1. About This Policy

   • This Privacy Policy (Policy) applies to The Global Refugee Academy ABN 51 673 717 149 ("TGRA", "we", "our" or "us").
   • The Global Refugee Academy seeks to support refugees with relevant learning content, provided safely, to help their prospects of securing pathways to safety, with enhanced settlement outcomes supported by meaningful income-earning opportunities.
   • This Policy does not apply to:
     • job prospective students;
     • employees;
     • program participants
     • volunteers (or applicants for volunteer positions).

If you are one of these individuals, please see our separate privacy policy, which can be made available on request.

• We understand the importance of protecting your personal information. This Policy outlines the types of personal information that we usually collect, the purposes for which we collect it, to whom we disclose it, and how we hold it and keep it secure.  It also outlines how to access or correct your personal information, how to make a privacy complaint and how we deal with complaints. 
• In this Policy, personal information means any information or opinion about an identified individual or an individual who is reasonably identifiable, whether true or not. It does not include information that is de-identified.
• We may change this Policy from time to time, by publishing changes on our website.

2. Types of Personal Information We Collect
   

   • The types of personal information we collect about you depends on the dealings you have with us, and may include:
     • your name, address, email address and phone number; and
     • your interests and preferences.

3. Dealing With Us Anonymously or Using a Pseudonym
   

   • Where possible and lawful, you may interact with us anonymously or using a pseudonym. For example, if you contact us with a general question we will not record your name unless we need it to adequately handle your question.
   • However, for many of our functions and activities we usually need your name, contact information and other details to enable us to provide our services or products to you.

4. Ways We Collect Your Personal Information
   

   • We collect personal information about you when you interact with us, e.g. when you complete a form on our website or email us.

5. Collection of Information Via Our Website
   

   • When you visit our website, we may also use 'cookies' or other similar tracking technologies that help us track your website usage and remember your preferences. Cookies are small files that store information on your computer, mobile phone or other device. They enable the entity that put the cookie on your device to recognise you across different websites, services, devices and/or browsing sessions. You can disable cookies through your internet browser but our website may not work as intended for you if you do so.
   • Whilst we do not use browsing information to identify you personally, we may record certain information about your use of our website, such as which pages you visit, the time and date of your visit, search engine referrals and the internet protocol address assigned to your computer.
   • Our web pages may contain electronic images, known as web beacons. These electronic images enable us to count users who have visited certain pages on our website. Web beacons are not used by us to access your personal information, they are simply a tool we use to analyse which web pages are viewed, in an aggregate number.

6. Purposes For Which We Collect, Use and Disclose Personal Information
   

   • We collect, use and disclose your personal information for the following purposes:
     • to educate and train our staff
     • to manage our relationships with you;
     • to help us provide, manage, develop and enhance our services, including our website; and
     • to comply with our legal obligations.
     • to receive services from our suppliers and business partners

7. Disclosing Your Personal Information
   

   • We may disclose your personal information to the following:
     • organisations we contract to provide services on our behalf such as software suppliers;
     • our professional advisers, including lawyers, accountants and auditors;
     • anyone to whom part or all of our assets or businesses are transferred or sold; and
     • government agencies, regulatory bodies and law enforcement agencies, or other similar entities.
   • We do not currently disclose your personal information to third parties located overseas.

8. Direct Marketing
   

   • We may, with your consent where required, use your personal information to identify a product or service that you may be interested in and to contact you from time to time (including by phone or email) to tell you about products, services, news, deals and other information we believe could be of interest to you.
   • You can opt-out of receiving direct marketing communications from us at any time by unsubscribing from the mailing list via email to info@globalrefugeeacademy.org

9. Security and Storage
   

   • We store your personal information electronically with a third party data storage provider. We take all reasonable steps (including organisational and technological measures) to protect your personal information from misuse, interference and loss, as well as unauthorised access, modification or disclosure.
   • We only keep your personal information for as long as it is required for a purpose for which the information may be used or disclosed under the Privacy Act 1988 (Cth) or as otherwise required by applicable laws. If we no longer need to hold your personal information for any reason or we are no longer required by law to keep it, we will take reasonable steps to de-identify or destroy that information. These steps may vary depending on the nature of the information, the way it was collected and how it was stored.

10. Access To And Correction of Your Information
    

    • We will endeavour to ensure that the personal information collected from you is up to date, accurate and complete.
    • You may request access to, or correction of, the personal information we hold about you at any time by contacting the People & Partnerships Manager by using the details set out in the CONTACT US section below.
    • We may need to verify your identity before responding to your request. Subject to any applicable exceptions or requirements, we will respond to your request within a reasonable time and usually within 28 days. If we decide to refuse your request, in most circumstances we will tell you why in writing and how to complain.

11. Complaints

    • You can make a complaint in writing to the People & Partnerships Manager using the details set out in the CONTACT US section below. We will respond to you within a reasonable period of time to acknowledge your complaint and inform you of the next steps we will take in dealing with your complaint.
    • If you are not satisfied with our response, you may complain to the Office of the Australian Information Commissioner (OAIC) via the OAIC website, oaic.gov.au.

12. Contact Us
    

    • If you have a question or comment regarding this Policy, wish to make a complaint, or wish to request to access or correct your personal information, please contact the us using the following details: info@globalrefugeeacademy.org

Dated: October, 2024