpose); or
  vi. for any other purpose set out in this Privacy Policy.
2. You also acknowledge and agree that in providing Services, we will provide some or all of your Personal Information to the entities who you apply for an opportunity and to the institution from which you graduated. An application is defined as clicking on the Application Buttons and/or external links which take you to the entity’s own website, external to the Website.
3. By providing your Personal Information, you agree to the use of your Personal Information in this manner. You acknowledge that we request your Personal Information as part of the process of assisting you in obtaining or accessing graduate opportunities, including finding employment and/or internships, and you agree that, in requesting this information, we are not acting in contravention of any laws or regulations relating to equal opportunity or anti-discrimination, including Australia’s and New Zealand’s Equal Opportunity Acts.
What happens if we are unable to collect your Personal Information?
1. It is important for us to process your Personal Information in order to provide our products and services to you. If you do not want your information to be processed for the purposes set out in this Privacy Policy, you may need to cease using our Website, products or services or engaging with us.
2. You can choose not to share your Personal Information with us. However, if you choose not to provide us with the necessary Personal Information, we may not be able to provide you with some or all of our products or services.
3. We also require your Personal Information to meet our legal obligations. Where the legal basis for the processing of your Personal Information is to comply with our legal obligations, a failure by you to provide us with certain Personal Information may cause us and/or you to be in breach of these legal obligations.
Disclosure of Your Information
1. We will disclose your Personal Information in the following circumstances:
  i. to Organisations when you apply to an advertisement on our Website;
  ii. to third parties such as service providers, contractors and partners from time to time for the purpose of assisting us to deliver the Services, enabling you access to the products or services they offer or conducting surveys, trials or customer research;
  iii. if required or permitted by law, including to government authorities, law enforcement agencies, regulatory bodies or competent officers which/who have legal authority to request the disclosure of Personal Information;
  iv. if we believe, in our absolute discretion, it is in the public interest;
  v. to seek feedback, or monitor, or improve quality of service;
  vi. to our Related Businesses;
  vii. in the event of a merger, acquisition or restructure, to the transferee or successor of any entity within the Group, or any prospective purchaser of any business or asset within the Group (together with its relevant advisors);
  viii. for any other purpose set out in this Privacy Policy; or
  ix. where we otherwise obtain your permission to disclose the information.
2. We may also share aggregated, non-personally identifiable information publicly, for example, to show trends about the general use of our Services.
Graduate Profiles
1. Graduate Profiles are public by default. Where you choose to allow your Graduate Profile to remain public, you consent to your Personal Information being made available to the general public, including through publicly available search engines.
2. You acknowledge that where you change your Graduate Profile from public to private or protected, we cannot control the dissemination of your Personal Information which has previously been public and that we are not responsible for the length of time it takes for a search engine to remove your Personal Information from their results.
3. Where you choose to make your Graduate Profile protected, you consent to your Personal Information being made available to your connections, our staff, potential employers, and staff from your university.
4. Where you choose to make your Graduate Profile private, you consent to your Personal Information being made available to your connections and our staff.
Applying for Opportunities
Where you choose to apply for an opportunity advertised on the Website, including by clicking the “Apply Now” button, you consent to us making your Personal Information available to the Organisation providing the opportunity, as part of the application process.
Disclosure to Overseas Recipients
1. Depending on your Graduate Profile preferences, we may disclose your Personal Information to overseas recipients, including connections and potential employers in the following countries:
  i. Australia;
  ii. New Zealand;
  iii. Hong Kong;
  iv. Singapore;
  v. United States;
  vi. United Kingdom;
  vii. China;
  viii. Malaysia;
  ix. India;
  x. South Africa;
  xi. Philippines;
  xii. Thailand;
  xiii. Indonesia.
2. You acknowledge that recipients of your Personal Information in the above and other overseas countries may not be subject to privacy laws that are similar, or equivalent to, the Privacy Laws. Where you have connections in these jurisdictions, or where your Graduate Profile is protected or private, or where we are otherwise permitted to do so under this Privacy Policy, you consent to your Personal Information being provided to recipients in these jurisdictions.
3. You also acknowledge that we may share, transfer or disclose your Personal Information outside of your home location:
  i. to our Related Businesses overseas, including without limitation Gradconnection Pty Ltd (registered in Australia), the Group entity that is responsible for hosting the Website;
  ii. to a service provider, partner or other third party who provides services to us from an overseas location; and
  iii. where we consider it necessary to comply with any legal or regulatory obligations.
Use of Email Addresses
1. If you provide us with an email address that is considered Personal Information, our use of that email address will be subject to our Privacy Policy.
2. Without limiting section 3 or anything else in this Privacy Policy, if you provide us with an email address (even if it is not considered Personal Information), you agree that we may share this information with our Related Businesses and that we and our Related Businesses may use that email address to send you information, marketing and promotional material related to us and our Related Businesses.
3. If you do not want to continue to receive marketing and promotional material from us, you may opt out of receiving this type of communication at any time by clicking the ‘unsubscribe’ link provided in the relevant communication. Please note that clicking ‘unsubscribe’ in the footer of an email will only unsubscribe you from the particular type of marketing message you have received (e.g. messages about products) and in order to opt out of receiving all marketing messages from us you will need to update your email preferences to withdraw consent to receive each type of marketing message. Opting out of emails will not opt you out of receiving SMS and vice versa. Opting out of marketing messages sent from one of our Related Businesses will not opt you out of receiving marketing messages from our other Related Businesses.
Related Bodies Corporate
1. We may also disclose your Personal Information to our Related Businesses from time to time as part of the Group’s business operations, including (1) for the purpose of research and development of products and services within the Group, (2) to manage, administer and improve our products and services, verify your identity and ensure the safety and security of our operations and (3) to protect rights of all entities within the Group, its assets, other rights and interests and personnel. This includes (but is not limited to):
  1. data enhancement and parsing to facilitate product functionality and service quality;
  2. to obtain insights about our Users and to help businesses within the Group to improve, tailor and develop their products and services (for example, by conducting trials, analytics and customer research, and by using your information within machine learning and artificial intelligence systems, and to respond to market changes and customer needs and requests);
  3. development and improvement of algorithms servicing product functionality (e.g. Search recommendations);
  4. IT security measures for the benefit of protecting customer data;
  5. data aggregation to support customer experiences, support services, and data analytics;
  6. ensuring the proper and more efficient working of the IT systems and services; and
  7. to verify your identity (and any other information you may provide to us), your accounts and activities, to detect, prevent and respond to potential or actual security incidents and to monitor and protect against other malicious, deceptive, fraudulent or illegal activities.
2. If you are a User and visit one of our Related Sites, we may track or monitor your behaviour on that site to enable us and our Related Businesses to improve and tailor the products and services offered to you including providing you with relevant content based on your online activity.
3. We may also receive Personal Information from our Related Businesses from time to time in accordance with the privacy policy of those Related Businesses and/or the Privacy Laws or other relevant law (as applicable).
Security
1. We take reasonable steps to ensure the security of our systems and to protect your Personal Information from misuse, interference and loss as well as unauthorised access, modification or disclosure. Any Personal Information which we hold is stored on secure servers and protected in controlled facilities.
2. While we limit access to your Personal Information in accordance with your choice of Graduate Profile, you agree that no transmission of data over the Internet is guaranteed as wholly secure and that any information you provide to us through the Internet, including via email, is at your own risk. You agree that, even though we use our best endeavours to secure your Personal Information, such as email encryption, we cannot guarantee that any information sent or accessed electronically is secure.
3. You must also assist us in keeping your Personal Information secure by maintaining the confidentiality of your account password and notifying us immediately if there is any unauthorised use of your account by any other Internet user, or any other breach of security relating to your account.
4. We disclose your Personal Information to third parties or their nominees in accordance with your Graduate Profile preferences. The use of your Personal Information by these third parties is not within our control and we cannot accept responsibility for the conduct of these third parties.
Links
The Website may contain links to Third Party Websites. We are not responsible for the information on these sites, or their privacy policies. We may keep track of your interaction with links provided on the Website in order to improve services and to aggregate statistics.
Accessing and Amending Personal Information

