Cengage [Australia or New Zealand]

About this Privacy Policy

We understand and appreciate that privacy is a major concern for individuals who trust us with their personal and sensitive information, as it is for us.

This policy details our commitment to the responsible and transparent use of private information. We commit to collecting, using, storing and disclosing this information in a lawful and responsible way.

Please read this policy carefully to understand how we will treat your personal information. It describes what you can do if you have any concerns or complaints about the way we collect or process personal information.

We will act in accordance with the Commonwealth Privacy Act 1988, the New Zealand Privacy Act 1993 and, to the extent it is relevant, the General Data Protection Regulation (GDPR) 2016/679 that stipulate how organisations should manage the collection, use and disclosure of personal information.

GDPR applies to Cengage Australia as Cengage have offices in the European Union. When processing your personal information, our lawful basis is:

Legitimate interest to fulfil any contractual agreements between you and us if you are an existing or prospective customer
Consent obtained prior to promoting our services to you

What kinds of information do we collect?

The Personal Information we collect is for the purposes of administering the terms of your service/s and conducting business transactions with you. This information includes (but is not limited to)

Personal information	Use
Name	To create an account and, subsequently, verify your identity
Email address	To identify you on login to our applications and contact you (including for surveys, competitions or promotions)
Address	To send materials to you or communicate with you
Phone number	To call or send SMS messages
Date of birth/age	To determine appropriate data retention rules to apply to your account
Occupation	To customise offers
School affiliation	To target materials accurately to your needs
Area of study	To provide you with information about new or existing products and services
Grades	To support your teacher's tuition
Expected graduation date	To ensure that you are complying with our terms and conditions
Purchase history	To support product queries
Content use	To determine time spent on materials and in-product assessments
Credit card information	To transfer to our third-party payment provider (this information is never stored by us)
Banking information	To process royalty payments

How do we collect personal information?

We may collect information directly from you, from a third party, from our website or from your IP address.

Collection type	Details
Directly from you	When you register for a service, purchase a product, complete a form, call or email us, promotional events, surveys, questionnaires, business card exchange or when you engage with us on social media (e.g. blogs and forums)
From a third party	From a sales representative, school or educational body
From our website	Using cookies (small files that are stored on your computer) and web server logs to collect information about how our websites are used. Cookies help us to recognise computers that have accessed our websites. We use this information to improve the websites and customer experience. This information may include the date and time of visits, the pages viewed, time spent at our website and the websites visited just before and just after our website. This information is collated on an aggregate basis, and may also be associated with your personal information.
From your IP (Internet Protocol) address	To identify your geographical location and to diagnose and resolve problems accessing our products and services or in aggregate to understand where our products and services are being used. Your IP address may also be used when you are buying our products to ensure that you only buy products that we are entitled to sell in your location

A special note about children

We collect information about children in order to deliver a product or service. We do not market to children. Parents must consent to the collection and use of personal information for any child under the age of 18.

How do we protect personal information?

We are committed to protecting the security of your personal information and we take all reasonable precautions to protect it from unauthorised access, modification or disclosure. We will also take all reasonable steps to ensure vendors comply with secure handling of your personal information.

We employ website encryption on pages that contain personal information and encrypt personal data at rest.

We encourage the use of complex passwords (incorporating upper and lower case letters, at least eight characters, at least one special character and at least one number) to secure user accounts.

Notification of data breach

In accordance with obligations under relevant data protection laws, we will inform the competent regulatory authority and affected individuals without undue delay in the event of a personal information data breach. We will provide all relevant information relating to the data breach as part of our notification. We will use reasonable endeavours to assist you in mitigating the adverse effects of any data breach.

How do we disclose personal information?

We may disclose personal information to provide services to you (for example, we outsource mailing to a courier and will provide your personal information accordingly when you purchase material from us to send that material to you) and to advise you about our new or existing services.

We engage with third party applications including, but not limited to, ServiceNow, Google Analytics, Dynatrace and Splunk to provide customer support, website usage information, application performance and security monitoring functions. Some of these applications may contain personal information.

We may also disclose personal information when required by law.

Do we transfer personal information to overseas recipients?

We may transfer personal information to the United States, as necessary to provide services. In this instance we have standard contractual data protection clauses in place to protect your data.

Opting out

You may elect not to receive future communications by sending an e-mail stating your wishes to anz.privacy@cengage.com or by completing the form at https://cengage.com.au/unsubscribe

Rights of individuals

Right	Details
Quality of information	We will take reasonable steps to ensure the personal information we hold about you is accurate, up-to-date and complete.
Access to personal information	You can access the personal information we hold about you. Your personal information will usually be available within 14 business days of your request (subject to allowable exemptions). We will let you know if additional time is required.
Rectifying personal information	You have a right to ask us to correct any inaccurate personal information we hold about you. We will take reasonable steps to correct your personal information to ensure it is accurate, up-to-date, complete, relevant and not misleading.
Erasing personal information	Where one of the grounds specified in Article 17 of the GDPR applies, you have a right to ask us to erase any personal information we hold about you. We will do that without undue delay.
Right to withdraw consent	Where applicable under GDPR, if we have collected and processed any personal information on the basis of your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
Right to object and data portability	Where applicable under GDPR, you can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information to another provider.
Right to object to automated profiling	Where applicable under GDPR, you can object to decisions being taken based solely on automated means, including profiling, which produce legal effects concerning you or similarly significantly affect you.
Exercising rights	You can exercise any of these rights by contacting us using the contact details provided below. We may require evidence of your identity when processing your request to access, rectify, erase, port or cease profiling your personal information. We will process your request as soon as reasonably practicable, provided we are not otherwise prevented from doing so on legal grounds. If we are unable to meet your request, we will let you know why.

