Marketing privacy notice

The International College of Manitoba (ICM) is a partnership between University of Manitoba (UM) and global education provider Navitas Pty Ltd.

The Marketing Privacy Notice explains how Navitas Pty Ltd collects, uses, processes, and keeps your personal data safe on behalf of The International College of Manitoba (ICM) and University of Manitoba (UM) for marketing purposes.

Welcome to our Privacy Notice. This notice explains how we, Navitas Pty Ltd, collect, use and otherwise process your personal data, as well as how we ensure that your information is kept safe.

Introduction

Navitas respects your right to privacy. This privacy notice explains who we are, how we collect, share, and use personal information about you, and how you can exercise your privacy rights. This Privacy Notice applies to data collected about all users of www.navitas.com and websites of our subsidiary companies, and other related websites, (the “Website”) and the services available on the Website (the “Services”).

Navitas reserves the right to make changes periodically to this Privacy Notice at our sole discretion. Changes to the Privacy Notice will be posted on this page.

Who is Navitas?

Navitas is a global education provider (ABN 69 109 613 309). Our head office is in Perth, Western Australia at the following address:

Navitas Pty Ltd

Level 9

143 St Georges Terrace

PERTH WA 6000 Australia

The Company has subsidiary companies and affiliated organisations operating in Australia, New Zealand, Canada, UK, Europe, Africa, Southeast Asia, North Asia, South America, the Middle East, and the USA, collectively called the “Company”.

The European head office is in the UK at the following address:

Navitas UK Holdings Limited

The Lambourn

Wyndyke Furlong

Abingdon

OX14 1UJ

United Kingdom

You can contact Navitas for any privacy related questions or concerns, from any country in the world by emailing the Privacy Team at privacy@navitas.com

The personal data we are collecting from you and how we will use it

We are collecting the following personal information to send you electronic marketing, both directly from Navitas and from our trusted partners. We also use your personal data for our internal sales people to contact you about opportunities.

The following personal data is collected on our forms, but may not contain all the information fields below, those will depend on your circumstances and the course you are applying for.

First Name
Last Name
Email Address
Telephone Country Code
Mobile
Nationality
How you intend to fund your studies with us.
Current level of schooling being undertaken.
When would you like to start studying.
Program type you are interested in studying.
Course you are interested in.
City of Residence
In which country you wish to study in
Desired college
Current Year Level

You have the right to stop the use of your personal data for marketing activity through all channels, or selected channels. We will always comply with your request. If you wish us to stop marketing you, at any time, please click the ‘unsubscribe’
link in any email communication that we send.

Please note that you may continue to receive communications for a short period after changing your preferences while our systems are fully updated.

You will have made a clear indication of your consent to marketing by Navitas via a box you ticked, or by adding your email address when prompted. If this is not the case, please contact privacy@navitas.com.

We won’t share your information with any other organisation, all the marketing we send you, even if it is about our trusted partners, will come from Navitas.

The lawful basis for collecting and processing your personal data

Navitas are using Consent to collect your personal data and send you electronic marketing.

This means you have provided us with your consent, and you can withdraw it at any time and we will stop marketing to you.

You will find our unsubscribe link at the bottom of any emails we send to you, and if you have consented to us sending you marketing by any other means, you can contact us at privacy@navitas.com and request that we stop.

How long do we keep your Personal Data?

We have a detailed records management program in place and all records (paper and electronic) are required to be managed in accordance with its security and disposal steps.

Your personal data, collected for marketing purposes, is kept for 6 years at which point it will be securely deleted. This retention period is based on proven success and engagement with Navitas via its marketing campaigns over a 5–6-year period.
However, as confirmed throughout this privacy notice, if you wish to stop receiving marketing information, use the unsubscribe button or update your preferences and Navitas will stop marketing you.

Sharing your Personal Data

The only recipients of your personal data outside of Navitas are software suppliers who provide Navitas with the systems/software to which we market you from.