Unless you become a Registered User, we do not collect information that identifies you personally. Subject to the exceptions listed in the Privacy Laws, you have the right to access your Personal Information that is in our custody or control. If you become a Registered User, you are able to change, update or clear your Graduate Profile and account settings at any time by logging into your account.
If you wish to access Personal Information about you that is not available on or accessible from your Graduate Profile, please contact us using the GradConnection Contact Details and we will use our best endeavours to provide the information within 10 business days of receiving your request. Please note that we may charge a fee to cover the cost of meeting your request.
If we refuse your request we will provide you with reasons for our refusal within 20 business days.
From time to time your Personal Information may change. It is important that you inform us of changes to your details by keeping the information on your Graduate Profile current and by updating your Graduate Profile if you wish to continue accessing the Services we provide.
To delete data in your Graduate Profile you will need to delete your entire GradConnection account. We reserve the right to disable a Graduate Profile at its sole discretion (for example if information is found or believed to be untrue or being stored for improper purposes). Users can delete data in their Graduate Profile by:
1. Login to your account
2. Go to Settings
3. Scroll to the bottom of the page and hit the Delete Account button
4. Fill out the form and hit the Delete Account button

Complaints
If you believe that the privacy of your Personal Information is not effectively protected, or if you are concerned that your privacy has been compromised through the dissemination of your Personal Information, please contact us using the GradConnection Contact Details.

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