?Important Information for EEA Residents

1. Information about Cengage

Cengage is providing this supplemental privacy notice to give individuals in the European Economic Area (EEA) the additional information required by the EU General Data Protection Regulation. These provisions, together with the statements in the Cengage Privacy Notice, explain our practices with regard to EEA personal data.

This information is being provided by Cengage, Inc. for itself and its subsidiaries:

Cengage, Inc.
Privacy Office
200 Pier 4 Boulevard, Suite 400
Boston, MA. 02210
Cengage, Inc. is based in the United States.

Our representative in the EEA is:

Cengage Learning (EMEA) Limited
Cheriton House
North Way
Walworth Business Park
Andover
Hampshire
SP10 5BE
Registration Number: Z2487772

2. The Purposes and Legal Basis for Processing, including Legitimate Interests

The Cengage Privacy Notice explains the reasons why we process your Personal Information. We only process Personal Information when we have a legal basis for the processing, such as:

To fulfil a contract with you or your school

For closely-related purposes, such as payment processing and financial account management, contract management, website administration, business continuity and disaster recovery, security and fraud prevention, corporate governance, reporting and legal compliance

With your consent (or provided you have not objected, as may be appropriate under applicable law), such to provide you with marketing communications ?

We may also process your Personal Information for the purposes of our legitimate interests (or for the legitimate interests of your school, provided that such processing shall not outweigh your rights and freedoms.) In particular, we may process your Personal Information as needed to:

Protect you, us or others from threats (such as security threats or fraud) or cheating,?

Comply with the laws that are applicable to us around the world,

Enable or administer our business, such as for quality control, consolidated reporting, and customer service,?

Manage corporate transactions, such as mergers or acquisitions, and ?

Understand and improve our business or customer relationships generally.

3. Automated Decision-Making and Profiling

We may use profiling and analytics to understand how individuals interact with our educational materials, such as assess engagement and improve learning outcomes, and product development purposes. For example, we may use analytics to study the amount of time that individuals spend on specific content items and we may infer engagement from this process. These analytics also help us understand and improve our materials, as we can determine what materials are more or less accessible to students. We may also use analytics for course integrity purposes, such as to identify individuals that may be cheating.

We will not make automated decisions about you that may significantly affect you, unless (1) the decision is necessary as part of a contract that we have with you, (2) we have your explicit consent, or (3) we are required by law to use the technology.

4. When You are Required to Provide Personal Information to Cengage

In most cases, you are not required by law to provide any Personal Information to Cengage. You are required to provide certain Personal Information to enable us to enter into a contract with you so that you can use our products and services. Our registration forms indicate which data elements are required for our contracts. If you do not provide these data elements, we cannot do business with you.

5. International Transfers

As noted above, your Personal Information may be transferred to, stored at or processed in the United States and other countries which may not have equivalent privacy or data protection laws.?

We generally use approved Standard Contractual Clauses to assure that Personal Information is adequately protected when it is transferred out of the European Economic Area or Switzerland, but we may also make transfers to recipients with approved Binding Corporate Rules or to recipients in the United States who have certified to the EU-US and/or Swiss-US Privacy Shield Framework.

Please contact us via email to anz.privacy@cengage.com if you would like more information about cross-border transfers or to obtain a copy of the Standard Contractual Clauses.

6. Data Retention

We will retain your Personal Information for as long as the information is needed for the purposes set forth in Section 3 above and for any additional period that may be required or permitted by law. You may request that we delete your Personal Information. To do so, submit a?“right to be forgotten” form?and follow the instructions and prompts. Unless we are required by law to retain your information, we will delete it within 30 days of your request.

7. How to Contact Us

Please contact us if you have any questions or comments about our privacy practices or this Privacy Notice. You can always reach us via email, anz.privacy@cengage.com. You can also reach us via mail to the addresses given above.

How can you contact us or raise a concern or complaint about how we have collected, used or disclosed your personal information?

You may contact us to update your personal information, or request access to the personal information that we hold about you by emailing anz.privacy@cengage.com. You may also contact us via the Contact Us link on our website, https://cengage.com.au/contact-us, by phone on 1300 790 853, or by writing to us at the address listed below.

If you have concerns or would like to make a complaint about the way that we have collected, used, stored or disclosed or otherwise handled your personal information, please contact our Privacy Steward:

Sandra Hamilton
Privacy Steward
Cengage Learning
Level 7, 80 Dorcas Street
South Melbourne Vic 3205

Email: anz.privacy@cengage.com

Our Privacy Steward will endeavour to:

Provide an initial response to your query or complaint within 3 business days; and
Investigate and attempt to resolve your query or complaint within 30 business days.

If you are not satisfied with the outcome you may contact us again or may wish to contact the Australian Privacy Commissioner in writing at the following address:

Australian Privacy Commissioner, OAIC, GPO Box 5218, Sydney NSW 2001

Changes to our Privacy Policy

We reserve the right to change this Policy at any time, and any amended Policy is effective upon posting to this Website. We will make every effort to communicate any significant changes to you via email or notification via the service. Your continued use of the Service will be deemed acceptance of any amended Policy.

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