There are data processing agreements in place with these suppliers, to ensure they protect your personal data as Navitas does. These agreements are in our contracts and hold suppliers to an extremely high level of security.

Processing and Transferring your Personal Data

Navitas is a global organisation. We have operations in many different geographic regions and our head office is in Australia, therefore, we will sometimes need to share your personal data internationally with our marketing teams.

Where your personal data is shared internally across Navitas and the countries it resides in, there is an Intra-Group Data Sharing Agreement, which includes the required safeguards.

With regards to external sharing of your data, outside of Navitas, the below table lists the suppliers/vendors used, where in the world your personal data is transferred to, and the contractual and international safeguards in place to protect your personal
data.

System/Software	Transfers data	Transfer safeguards
Marketo	Australia	Data Processing Agreement/Standard Contractual Clauses
Salesforce	Japan	Data Processing Agreement/Standard Contractual Clauses
One Trust	Germany	Data Processing Agreement
MailChimp	Worldwide	Data Processing Agreement/Standard Contractual Clauses
Google	Worldwide	Data Processing Agreement/Standard Contractual Clauses
Meta	Worldwide	Data Processing Agreement/Standard Contractual Clauses

Your rights over your Personal Data explained

Navitas is using Consent as the lawful basis for processing your personal data for marketing purposes. This means you have a legal right to withdraw your consent, at any time, and Navitas will stop sending you marketing information.

However, under privacy legislation, you also have other Rights when it comes to the personal data Navitas collects and uses for marketing purposes.

The rights you have may be different depending on where you live in the world, or where in the world Navitas is using your personal data.

If your country is not listed below, please contact privacy@navitas.com for further information.

If you live in the UK or the EU (including Liechtenstein, Norway, and Iceland) your rights are listed below.

Right of access – Request a copy of the personal data Navitas holds on you.
Right to rectification
Right to erasure
Right to restriction of processing
Right to Portability
Right to object and automated individual decision-making
Right to object
Automated individual decision-making, including profiling

If you live in Australia, you have the right to:

Request anonymity and pseudonymity
Request for information not to be used for marketing purposes
Access and review personal data we hold about you
Rectify/correct any inaccurate personal information we hold about you

If you live in New Zealand or Canada, you have the right to:

Access and review personal data we hold about you
Rectify/correct personal data we hold about you

If you live in the United States of America, you have the right to:

Access and review personal data we hold about
Rectify/correct personal data we hold about you
Be informed of any disclosures
Request deletion of your information

For any questions or queries, no matter where in the world you are located, please email privacy@navitas.com.

Questions or Issues you may have

If you are contacting us to complain about an alleged breach of this Privacy Notice, or you have a question, please provide us with as much detail as possible so that we can deal with your concern quickly and effectively.

We will take every privacy complaint seriously and assess it with the aim of resolving the issue swiftly.

Our Contact Details

If you wish to speak with the DPO for Navitas and raise any queries or concerns, they can be contacted via privacy@navitas.com

Contacting your Supervisory Authority

If you need to make a complaint about how Navitas collects and uses your personal data, we kindly ask that you contact us in the first instance on privacy@navitas.com. The Regulators, no matter what country they reside in, would prefer that Navitas
tries to resolve any issues with you first before you contact them.

However, the Regulators are there for your concerns, and if you feel Navitas has not handled your complaint appropriately, we encourage you to contact them. Navitas is committed to the open and transparent processing of your personal data and welcomes
the Regulators view.

You may contact the Regulator in whichever country you live and details of them can be found via a quick Google search if you are not already aware of them. Alternatively, please reach out to our privacy team for advice, they will be happy to assist
you.

Europe (inclusive of the UK and non-EU Member States)

Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Email: casework@ico.org

Telephone: 0303 123 1113

Website – www.ico.org.uk

Australia

Australian Information Commissioner (OAIC)

Telephone +61 1300 363 992

Email: enquiries@oaic.gov.au

Website: www.oaic.gov.au